green homes service consultation: clg response

8/14/2019 Green Homes Service Consultation: CLG Response

1/18

The Next Steps: EPCS and the establishment o theGreen Homes Service: ConsultationSummary o responses

www.communities.gov.ukcommunity, opportunity, prosperity


2/18


3/18

The Next Steps: EPCS and the establishment o theGreen Homes Service: ConsultationSummary o responses

July 2009Department for Communities and Local Government


4/18

Communities and Local GovernmentEland House

Bressenden PlaceLondon

SW1E 5DUTelephone: 020 7944 4400Website: www.communities.gov.uk

Crown Copyright, 2009

Copyright in the typographical arrangement rests with the Crown.

This publication, excluding logos, may be reproduced ree o charge in any ormat or medium or research,private study or or internal circulation within an organisation. This is subject to it being reproduced accuratelyand not used in a misleading context. The material must be acknowledged as Crown copyright and the titleo the publication specifed.

Any other use o the contents o this publication would require a copyright licence. Please apply or a Click-Use Licence

or core material at www.opsi.gov.uk/click-use/system/online/pLogin.asp, or by writing to the Ofce o Public SectorInormation, Inormation Policy Team, Kew, Richmond, Surrey TW9 4DU

e-mail: [email protected]

I you require this publication in an alternative ormat please email [email protected]

Communities and Local Government Publications

Tel: 0300 123 1124Fax: 0300 123 1125Email: [email protected] via the Communities and Local Government website: www.communities.gov.uk

July 2009

Reerence Number: 08 EPBD 05540

ISBN: 978-1-4098-0501-4


5/18

Contents

Page

Introduction 5

Summary o responses to consultation 6

Conclusion 13

Annex A List o respondents 14


6/18


7/18

Introduction 5

Introduction

On 23 June 2008 the Government published a consultation on the ollowing issues:

TogivetheESTaccesstotheinformationcontainedindomesticEPCssothatthey

can identiy F and G rated homes and target them with an oer o advice and help

TogivetheCarbonTrustaccesstotheinformationcontainedinnon-domesticEPCs

ToallowenergyassessorstosearchtheregisterbyaddressaswellasbyUPRN

Toallowpublicaccesstothenon-domesticregisterinordertoseewhethera

building has an EPC, but not to download or access the EPC.

The consultation asked three questions:

1. What are your views on these proposals?

2. Do you think the saeguards proposed on access to the registers are

sufcient?

3. I you do not think the saeguards are sufcient what are the reasons or

your opinion, and are there other saeguards that you can suggest to meet

your concerns?

The consultation closed on 1 September. This document summarises the responses and

gives the Governments view.


8/18

6 The Next Steps: EPCS and the establishment o the Green Homes Service: Consultation

Summary o responses to consultation

For access, in ullor in part

Against access, inull or in part

No comment Total

30 6 9 45

67% 13% 20% 100%

Issues raised in responses

Proposal Issues raised Comments

To give the EST accessto the inormationcontained in domesticEPCs so that they canidentiy F and G ratedhomes and target themwith an oer o adviceand help

Data should not be passedon to any third party bythe EST. There is a dangero homeowners becomingthe target o indiscriminateadvertising. More details areneeded on the proposedsaeguards.

What fnancial incentiveswill be put in place tohelp buyers implementrecommendations?

How will EST ensure detailsreach the buyer?

Will EST write to tenants or

to landlords? I the ormer,will tenants receive multiplemailings?

It would be helpul or theEST to publish aggregateddata

The Government agrees.Data will be supplied tothe EST under the termso a Memorandum oUnderstanding, andany breach will lead toimmediate withdrawal oaccess. The MoU will spellout amongst other thingswhat saeguards are to be

adopted.

A range o incentives arealready in place throughschemes such as Warm Frontand CERT.

This is a matter or the EST.

This is a matter or the

EST. But there will not bemultiple mailings: they willbe controlled by the ESTthrough a mailing house.

The Government agrees.The inormation on theEPC registers will over timebuild up into an invaluableresource or tracking theenergy efciency o thenations building stock.Stakeholders will be invitedto help ormulate a strategyor the use and publicationo this data.


9/18



Inormation should not

be limited to F and Gproperties. Signifcantrecommendations or energyefcient measures may becontained in properties withC,D and E ratings.

In order to write to all F andG rated properties, the ESTand CT will need to identiythese properties. Thereore it

appears that the inormationcannot be supplied in sucha way as to be anonymousas mentioned in theconsultation.

I the government is keento educate people aboutmaking their F and G ratedproperties more energyefcient, it might be easier,and certainly pose ewerdata protection concerns, torun an advertising campaignin the national media.EST and CT data handlingprocesses should bedemonstrably transparentand both organisationsshould put in place systems

or responding to validdisputes.

Other organisations shouldbe oered access to thedata.

The Government will

consider this in due course aspart o the evaluation o theGreen Homes Service.

EPCs are supplied orproperties, not individuals.EPCs will make it clear toconsumers that inormation

will be made available to theEST.

The Government hasalready undertaken a majoradvertising campaign, Act onCO

2

The Government agrees.Data will be supplied tothe EST under the termso a Memorandum oUnderstanding, and

any breach will lead toimmediate withdrawal oaccess.

The Government has noplans to do so but is willingto listen to representations.


10/18



To give the Carbon

Trust access to theinormation containedin non-domestic EPCs

The proposals about how

the Carbon Trust will usedata need to be morespecifc.

Data should not be passedto any third party by the CT.

Other organisations such asNIFES and ESTA should alsobe given access to the data.

It would be helpul or theCarbon Trust to publishaggregated data.

The Government will work

with the Carbon Trust andstakeholders to developmore specifc proposals orlegislation in the Spring.

The Government agrees.Data will be supplied tothe CT under the termso a Memorandum oUnderstanding, andany breach will lead to

immediate withdrawal oaccess

The Government will workwith the Carbon Trust andstakeholders to developmore specifc proposals orlegislation in the Spring

The Government agrees.The inormation on theEPC registers will over timebuild up into an invaluableresource or tracking theenergy efciency o thenations building stock.Stakeholders will be invitedto help ormulate a strategyor the use and publicationo this data.


11/18



To allow energy

assessors to search theregister by address aswell as by UPRN

There are concerns that

assessors will misuse accessby selling on data since theywill have access to marketinormation not available toothers.

Landlords should be givendirect access to the register.

Energy Assessors shouldhave access to RdSAP. Thiswould provide assessors withuller data than is availablerom the EPC alone.

The proposals all ar shorto providing reasonableaccess to the data currentlyheld in the national registerso EPCs.

The Government will work

with accreditation schemesto ensure such abuses do nothappen. Any assessor oundto have misused access willimmediately be removedrom the register and will nolonger be able to work as anassessor.

The Government has noplans to do so.

The Government willconsider this in due course.

The Government isconsidering a long-termstrategy or the data held inEPCs.


12/18



To allow public access

to the non-domesticregister in order to seewhether a buildinghas an EPC, but not todownload or access theEPC

There is a danger that the

public will misunderstandthe ratings given on an EPC.

EPCs or schools should bemade available to Dept orChildren, Schools & Families

so schools can be moreenergy efcient.

The current proposal isunworkable, as there isa duplication o eort byLandmark. An alternativeapproach is that assessorsgain access via the IT systemsalready in place within theaccreditation schemes.

The public will not have

access either to the EPCor the rating. They will beable only to see whethera building has an EPC.This is designed to avoidduplication and expense tosellers and landlords.

The Government willconsider this urther.

The Government will workwith the EST on setting upthe relevant structures andwill seek a ull evaluation othe results.

Land Registry Data fles shouldautomatically be issued toHM Land Registry

The Government has noplans to do so.

The consultationdocument

The title o the consultationwas misleading.

The title o the consultationreerred to all EPCs, domesticand non-domestic.


13/18



EPCs Local authorities should be

given access to the datacontained in EPCs.

The Land Registry should

be given access to the datacontained in EPCs. Thiswould allow a welcome packon energy efciency to besent to all new homeowners.

An explicit link should bemade to the HHSRS systemto ensure that householdsin homes with poor energyefciency were identifed.

The EPC needs to beimproved as a document

There is insufcient guidanceon the application o EPCs.

The inormation on the

EPC registers will over timebuild up into an invaluableresource or tracking theenergy efciency o thenations building stock.Stakeholders will be invitedto help ormulate a strategyor the use and publicationo this data.

The Government has no

plans to do so but is willingto listen to representations.

The Government has noplans to do so but is willingto listen to representationsand to explore the issuesurther.

There is an ongoing processo change control andimprovement to the contentand ormat o EPCs overseenby two technical steeringgroups.

The Government publishedguidance on commercial

EPCs in January; an updatedversion was published in thesummer. Guidance can alsobe obtained rom the CLGwebsite and rom the EPBDhelpline.


14/18



The role o energy assessors

should be expanded toinclude the giving o energyadvice based on an EPC.

EPCs should be required orall lets and not just those osel-contained dwellings.

The Government is working

closely with energy assessorson the uture developmento their role.

The Government haslegislated in terms o itsunderstanding o therequirements o the EPBD.

Other issues The Government hasmade insufcient use o

the expertise o propertyexperienced individuals indeveloping its proposals.This does a disservice to theproud traditions o our civilservice.

Householders need clearguidance on cost eectiveimprovements and where togo or trusted qualifed tradepersons.

Main ocus o theconsultation appears to bethe need or behaviouralchange to encourage energyefciency in homes. Thisneeds to be monitored

closely.

There is a need or a greatlyimproved scientifc andempirically well oundedknowledge base on buildingsenergy use in the UK.

The Government hasdeveloped policy on EPBD

with the assistance onine stakeholder groupscomprising a wide rangeo interests includingproperty experiencedindividuals, representativeproperty organisations andcommercial property lawyers.

The Government agrees.

The Government agrees. Theimplementation o the GHSwill be evaluated.

Over time the inormationcontained on the EPCregisters will provide such aknowledge base.


15/18

Conclusion 13

Conclusion

The Government is grateul to all those who responded to the consultation.

The large majority o respondents supported the proposals or access although a number o

valuable points were made about the need or adequate data protection and protection o

consumers. The Government will consider these careully in implementing the proposals. In

particular it proposes to take urther time to work up detailed proposals or the Carbon Trust

to have access to the non-domestic EPC register, and will not thereore include this proposal in

the current package o legislation. A number o wider issues around access to and use o the

data contained in EPCs were also raised, and the Government will consider these.


16/18


Annex A

List o respondents

Companies who have provided eedback or the EST Consultation

1. Association or the Conservation o Energy

2. BCSC

3. British Property Federation

4. Chartered Institution o Building Services Engineers

5. Commission or Architecture and the Built Environment

6. Crosher James

7. Degree Days Direct Ltd

8. Energy Efciency Partnership or Homes

9. Energy Saving Trust

10. Gleeds

11. Goring Chase Residents Association Ltd

12. Government Contracts

13. Greater London Authority

14. Green Surveys Limited

15. Health and Environmental Action Services16. Home Energy Conservation Ofcer

17. Homes Matter

18. Jones Lang LaSalle

19. LAtelier

20. Local Government Association

21. London Borough o Richmond Upon Thames

22. National Energy Services

23. National Insulation Association

24. National Landlords Association25. Neighbourhood Services

26. Northgate Public Services

27. NTL World

28. Oil Firing Technical Association

29. RBWM

30. Reading Borough Council

31. Reigate and Banstead Borough Council

32. Royal Institution o Chartered Surveyors

33. Schools Capital Design Team

34. Sheldon Reed Ltd & SR Inspectors

35. Somerset County Council


17/18

Annex A 15

36. South Coast Home Inspectors

37. Stephenson Harwood

38. Surveys Ltd

39. Taylor Wessing40. The Energy Efciency Company

41. Trading Standards Institute

42. Tunbridge Wells Borough Council

43. University College London

44. WSP Energy

45. WWF


18/18

ISBN 978-1409805014

9 781409 805014ISBN: 978-1-4098-0501-4

green homes service consultation: clg response

Documents