Councils and housing associations warn on feasibility of setting minimum energy efficiency standard for socially rented homes

The Local Government Association (LGA) said in its response to a government consultation that councils wanted to tackle fuel poverty, but “we have concerns about the deliverability, affordability, and clarity of the proposals as currently set out in the consultation”.

This was because there was as yet no finalised Energy Performance Certificate (EPC) framework or Home Energy Model (HEM), both of which the LGA said were “central to understanding the implications of MEES”.

It added: “Without clarity on these foundational elements, it is difficult for local authorities with housing stock to assess the feasibility of the proposed standards or to plan effectively for compliance”. 

Once the HEM and reformed EPC framework were published, Government should work with experts to finalise appropriate target metrics for MEES rather then seek to set these earlier.

The LGA said the financial strains suffered by most housing revenue accounts meant adequate funding would be needed to implement MEES and “given the current issues regarding a skills shortage and limited supply chain capacity, a long-term strategy and funding agreement is needed to support local authorities with housing stock to implement MEES across their homes”.  

The Association of Retained Council Housing (ARCH) said its members had to ensure homes comply with the updated Decent Homes Standard, new fire and building safety requirements and other recent regulatory requirements.

“All of these are necessary but, as yet, Government has not answered the question of how simultaneous compliance with all of them can be funded from expected resources,” ARCH said.

“Against this background, compliance with a MEES will not be feasible for the great majority of local authorities without adequate dedicated financial support from Government.”

ARCH, which represents local authorities who have retained ownership and management of their council homes, said the consultation was premature because “we do not think it possible to give a definite or final answer on the proposed options for the MEES metric until the proposed grades for each of the metrics are finalised”.

It also said most local authorities had an ambition to reach EPC level C by 2030 but some had “simply not been able to fund the investment…in consulting on MEES before, or without offering, consultation on the new Warm Homes Fund, the Government is tackling things the wrong way round. It will only be possible to give a definite answer on the feasibility of compliance with MEES by 2030 when funding arrangements are finalised”.

G15, which represents London’s largest housing associations, said current proposals would require at least £10,000 to be spent on each home to reach minimum compliance, and in some cases this would “deliver little or no improvement in resident comfort or energy affordability”.

Government plans would force landlords to prioritise investment on short-term compliance rather than long-term outcomes, “and would likely mean further costly works on the same homes later to bring them in line with net zero carbon requirements”.

G15 said a longer, more joined-up timeframe would allow landlords to integrate energy efficiency works with other planned improvements, prioritise investment where it delivers the greatest benefit and avoid stop-gap or inefficient spending by allowing complex or high-cost homes to be upgraded correctly the first time.

It warned: “If the Government does not align MEES and the updated Decent Homes Standard to a 2037 target, then it is essential that a clear and robust carve-out is created for homes where compliance costs are disproportionately high.”

Where bringing a property to EPC C standard would require investment of up to £60,000, “it is not a proportionate or sensible use of resources to mandate an interim £10,000 spend by 2030 that will not achieve full compliance, nor the best outcomes for residents”, G15’s response said.

Mark Smulian