Wyre Forest District Council Home Energy Conservation Act (HECA) Report

Introduction
Headline and overview questions
Communications
Local green supply chains

Social housing

Domestic Private Rented Sector (PRS) Minimum Energy Efficiency Standards
Financial support for energy efficiency
Fuel poverty
The Energy Company Obligation
Smart metering
Future schemes or wider initiatives

Introduction

The Home Energy Conservation Act 1995 (HECA) requires local authorities (LAs) in England to submit reports to the Secretary of State demonstrating what energy conservation measures they have adopted to improve the energy efficiency of residential accommodation in that LA’s area. This covers measures to improve properties in the owner-occupier, private rented sector and social rented sector.

LAs are required to provide an update report every two years setting out the energy conservation measures that the authority considers practicable, cost-effective and likely to result in significant improvement in the energy efficiency of residential accommodation in the area. This report builds on previous reports setting out how Wyre Forest District Council intends to help householders take advantage of financial incentives such as the Energy Company Obligation (ECO) and the Green Homes Grant Local Authority Delivery Scheme (LADS) and any other schemes that became available. In addition it will also provide information on funding sourced and provided by the council.

The 2021 report details projects and work we have delivered since the last report in 2019 and also sets out our plans for the next two years to address home energy related issues across our district.

HECA Reporting 2021 Questions

Name of Local Authority: Wyre Forest District Council

Name, job title and email address official submitting the report:

Jennifer Moreton

Principal Health and Sustainability Officer

Jennifer.Moreton@wyreforestdc.gov.uk 

Headline and Overview Questions

1. Does your Local Authority have a current strategy on carbon reduction and/or energy efficiency for domestic or non-domestic properties?
   If yes, please provide a link
   If no, are you planning to develop one
2. What scheme(s) is your Local Authority planning to implement in support of energy saving/carbon reduction in residential accommodation properties in the next two years?
3. What has been, or will be, the cost(s) of running and administering the scheme(s), such as the value of grants and other support made available, plus any other costs incurred (such as administration) as desired.
4. What businesses, charities, third sector organisations or other stakeholders do you work with to deliver the scheme(s)?
5. What has been, or will be, the outcome of the scheme(s)? These outcomes could include energy savings, carbon savings, economic impacts such as job creation and/or increased business competitiveness or societal impacts such as alleviation of fuel poverty and/or improved health outcomes etc.

Wyre Forest District Council declared a climate emergency in May 2019. The Council set up an advisory panel to work closely with the council’s Cabinet on steps it can take to reduce the council’s carbon emissions. ‘Warm and Healthy Homes’ is one of the key themes of the Wyre Forest climate change strategy and the associated annual action plan sets out activities to support local residents and organisations in reducing their carbon footprint.

Wyre Forest District Council is currently delivering the Green Homes Grant Local Authority Delivery Phase 1A (GHG LADS 1A) in a consortium of Local Authorities in Worcestershire. We also have a statement of intent to facilitate ECO3 LA Flex for eligible residents in the District. Further details on these schemes are outlined separately below:

GHG LADs Phase 1a - £ 224,250 Government Grant for delivery and Administration Costs
GHG LADs Phase 2 – allocation of £572,250, of which administration costs are 9% The Midlands Energy Hub have funded the customer journey support element of the programme.
ECO Flex – delivered through our wider SLA with Act on Energy who check the eligibility of householders and measure suitability.

Wyre Forest District Council work with Act on Energy to deliver the Council’s energy advice and information service to residents. When residents contact Act on energy their circumstances are assessed and are then sign posted to the most appropriate support available, whether it be for grants for physical intervention measures, emergency heating, information, advice and guidance. The Charity also signpost and support with income maximisation and priority service registers. Act on Energy also work across the wider county to delivery fuel voucher scheme where they have accessed funding through EST redress and also the county council winter COVID-19 support fund where they have provided wider debt support for energy, alongside emergency heating and heating repair funding for residents.

Other Charity and third sector organisations the Council work with include ALEO Midlands, CAB, Age UK, and a wide range of local organisations such as food banks and wellbeing charities. The Council are also sit on the recently established Wyre Forest Green Alliance, a consortium of local community organisations working together to tackle climate change.

Between July 2019 and April 2021, 600 advice and information calls were taken by Act on Energy and the Council. This will have enabled residents to save money on their energy bills by supporting them out of fuel debt, supporting residents to access cheaper energy tariffs, advising on most efficient use of heating systems and sign-posting to fuel payment support. We provided advice at events to over 400 residents; this was unfortunately curtailed due to the pandemic.

Worcestershire Local Authorities in partnership with Act on Energy delivered a fuel voucher scheme as part of a COVID-19 crisis funding. This support assisted with payment of fuel bills and fuel debt as a result of the COVID-19 pandemic. In Worcestershire 998 households applied for assistance through the scheme with a total funding of £62,744. Of this total funding £16,940 provided support to fuel bills to over 269 households.

Local Communications Strategy

1. 1. Does your Local Authority provide any advisory services to customers on how to save energy?
   If yes, please briefly outline how this is undertaken.
2. 2. How do you communicate or encourage energy saving amongst domestic consumers and/or local businesses?

Act on Energy is a local energy charity that has over 22 years experience of providing energy advice. We fund Act on Energy to deliver and administer some of our domestic energy saving schemes and run the Council’s energy advice and information service.

This service provides a comprehensive and impartial energy efficiency advice service to the residents through a freephone telephone number. When residents contact Act on Energy their circumstances are assessed and are then sign posted to the most appropriate support available, whether this be a grant for energy efficiency measures, emergency heating, advice and information or a referral to another agency for ongoing support such as income maximisation or the priority services register.

Act on Energy also work with in the community to raise awareness of fuel poverty and raise the profile of the net zero agenda through presentations and training sessions to local groups.

In addition, Act on Energy provide a local community outreach programme, Heat for Health, promoting energy advice and energy efficiency measures within the community linking with local health professionals providing local awareness campaigns, training, advice and home visits. This ensures that the links to housing and health are made by health care professionals and they can refer patients directly into the service or via social subscribing.

Act on Energy provide the secretariat services for ALEO national and Midlands and we fin this a useful way to feed into consultations and also to network with other LA’s.

Advice and information is also included in the Council’s general communications with the public via online newsletters, website, social media etc.

Local Green Supply Chain

1. Have you made any assessment, or undertaken any analysis of the existing capacity in your local energy efficiency retrofit supply chain to support the decarbonisation of buildings by 2050? If Yes, please summarise the outcomes.
2. What actions are you taking, if any, to upskill and/or grow the local energy efficiency installer supply chain? This could include the facilitation of training, and local installer networking opportunities.
3. What actions are you taking, if any, to promote energy efficiency and the installer supply chain to consumers, and encourage households to consider energy retrofit?
4. If no action is taking place in either of these two areas, please let us know of any barriers you have encountered.
5. How effectively is your LA able to engage (Trustmark/PAS2035/PAS2030 certified) installers?
6. Do you have any plans to develop policies or initiatives in this space over the next five years as part of supporting your local decarbonisation efforts?

The Worcestershire LEP along with partners at the Midlands Energy Hub has undertaken an assessment of Low Carbon Environmental Services and Goods. This highlights the low carbon sectors across the District and the county.

We are working with our LEP partners on this agenda and it forms a part of Worcestershire’s Energy Strategy to assess and look at ways to grow the low carbon economy across the county.

Through our partner Act on Energy, eligible residents are offered support through one of the various grant schemes available. Act on Energy also work closely with front line members of staff to provide training to them on fuel poverty issues and to encourage referrals to our schemes. Between July 2019 and March 2020, 34 front line staff were trained by Act on Energy. Act on Energy has a dedicated website describing the various grants, advice and support available for residents, including an installer network. Act on Energy work with local contractors for physical intervention scheme to install measures and promotion national and local grants.

The past year has been a challenging time to promote energy efficiency installs in homes due to the COVID-19 pandemic. Residents have understandably been reluctant to allow people in their homes especially with vulnerable households often requiring assistance. This has therefore led to reduced numbers of households applying for physical measures.

Social Housing

1. What action, if any, has your LA taken to install energy efficiency or low carbon heat measures in social housing? Have these been installed to a satisfactory quality? What actions (if any) have your social housing partners taken?
2. Do you have easy access to the information/knowledge within your organisation that you would expect to need for social housing retrofit projects? (e.g. stock condition; property data; approach to procurement; alignment with existing internal maintenance/upgrade plans; tenant engagement and management plans; costings)
   If no, would it be easy/difficult to obtain this information?
3. Have you experienced any challenges to retrofit, including during any previous government schemes you have taken part in (e.g. supply chain, funding, tenant cooperation, mixed tenure, split incentive, policy clarity, etc)? Please provide some detail. Have social housing partners reported any challenges to retrofit?
4. How does your LA currently/how will your LA in future plan to go about identifying suitable housing stock and measures for retrofit? How do social housing partners identify suitable stock? By the same measures or via a different method?
5. What considerations would make you more or less likely to apply for government funding? If known, what is the opinion of your social housing partners?
6. To what extent are social housing tenants willing or unwilling to undergo retrofit, and what are the barriers and facilitators to their participation? If known, is this the same opinion across all social housing tenants or is it different with HA and ALMO tenants?
7. Does the approach to retrofit change for leaseholders in mixed tenure blocks? What encourages them to co-operate?

WFDC does not own any housing. Community Housing Group own the ex-council housing stock and their actions include:

• investment programmes for replacement doors and windows
• investment programmes for replacement heating systems with energy efficient boilers
• a strategy for removing low efficiency secondary heating appliances
• programme of loft insulation top-up previously completed bringing loft insulation up to a 300mm minimum
• a programme of external wall insulation completed for our Pre-cast Reinforced Concrete homes
• Set aside funding in Group Business Plan for energy efficiency / carbon reduction services and works - £13.4m for life of plan
• Recruiting an Energy Manager to drive forward carbon reduction strategy

Community Housing Group:

• Hold Stock Condition data and energy performance data on our assets
• Have Stock Condition Survey data validated by independently by Savills
• Investment and maintenance programmes are planned within our asset management software – based on lifecycle renewals
• Stock Condition Survey data and resultant investment and maintenance programmes costs feed in to Group Business Plan
• Full funding is allocated within the Group Business Plan (funding sufficiency validated by Savills)
• Tenant engagement is overseen by our tenant led Customer Voice and Assurance Group

Challenges:

• Sometimes difficult to gather the data required and produce a quality bid in the timescale
• Funding requirements can be complex
• Availability of alternative energy technology at cost effective pricing is a challenge
• When funding “kick-in”, installers are fully committed on larger projects leaving smaller projects struggling to find resources to complete on time

Use of the Stock Condition Survey data and energy performance data held on social housing assets. Any queries / anomalies will be resolved through CHG’s in-house Stock Condition Surveyors and energy assessors

Recruitment and appointment of our proposed Energy Manager will ensure a dedicated resource to focus on gaining grant funding to support of improvement works.

To what extent are social housing tenants willing or unwilling to undergo retrofit, and what are the barriers and facilitators to their participation? If known, is this the same opinion across all social housing tenants or is it different with HA and ALMO tenants?

Generally speaking, our tenants are receptive to modernisation and improvement works that are rolled out under our DHS programmes. Having said this we do have some refusals. We work with our tenants to understand their reasons for refusing, which of course may be due to temporary concerns. In these circumstances we work with the tenant to alleviate their concerns and / or agree a date that would be suitable for the works.

Does the approach to retrofit change for leaseholders in mixed tenure blocks? What encourages them to co-operate?

CHG do not offer internal property modernisation works to leaseholders as a matter of course or free of charge. Works can be carried out with the leaseholder’s agreement and would be charged at cost to them. External envelope works, such as windows and door replacements, are carried out and costs recovered through our agreed service charge process.

Domestic Private Rented Sector (PRS) Minimum Energy Efficiency Standards

1. Is your authority aware of the PRS Minimum Efficiency Standards regulations requiring private rentals in England and Wales to meet a minimum energy performance rating of EPC Band E as of April 2020, unless a valid exemption applies?
2. Which team within your authority is responsible for, leading on enforcement of the PRS minimum standard? Please provide the contact details of the person leading this team.
3. What method or methods does your authority use to communicate with landlords and tenants about the standards and other related issues?
4. What barriers, if any, does your local authority face enforcing these regulations (e.g. identifying non-compliant properties/landlords, budgeting/resourcing, any legal issues)?
5. Do you directly target landlords of EPC F and G rated properties to enforce these regulations? If yes, how? If no, please explain.

Is your authority aware of the PRS Minimum Efficiency Standards regulations requiring private rentals in England and Wales to meet a minimum energy performance rating of EPC Band E as of April 2020, unless a valid exemption applies?

Yes we are aware of the Regulations and were part of the BEIS Year 2 PRS Enforcement Pilot Study in which the aim of the pilot was to test out approaches and develop best practice. They were particularly interested in Local Authorities who were already engaged with the PRS Regulations and had started developing monitoring, compliance and enforcement processes which we started back in 2019.

Which team within your authority is responsible for, leading on enforcement of the PRS minimum standard? Please provide the contact details of the person leading this team.
Private Sector Housing team, 1FTO dedicated to undertake EPC enforcement work. PSH team / officer managed by Richard Osborne, Richard.Osborne@nwwm.org.uk

What method or methods does your authority use to communicate with landlords and tenants about the standards and other related issues?

During the initial stages of the project, when we were actively trying to make landlords around the District aware of the new regulations and what was expected, we communicated with landlords by writing out to them directly, or by writing to the tenants if necessary. We also wrote out to all of the local estate agents and made sure they were also aware and advised them to pass the information on to all the landlords they worked with. We also did a press release in the local newspaper, lots of social media content and included it on the front of our webpage. In some instances, we may not be aware of an issue with a property’s EPC and this comes to light from a tenant complaining about their property or from another housing related issue.

What barriers, if any, does your local authority face enforcing these regulations (e.g. identifying non-compliant properties/landlords, budgeting/resourcing, any legal issues)?

Initially when we had the first bulk load of data from the national register, we found it difficult as there seemed to be a lot of duplicates or errors with the data. It was very time consuming but paid off. It is also a struggle at times to identify a landlord or to get hold of details for them. Other issues we were faced with included specific EPC’s such as properties having two EPC’s valid, done by different assessors and one meeting the standards and one not. Other barriers include issues with the recommendations on some of the certificates. We are now working with local assessors if we come across situations like this one. Luckily due to Wyre Forest being able to take part in the BEIS Year 2 PRS Enforcement Pilot Study, this meant an officer could focus primarily on enforcing these regulations but throughout 2020 and with the global pandemic it was difficult at times to enforce the regulations due to lack of contractors and availability / tenants self isolating etc.

Do you directly target landlords of EPC F and G rated properties to enforce these regulations? If yes, how? If no, please explain.

Our approach was initially soft, but we always have ensured we communicate directly with landlords when we can to try and get them to work with us in the first instance and try and avoid more serious enforcement action. We are now more actively enforcing and serving penalty notices so all communication is direct. We have taken the approach of targeting properties that appear to have registered invalid exemptions first, and then targeting landlords that have properties with the biggest difference between their current EPC and what its potential is.

Financial Support for Energy Efficiency

Where possible, please set out your answers to the following questions by tenure (owner occupied, privately rented, or social housing).

1. What financial programmes, if any, do you have to promote domestic energy efficiency or energy saving? If applicable please outline the budget (and % of the budget that is used), where such funding is sourced and where it is targeted.
2. What future investment for energy efficiency or low carbon heat measures do you have planned, and when are these investments planned for?

The Housing Assistance Policy sets out the basis on which Wyre Forest District Council will offer financial assistance for works of adaption, repair or renewal in the private housing sector. This policy is set in response to both local identified needs and issues and national housing strategies. Financial support available through this policy includes Disabled Facilities Grants and Home Repair Assistance. Projects are agreed on an annual basis and typically include measures to improve conditions in the private rented sector where the works are above what can be reasonably expected of a landlord and are of benefit to the tenants, for example improved insulation, efficient heating systems and ventilation. The current Landlord Assistance scheme is offered to private landlords with up to 50% of the costs for energy efficiency improvements funded, where the property already meets a Band E or above on the EPC. To be eligible, the tenant must be in recent of a means tested benefit. In 2019/20 and 2020/21, £153k of funding was provided through these schemes, improving 59 properties.

Green Home Grant Local Authority Delivery schemes promote energy efficiency grants for physical measures accompanied with advice on how to use these effectively. These have been outlined above.

We also ensure that we help residents access ECO through our energy efficiency partners Act on Energy.

Wyre Forest District Council will continue to actively apply for funding from a range of sources to support residents to continue to improve the energy efficiency of their homes. We will also continue to closely with registered providers and in partnership devise mixed tenure schemes. With long term funding through LADS,HUGS and SHDF we hope to achieve long term outcomes for both carbon reduction and reductions in fuel poverty.

Fuel Poverty

1. Does your Local Authority have a Fuel Poverty Strategy?
2. What steps have you taken to identify residents/properties in fuel poverty? What blockers, if any, have there been in identifying households in fuel poverty?
3. How does fuel poverty interlink with your local authority’s overall Carbon Reduction Strategy?
4. Please highlight any fuel poverty issues specific to your area.
5. What measures or initiatives have you taken to promote fuel cost reduction for those in fuel poverty? Include information on partnerships with local businesses or energy providers you have.

Fuel poverty is embedded within a number of key documents including WFDC’s climate change and health action plans and the wider countywide housing partnership plan

The Council is also a partner of the Warmer Worcestershire Fuel Poverty Plan. This is supported through public health and feeds into the aims and objectives of the Health and Well being Board and takes in to consideration the work of the Joint Strategic Needs Assessment JSNA. The plan is a 5 year one that commenced in 2016 and is reviewed on annual basis to ensure that it supports the delivery and works alongside the cold weather plan.

The council is partner of the LEP Energy Strategy which also has fuel poverty as one of its key priorities along with carbon reduction and increased renewable energy generation across the county.

Fuel poverty has in the past used the BEIS statistics to target LSOA with high levels of fuel poverty. Throughout the pandemic this has changed and the number of residents asking for energy support has changed. We believe being able to visit a resident in their home is the best way to fully assess their situation and enable a suite of service to be provided both energy related but wider service provision.

Fuel poverty is part of a wider sustainability strategy so that we can assess and deliver appropriate outcomes in a staged process so that householders in fuel poverty are not impacted by any carbon reduction programmes.

We are a district with a mix of gas and off gas properties. The majority of which is on mains gas so the lack funding support for broken boilers can be challenging. We access funding though the WHD Industry Initiative but this is often oversubscribed and funding allocated by December.

We utilize our energy advice partners Act on Energy who are able to access both energy suppliers ECO and local contractors to deliver our energy efficiency works and support vulnerable residents in our communities. We have as described earlier accessed funding through GHG LADs and will continue to develop this programme for LADs 3 and also work with partners on delivery of the ECO4.

Green Homes Grant Local Authority Delivery

Of the £2bn Green Homes Grant scheme introduced in summer 2020, £500m was assigned for Local Authority Delivery (LAD). LAD enables Local Authorities to bid for grant funding to support low income households in their area with energy efficiency and low carbon heating upgrades. £200m was made available through Local Authority grant competitions in 2020, known as phases 1A and 1B and £300m was allocated under Phase 2 between the five regional Local Energy Hubs.

1. Has your Local Authority Participated in GHG: LAD?
   
   • If yes, please indicate which phase you participated in and briefly outline the project.
   • If no, please indicate what barriers prevented you from participation in the scheme.
2. Would your Local Authority be in a position to manage the delivery of upgrades through a scheme such as LAD in 2022?
   
   • If yes, please indicate the anticipated number of homes that could be upgraded per year.
   • If no, please indicate what barriers would prevent you from delivering upgrades in your area.

Wyre Forest District Council bid for GHG LAD Phase 1a through a consortium of local authorities in Worcestershire and in partnership with Act on Energy. The Council have identified 50 properties through previous stock condition surveys to be targeted for external wall insulation, loft insulation and draught proofing measures. The overall funding includes - £ 224,250 Government Grant for delivery and Administration Costs

Wyre Forest District Council have accepted the allocation of funding for LADs 2 and are in the proposal development stage of the project. The biggest challenge for the delivery is supply chain capacity in both installers and surveyors . We are also aware that the £10,000 average for many measures is not adequate particularly if we are truly looking at a whole house fabric first approach to delivery.

The Energy Company Obligation

The Energy Company Obligation (ECO) is an obligation on energy suppliers aimed at helping households cut their energy bills and reduce carbon emissions by installing energy saving measures. Following the Spring 2018 consultation, the Government set out in its response that ECO3 will fully focus on Affordable Warmth – low income, vulnerable and fuel poor households.

The ECO “Local Authority flexible eligibility” (LA Flex) programme allows LAs to make declarations determining that certain households in fuel poverty or with occupants on low incomes and vulnerable to the effects of cold homes, are referred to ECO obligated suppliers for support under the Affordable Warmth element of ECO.

LAs involved in the LA Flex programme are required to issue a Statement of Intent that they are going to identify households as eligible, and the criteria they are going to use; and a declaration that the LA has been consulted on the installation of measures in a home.

1. Has your local authority published a Statement of Intent (SoI) for ECO flexibility eligibility? (Y/N)
   Please answer the following questions to help us to understand LA Flex delivery in more detail:
2. How many declarations were issued for low income vulnerable households?
3. How many declarations were issued for Fuel Poor households?
4. How many declarations were issued for in-fill?
5. What is the highest income cap published in your SoI?
6. If you have used an income over £30k gross, what reason have you given?
7. Do you charge for declarations to be signed? If so, please state how much?

We deliver ECO Flex through a countywide SOI with the six other district councils and the county council along with our trusted and impartial partner Act on Energy who assess each case individually to ensure the need and eligibility of the resident. Referrals for the scheme come though our promotional work and through trusted partners.

We signed declarations for 267 households in Worcestershire during the last two years.

The cap on income for our SOI is set at £33,129 which is based on a household income below the Worcestershire median of £33,129 (gross) per annum. This cap come with other criteria for example off the main gas network, having a health condition exacerbated by a cold home. View the SOI.

Our partners Act on Energy check for eligibility of the resident and ensure both householder eligibility and compliance. They also endeavour to ensure that the measures are appropriate to the property. We fund them to deliver our wider energy efficiency work and they change a small administration fee of £15 which currently does not cover the cost of the administration of a declaration. Which currently in real terms is between £25 and £50 per households dependant on the complexity of the case and measures required this excludes any home visit cost that may be required.

Smart Metering

1. Please provide a brief statement outlining your current or planned approach to promote smart meter take up and supporting residents to achieve benefits.
2. Please provide further information on activities relating to smart metering, including but not limited to:
   
   1. Integrating approaches to delivering energy efficiency improvements in residential accommodation
   2. Arranging for smart meters to be installed by energy suppliers in vacant social housing premises
   3. Using social landlords to promote smart meter uptake
   4. Including smart meters in landlord licencing schemes
   5. Supporting residents who have had appliances condemned for safety reasons
   6. Other supporting activities

Smart metering advice is part of the suite of advice provided by our partners Act on Energy. They provide switching and tariff advice and embedded as part of this work. They are also a part of the BESN training programme which includes switching and smart meters. They provided training over the last two years in over 300 staff on this subject alone.

Our partners Act on Energy are also looking at the impact on metering and energy in the homes of those with dementia and encourage the installation of Smart Meter as part of the wider advice and support.

Future Schemes or Wider Initiatives

Please outline any further schemes or wider initiatives not covered above that your local authority has carried out or is planning to undertake to improve energy efficiency in residential accommodation.

We participate annually in a collective energy switching scheme and are planning to take part in a collective solar PV installation scheme in 2022.

We work on a number of partner schemes with other councils including the county council. We support a number of their programmes such as the Warm Homes Fund First Time Central Heating Scheme.

We also provided support to a number of business programme run by the county, such as Business Energy Efficiency Programme (BEEP) and we also sit on the board of the county wide Public Sector Energy Efficiency Programme (PEEP).