CRS58 Number of households/people falling below the SHQS & Tolerable Standard

Good Places Better Health (GPBH) was launched in 2008 as the Scottish Government’s strategy on health and the environment (Scottish Government, 2008).  Between 2008 and 2011 a prototype phase of GPBH provided recommendations covering four key health challenges facing children in Scotland: asthma, mental health and well-being, unintentional injury and obesity (Scottish Government, 2011a).  The Scottish Climate Change Adaptation Programme (SCCAP) uses (some of) the recommendations from that work to evaluate societal preparedness and climate change resilience: 

• Review energy efficient criteria of the Tolerable Standard and the Scottish Housing Quality Standard to enable energy efficiency improvements
• Streamline and simplify the grants system for energy efficiency improvements
• Improve Registered Social Landlord action on fuel poverty
• Improve the uptake of home insulation grants
• Use point of sale/exchange of lease/construction of extensions to require communication and/or upgrading of building’s energy efficiency
• Ensure home reports include details of how to access any grant funding for energy efficiency improvements

The Tolerable Standard is a minimum standard for habitability introduced in the 1969 Housing (Scotland) Act, whose parameters have been updated in the 1987, 2001 and 2006 Acts.  It is now included in the broader Scottish Housing Quality Standard (SHQS) and provides the low watermark for compliance

The SHQS itself was announced by Margaret Curran MSP, Minister for Communities, in February 2004. A target was agreed that social landlords must ensure that all their dwellings pass the SHQS by 2015, a target that will not now be met. Private owners and private landlords are currently under no obligation to bring their properties up to this standard.

The SHQS is composed of 5 Broad Categories covering 55 different elements of compliance as discussed in the Methodology section.  Assessments consider both the Tolerable Standard (Criterion A of the SHQS) as the minimum standard for habitability as well as Criteria B through E which cover the state of repair of the building fabric (Criterion B), energy efficiency (C), adequacy of facilities and services (D) and health, safety and security considerations (E).  Overall, the assessment provides an aggregate indicator of the climate resilience of the housing stock - insulation, heating, energy efficiency ratings - as well as a more general measure of societal resilience to climate change impacts. It allows policy makers to target relatively easily identified actions (such as improving the depth of loft insulation), although this does not necessarily mean of course that the actions themselves are easily implemented.

This indicator looks first at compliance with the lighting, ventilation, heating elements and thermal insulation elements of SHQS Criterion A: Must be compliant with the current Tolerable Standardbefore reviewing compliance specifically with demand management (energy efficiency), primarily through Criterion C: Must be Energy Efficient.

Other elements of the SHQS are considered in related indicators: rising and penetrating damp (Tolerable Standard element 2 is tracked through BB17); condition of the building fabric and disrepair (SQHS Annex B is tracked through BB16); condensation in housing stock (Tolerable Standard element 3 and SQHS element 42, tracked through BB18).

Related Indicators

CRS61: Number of households in fuel poverty

CRS64: Uptake of energy efficiency measures

BB16:  Building condition and disrepair

BB17/BB18: Dampness condesation in housing stock

BB20: Energy performance of Scottish housing stock

According to the data reported in the Scottish House Condition Survey 2014 (SHCS, 2014), 49% (nearly 1.2M) of dwellings across the entire housing stock failed the SHQS in 2013.  The rate of failure in the social sector 43% (264,000 properties) is significantly lower than in the private sector 51% (891,000 properties).[1]

71,000 properties (3%) are non-compliant with Criterion A of the SHQS (Tolerable Standard) – Below Tolerable Standard (BTS) – the minimum standard of habitability.   The majority (52,000 properties) are in the private sector, of which the majority (35,000) are predominantly older (pre-1919), owner-occupied dwellings; 34% of BTS failures are as a result of poor insulation (24,000 dwellings) while 11,000 (16%) were classified as having unsatisfactory provision of heating, lighting and ventilation; while the rest (19,000 or 27% of BTS failures) subject to rising/penetrating damp (see Indicator BB17:Dampness in housing stock).

For the SHQS overall, 39% of the private sector housing stock (681,353 dwellings) is non-compliant with respect to the energy efficiency elements of Criterion C in contrast to 28% of the social sector (172,000 dwellings) over half of which are likely attributable to failures to insulate the building fabric, primarily by insulating wall cavities.  However, as cavity wall treatment is often difficult to accurately assess, assumptions in the surveying method mean that this is likely to be an upper (over) estimate.

Extrapolating from estimates of household size (National Record of Scotland, 2013), around 2 million people are living in private and social sector housing in Scotland that fails to meet the energy efficiency criteria specified in the SHQS (Figure 1)

Over the decade since the SHQS was first established, the total number of dwellings failing the standard has fallen by twenty three percentage points, the social sector setting the pace in that fall with a third fewer dwellings failing the standard in 2013 than 2004.  In the same period the number of dwellings in the private sector failing the SQHS has fallen by around a quarter (24%) accounting for 338,000 properties (Figure 2). 

The distribution (of SHQS failures) between rural and urban housing has also fallen by a fifth (rural) and 27% (urban), a fall of nearly half a million dwellings (447,000) with a significant fall of percentage points between 2012 and 2013 to less than a million dwellings for the first time.  The difference between the proportion of rural and urban dwellings failing the SHQS has remained broadly the same.

The majority of SHQS compliance failures are due to dwellings not meeting the energy efficiency measures of Criterion C.  Nearly two-thirds (62%) of dwellings failed one or more of the elements in this Criterion in 2003 (Figure 3).  While this had fallen by just under a third in 2013 to 36%, failure to achieve the required standard for energy efficiency remains the primary reason for SHQS failure overall[1].

The fall in energy efficiency non-compliance was driven by improvements in the social sector with an 11-percentage point reduction between 2012 and 2013, reversing a temporary upward trend in 2011. More generally, the lowest failure rates were in the newest dwellings (post 1982 - 16% failure rate) and Housing Association stock (33%), which is generally more recent than other Local Authority stock and therefore designed from the outset to ensure SHQS compliance.

Both Housing Association and Local Authority dwellings have reduced their failure rates by around 10 percentage points between 2012 and 2013.  Overall, the number of dwellings across all sectors failing the standard has dropped by 5 percentage points in the 12 months to December 2013.  Distributional differences between Local Authorities are apparent (Figure 4).  The Western and Northern Isles are significantly exposed with over 60% of dwellings failing to comply with Criterion C, with 57% of Highland stock also failing.  By contrast, in the urban centres of Edinburgh, Glasgow and Stirling only around one-third of Local Authority dwellings fail to meet the Criteria overall.

However, over that same period the number of dwellings in both the social and private sector failing the minimum standard for habitability- the Tolerable Standard – has remained flat at over 70,000 properties (3% of the total housing stock).  Some distributional differences are indicated in local authority data with 7% of dwellings in the Orkney Islands and 6% of dwellings in Aberdeenshire, Moray and East Dunbartonshire failing the Tolerable Standard, much higher than the average.

On-going EU and Scottish legislation (European Council, 1992, 2008; Scottish Government 2013b, 2013c) will continue to drive Government energy efficiency programmes (Scottish Government 2014a, UK Government, 2015) providing incentives and guidance on improving thermal insulation, in loft spaces (SHQS elements 12 and 32) and building fabric (SHQS element 31), and the efficiency of boilers (SHQS elements 33 and 34A/B).  In large part as a result of these schemes, dwellings are becoming more energy efficient with 91% of dwellings in Scotland in 2013 having at least 100mm of loft insulation, for example, and 69% of cavity walled dwellings having cavity insulation (more detail is provided in the indicator CRS61: Number of households in fuel poverty).  These initiatives have been instrumental in improving the energy efficiency ratings of the housing stock as measured by the Energy Efficiency and Environmental Impact Ratings in Energy Performance Certificates (EPCs).  The criterion set by SHQS element 35 for energy efficiency ratings in particular – Standard Assessment Procedure (SAP 2001 standard) of 50 (gas systems) and 6 (oil, LPG, biomass, electricity systems) – seems to be eminently achievable given the fact that in 2013 over 80% of dwellings in Scotland are at EPC Band D (SAP 55-68) or higher.

It is therefore anticipated that compliance with Criterion C and those elements of Criterion A (Tolerable Standard) associated with energy efficiency (elements 3 and 12) will continue to improve from the 36% failure rate seen in 2013.

It is worth noting that more work is also required to address failings with respect to Criterion E: Healthy, Safe & Secure elements that accounted for 14% of SHQS failures and Criterion D: Modern Facilities & Services, 11% of SHQS failures in 2013.  More positively, no dwellings failed to achieve compliance with Criterion B (Serious Disrepair) although 19,000 dwellings failed Criterion A (Tolerable Standard) as a result of rising and/or penetrating damp (SHCS, 2014) - see also indicators BB17: Dampness in housing stock; BB18: Condensation in housing stock.

As noted above, patterns of change in the resilience of the Scottish housing stock will involve improvements in both thermal efficiency and energy efficiency driven in large part by a coherent programme of EU, UK and Scottish Government legislation and policy-making.

The Routemap to 2030 laid out in Scotland’s Sustainable Housing Standard [SSHS] identifies a range of initiatives that will have an undoubted impact on energy efficiency.  The Home Energy Efficiency Programme for Scotland [HEEPS] for both private and social sectors will help to address some of the building fabric issues identified above (Scottish Government, 2013b).

The SSHS also signposts the Energy Efficiency Standard for Social Housing [EESSH] (Scottish Government, 2014b) and the Regulation of Energy Efficiency Standards in the Private Sector [REEPS] with a consultation due in 2015[1].  Energy efficiency schemes and their uptake are explored further in indicator CRS64: Uptake of Energy Efficiency Measures.

2020 is a critical year for an assessment of progress on a number of interim targets:

• First milestone for social landlords to comply with EESSH.
• Energy Efficiency Action Plan  (Scottish Government, 2010)
• Energy consumption reduction of 12%; a reduction of (-)11.8% had been achieved in 2012.
  • 2020 Routemap for Renewable Energy (Scottish Government, 2011b)
  • 100% electricity demand from renewables; 44.4% had been achieved in 2013.
  • 10% renewable transport through biofuels; 3.5% had been achieved in 2013.
  • 11% renewable heat; 3% had been achieved in 2013.
    • Towards Decarbonising Heat (Scottish Government, 2014c)
    • 1.5TWh of heat to be delivered by district heating, 2% of the total forecast non-electrical heat demand in Scotland; less than 1% 2014.

Some of these initiatives will have an incremental effect over time (but a corresponding delay in their impact).  For example, as older boilers are replaced by condensing boilers[2] that are compliant with the Scottish Building Standards, demand side efficiency will improve overall in line with the minimum 86% efficient requirement of Scottish Government (2013c).  A revision of the current building regulations is expected in October 2015.

Similarly, EPCs were designed to have an impact on house prices, persuading owners to take remedial action to improve energy efficiency and environmental impact ratings before putting their homes on the market (Scottish Government, 2013b). 

The promotion of energy efficiency is embedded at national scale.  National Planning Framework 3 (Scottish Government, 2014d) recognises the Electricity and Heat Generation Policy Statements (Scottish Government 2013c, 2014c) as core components of the Infrastructure Investment Plan (IIP) underpinning the Government Economic Strategy (Scottish Government, 2015) and as distinct ‘Subject Policies’ within Scottish Planning Policy (SPP) (Scottish Government, 2014d).

Additional criteria for electrical installations and thermal insulation were added to the criteria tracked by the Tolerable Standard through the 2006 Housing Act. These requirements came into force in April 2009 and were first reported by the SHCS in 2010. The change in definition caused the fail rate for the standard to increase from 0.7% in 2009 to 3.9% in 2010 in the full time series tables.

The majority of dwellings that fail the SHQS fail on the energy efficiency criterion.  Full efficient central heating[1] is a strict requirement of this criterion. Dwellings with ‘inefficient’ central heating, even if it is full, will fail. Also crucial is the presence of thermal insulation measures - such as loft, hot water tank and cavity wall insulation (where applicable) - in the dwelling.

7% more rural than urban dwellings are failing the SHQS.  The overall fall in the proportion of dwellings failing the SHQS obscures the fact that the distributional (rural-urban) impacts continues to increase, up one percentage point since 2012 back to the same level as in 2003/04.

In particular, mechanisms to improve thermal storage as well as obstacles to implementation require more research to provide the basis for future policy development.

The extrapolation of households to people uses an average household size for each of the 32 Scottish Local Authorities (National Record of Scotland, 2013).  The resulting estimate of the number of people affected is therefore approximate and should be taken as an indicative of the order of magnitude rather than a definitive number.

European Council (1992) EC Directive 92/42/EEC: Efficiency Requirements for new hot water boilers fired with liquid or gaseous fuels, available at: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31992L0042&from=en

European Council (2008) EC Directive 92/42/EEC Boiler Efficiency Directive, available at:

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31992L0042&from=en and context http://europa.eu/legislation_summaries/energy/energy_efficiency/l21019_en.htm.  The most recent amendment was 2008 with a consolidated version at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1992L0042:20080321:EN:PDF

National Record of Scotland (2013) Estimates of Households and Dwellings in Scotland 2013, available at http://www.nrscotland.gov.uk/files//statistics/household-estimates/he-13/2013-estimates-house-dwellings-scot.pdf

Scottish Government (2008) Good Places, Better Health. A New Approach to Environment and Health in Scotland.  Implementation Plan.  Edinburgh.  Available at: http://www.gov.scot/Resource/Doc/254447/0075343.pdf

Scottish Government (2009) Renewable Heat Action Plan for Scotland: a plan for the promotion of heat from renewable sources, available at: http://www.gov.scot/Resource/Doc/290657/0089337.pdf

Scottish Government (2010) Conserve and Save: Energy Efficiency Action Plan for Scotland, available at: www.gov.scot/Resource/Doc/326979/0105437.pdf

Scottish Government (2011a) Good Places, Better Health for Scotland’s Children. Edinburgh.  Available at: http://www.gov.scot/Resource/0039/00398236.pdf

Scottish Government (2011b) 2020 Routemap for Renewable Energy in Scotland, available at: www.gov.scot/resource/doc/917/0118802.pdf

Scottish Government (2013a) Methodology Notes: SHCS Key Findings 2013, available at www.gov.scot/Resource/0046/00465693.pdf (accessed February 17th 2015).

Scottish Government (2013b) Scotland’s Sustainable Housing Strategy, available at: www.gov.scot/Resource/0042/00425697.pdf

Scottish Government (2013c) Building Standards Technical Handbook – Domestic.  Energy available at: www.gov.scot/Resource/0045/00459729.pdf  (accessed February 23^rd 2015).  All handbooks related to Building Regulations are available at: www.gov.scot/Topics/Built-Environment/Building/Building-standards/publications/pubtech

Scottish Government (2014a) Home Energy Efficiency Programme – Area Based Schemes, available at http://www.gov.scot/Topics/Built-Environment/Housing/warmhomes/uhis/heepsguidance

Scottish Government (2014b) The Energy Efficiency Standard for Social Housing [EESSH]: background and guidance for social landlords, available at /www.gov.scot/Resource/0044/00447123.pdf

Scottish Government (2014c) Towards Decarbonising Heat: Maximising the Opportunities for Scotland.  Draft Heat Generation Policy Statement (for Consultation), available at: www.gov.scot/Resource/0044/00445639.pdf

Scottish Government (2014d) Ambition, Opportunity, Place:  Scotland’s Third National Planning Framework, available at: www.gov.scot/Resource/0045/00453683.pdf

Scottish Government (2015) Scotland’s Economic Strategy, available at www.gov.scot/Resource/0047/00472389.pdf (accessed March 4^th 2015).

SHCS (2014) Mueller, G., Robertson, J., Leadbetter, C., Laing, N., McMeneny, M and Kyriakou, A. (2014) Scottish Housing Conditions Survey 2013, Key Findings.  Directorate for Housing, Regeneration and Welfare, Scottish Government.  Available at: www.gov.scot/Resource/0046/00465627.pdf (accessed February 17th 2015).

UK Government (2015) Household Energy, available at: https://www.gov.uk/government/policies/helping-households-to-cut-their-energy-bills

Housing Act (1969) http://www.legislation.gov.uk/ukpga/1969/33/pdfs/ukpga_19690033_en.pdf

Housing (Scotland) Act (1987) http://www.legislation.gov.uk/ukpga/1987/26/pdfs/ukpga_19870026_en.pdf

Housing (Scotland) Act (2001) http://www.legislation.gov.uk/asp/2001/10/pdfs/asp_20010010_en.pdf

Housing (Scotland) Act (2006) http://www.legislation.gov.uk/asp/2006/1/pdfs/asp_20060001_en.pdf

Local Government Benchmarking Framework, available at: http://www.improvementservice.org.uk/benchmarking/

Lead author: Mike Bonaventura (Crichton Carbon Centre)