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Improving Building Standards
Consultation on proposed new building standards

The UNISON Scotland Response
October 2001

Executive Summary . Introduction . Responses . Further Information

Executive Summary

  • UNISON Scotland has taken a keen interest in eliminating fuel poverty, including being part of the Keeping Scotland Warm initiative, and we believe it is appropriate for us to comment on the new building standards in the light of the importance that they can have in achieving this aim.

  • UNISON Scotland believes that tackling fuel poverty is already recognised as a key public issue in Scotland. Therefore the new building standards should be drafted to include tackling fuel poverty as one of these key public interest issues to be addressed.

  • We believe that new energy efficiency measures, as defined in the building standards, should be applied to the whole of an existing building when it is renovated or altered.

  • Adequate resources must be provided to local authorities to implement the new building standards.

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Introduction

This paper constitutes a response from UNISON Scotland to the Scottish Executive's consultation on new building standards for Scotland. UNISON Scotland has taken a keen interest in eliminating fuel poverty and we believe it is appropriate for us to comment on the new building standards in the light of the importance that they can have in achieving this aim.

In 200 30% of Scottish households lived in fuel poverty and 9 in 10 homes fell below current energy efficiency standards. UNISON Scotland believes that these conditions are not acceptable and that a comprehensive multi-agency solution is required to address the problem.

To take this agenda forward, UNISON Scotland, together with Energy Action Scotland, the CSPP and Transco, co-operated on the Keeping Scotland Warm initiative, with a series of seminars which brought experts and interested bodies together, drawing on their combined experience to produce recommendations to eliminate fuel poverty in Scotland. We also circulated a video to MSPS to raise awareness. This response is part of our continuing efforts to bring fuel poverty and energy efficiency issues before the Scottish Parliament and Executive.

UNISON is Scotland's largest trade union with many low-paid members who will benefit from the elimination of fuel poverty. In addition, many of our members in the health, local government and utilities sectors deal with the consequences of fuel poverty on a daily basis. The link between poverty and ill-health is now well recognised. People have a right to get out of fuel poverty and this should be reflected in all areas of social policy. We believe that building standards which reflect the public interest in providing warm, safe energy-efficient housing should be viewed as part of the Scottish Executive's social policy.

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Responses

Recognition of fuel poverty as one of the key public interest issues to be addressed by the new building standards

The consultation document says that the purpose of building standards is to set standards and protect the public interest. Obviously particular interests must be defined in order for the new building standards system to protect them properly.

The consultation document recognises that the definition of public interest might well expand further and recommends that the Executive and Parliament should define the issues of public interest to be covered by the building standards (para 2.6). UNISON Scotland endorses this approach and urges the Executive to include the elimination of fuel poverty as one of these defined public interests.

We firmly believe that the level of public importance attached to the elimination of fuel poverty has already been amply demonstrated. The various consultations on the Warm Deal and the UK Fuel Poverty Strategy are proof of this, as is the widespread public approval of the Warm Deal. In addition, we are aware of the importance that our members, many of whom are low-paid, attach to this issue.

Furthermore, the consultation document itself acknowledges that sustainability and the alleviation of fuel poverty are key issues that could be covered. Para 2.4 says

"it is clearly in the public interest that the stock of energy efficient housing should steadily increase…"

In addition the Working Party explicitly acknowledges (in para 2.30) that the alleviation of fuel poverty is one of the key issues to be considered; it recommends that further research be carried out into this issue to see if it should be included within the new standards.

However, UNISON Scotland believes that there has already been considerable research conducted into the extent of fuel poverty in Scotland and some measures are already in place (i.e. the Warm Deal). Therefore, we see no need for further delay and believe that it would be consistent with the importance that the Executive has already attached to the elimination of fuel poverty if it were to be included in the public interests to be addressed by the new building standards.

New Regulations on energy efficiency should be applied to the whole of a building when it is renovated or improved

In para 2.33 the Working Party Report states that "the application of energy standards to existing buildings when ‘building work' is done is very much an issue of policy currently under discussion."

UNISON Scotland is of the opinion that new energy efficiency measures should be applied to the whole of a building when it is improved or renovated. If this is not the case, much of Scotland's substandard older housing stock will not be improved and brought up to modern standards. Furthermore, requiring such upgrades will:

  • help the Scottish Executive achieve its stated aim of eradicating fuel poverty;
  • make a significant contribution to the UK climate change programme by reducing fuel consumption and therefore meeting one of the aims of the current UK Energy Review - to address the challenges of global warming
  • give Scotland a head start in implementing the new EC Energy in Buildings Directive.

Adequate resources must be provided to local authorities to implement the new building standards

UNISON Scotland, as will be clear from the issues addressed in this paper, welcomes the review of building standards and sees them as a good way of addressing vital social policy issues in a practical manner. We strongly believe that, in addition to formulating the standards properly in the first place, it is equally important to put in place the correct system to implement and police them. This means providing sufficient additional funding for local authorities to enable them to train, support and retain the staff necessary to ensure that the standards do translate into better, more energy efficient buildings.

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For further information please contact:

Matt Smith, Scottish Secretary
UNISON Scotland
UNISON House
14, West Campbell Street,
Glasgow G2 6RX
Tel 0141-332 0006 Fax 0141 342 2835
e-mail matt.smith@unison.co.uk

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