Improving Building Standards
Consultation on proposed new building standards
The UNISON Scotland Response
October 2001
Executive Summary .
Introduction . Responses . Further
Information
Executive Summary
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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.
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.
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:
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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
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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.
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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