New Government Proposals impose 1532 houses a year on Teignbridge

The government is conducting a consultation entitled “Changes to The Current Planning System”, which include proposed changes to the formula for calculation of housing numbers.

When applied to 2020 this formula requires 1532 houses a year, whereas the previous formula required 760 houses.

Summary of our concerns

  • The absence of parallel policies to limit the significant increase in GHG emissions goes against the UK’s Paris commitments on Climate Change
  • Extrapolating historic growth to predict future demand is unsustainable, unrealistic and unnecessary
  • Undue weight is given to workplace affordability now and 10 years ago
  • The Workplace Affordability Criteria proposed is likely to build houses in the wrong places and increase commuter miles
  • Workplace affordability does not take into account the major projected growth which is in pensioner households.
  • The assumption that house prices are simply determined by supply/demand is misguided
  • Imposing significant government targets to the housing market without safeguards or limits is likely to exacerbate boom/bust cycles
  • A rushed consultation for a policy change with significant impact on some local communities

What is the formula

The formula is calculated from:

An annual baseline is set by dividing the growth in household numbers over 10 years by 10.

This baseline is multiplied by an adjustment derived from workplace affordability and the difference between workplace affordability now and 10 years earlier.

The formula is designed to add at least 300,000 new houses per year in England.

Full details of the formula and a worked example are given in our detailed paper.

Growth in household numbers

This image has an empty alt attribute; its file name is image.png

ONS project a 7,920 growth in Teignbridge household numbers between 2020 and 2030. The chart on the right shows that the majority of these will be pensioners. Of those who are of working age it is likely that a significant proportion will be commuters.

Growth of 7920 over 10 years gives an annual baseline of 792 houses.

Workplace affordability

Workplace affordability is median house prices divided by median workplace earnings. So is a measure of the relationship of house prices in Teignbridge to pay in Teignbridge. The following chart shows the workplace affordability now and 10 years ago over the last few years:

Both now and 10 years ago affordability has been falling, which means that houses are becoming more affordable. 10 years ago we were recovering from a financial crisis and in 2010 after the general election the housing market stalled, causing a low in house prices and so affordability.

The government’s stated purpose in to have a formula which is reactive to deterioration in affordability in areas that are growing, such as areas of the Northern Powerhouse. Comparison with 10 years ago in this case fails because slight changes now are dwarfed by big changes 10 years ago.

The adjustments calculated using affordability over the last few years are shown below:

The adjustment varies considerably from year to year and does not have to have a relationship to recent changes in availability.

As many worker commute out of the district and the majority of household growth is in the older non-working population, we don’t think that workplace affordability is an appropriate measure.

Age based affordability

We have calculated affordability for pensioners aged under 75, and those aged 75 and over, based on median gross incomes for England. Currently pensioner incomes in the South West are higher that nationally:

This suggests that affordability for older pensioners is about the same as for the working population, but affordability is substantially lower for younger pensioners. This only considers earnings, it does not consider the larger capital resources that pensioners can have in housing, pensions and other investments.

Residential Affordability

Residential earnings are the earnings of residents of a district.

Residential affordability is median house price divided by median residential earnings.

ONS also publish median residential earnings for each financial year, so we can compare median residential and workplace earnings.

Residential earnings for Teignbridge are consistently higher that workplace earnings.

Comparison with Exeter

We have also considered the relationship of residential and workplace earnings in Exeter, and see an opposite relationship:

Here residential earnings are lower than workplace earnings, though recently the two have converged.

The effect of using residential earnings, rather than workplace earnings would be to make affordability lower in Teignbridge, and in earlier years higher in Exeter. This would result in more houses in Exeter and fewer in Teignbridge.

This would mean that more people who worked in Exeter lived in Exeter, so there would be less commuting, which would be likely to be by car.

What has this to do with climate change?

When a traditionally built house is constructed there are about 60tonnes of Carbon Dioxide equivalent (t CO2e) of Green House Gas (GHG) emissions. Building 1532 additional houses would cause embedded emissions of 93kT CO2e which is about half Teignbridge’s domestic emissions of 182kT CO2e (for 2018). On this basis the previous formula’s 760 houses would have emitted 46kT CO2e.

We have also demonstrated that using residential earnings would lead to more homes being built in areas with high earnings, which would lead to less commuting.

In 2018 road transport emissions for Teignbridge were 402 ktCO2e of which 329.8 ktCO2e were on A roads and motorways. These roads account for 45% of all emissions produced in Teignbridge.

The following map shows these emissions allocated according to traffic flows in the road network in Teignbridge.

An interactive version of this map can be found here.

Are 300,000 houses per year needed

ONS project that between 2020 and 2030 1.6 million households will be formed in England, nowhere near 3 million.

The consultation says: “The Government has based the proposed new approach on a number of principles for reform. These include ensuring that the new standard method delivers a number nationally that is consistent with the commitment to plan for the delivery of 300,000 new homes a year, a focus on achieving a more appropriate distribution of homes, and on targeting more homes into areas where they are least affordable.” 

So the new standard method for calculating housing numbers takes into account existing housing stock, as well as projected household growth. It also puts more emphasis on affordability by taking into account changes over time, and it inflates the final number by removing the 40% cap that currently applies.

Building 300,000 houses a year, rather than 160,000 means that 140,000 extra houses will be built. Using 60t per house, embedded emissions from these additional houses will be 8.4Mt , UK GHG emissions in 2019 were 351.5Mt, so this is unnecessary housebuilding could add 2.4% to UK emissions each year.

It would be better to reduce new housing numbers, and divert building trades resources to retro-fitting existing buildings so that these are as energy efficient as possible.

Research by the UK Collaborative Centre for Housing Evidence provides an alternative, and in our view more plausible explanation of the causes. Housing evidence has calculated that there were 1.12million surplus houses by March 2018, and that taking this into account net additions to housing stock exceed household formations.

In Teignbridge, since compatible records began in 2001, 497 houses have been completed than households formed. In addition there have been changes of use, conversions and retrofits that have effectively increased the housing stock, that are not counted in new build housing numbers.

In Teignbridge it is doubtful that building more houses will have much effect on affordability, because the majority of new housing that is built is out of reach for people on Teignbridge median earnings, and will mainly be bought by people whose income comes from outside the district. If house prices were to drop such that development was unprofitable, developers would just stop building and wait for the situation to correct.

We agree that tackling some of the other causes would be more effective:

  • Privatisation of council housing
  • Relaxation of restrictions on buy to let mortgages
  • Low median incomes
  • The lack of income progression recently in early careers.
  • Difficulty of accessing mortgage finance.
  • Competition with buy-to-let landlords.
  • Speculative purchase of housing as an investment asset, particularly by foreign buyers.

Unfortunately the government is intent on building 300,000 houses a year, so the consultation doesn’t offer much opportunity to comment on that.

Timetable for Teignbridge Local Plan

The consultation gives a tight timetable for submission of part 2 plans in order to be exempt from these requirements.

The current timetable for the Teignbridge local plan can be found here https://www.teignbridge.gov.uk/planning/local-plans-and-policy/local-development-scheme/

This starts development of part 2 of the plan in January 2021, and consults on sites in the period leading to September 2021. This plan is then submitted for inspection in April 2023. If the new formula is adopted by the end of 2020, then in order to be exempt from the new requirements, the council will have until September 2021 to submit a plan to the inspector. This sounds like an extremely challenging contraction of the planning process.

It is therefore likely that TDC will be obliged to comply with this formula, and so will need to identify additional sites, which will extend the plan timetable further.

Detailed Analysis

Our in depth analysis can be found here

Responding to the consultation

You can respond online to the consultation here.

The deadline for responses is 11:45pm on 1st October 2020.

Our response to the housing numbers part of the consultation is available here , and has been submitted online.

Are you interested in retrofit?

In 2019 nearly 70% of Teignbridge’s existing housing stock had an EPC rating D and below.  Despite the significant increase in new build, this % has changed little in the past 10 years and, in the last 2 years, has actually increased.

Green-House Gas (GHG) emissions from heating our buildings are significant with Teignbridge’s domestic emissions in 2018 accounted for approximately 25% of all its emissions, most of this from heating.

In order to to reach the UK’s Paris targets we can reduce emissions by retrofitting properties to:

  • decarbonise heating energy, by using low-carbon fuel sources (eg Biomass & Hydrogen) or switch to electric heating (eg. Heat Pumps) and using low-carbon electricity generation.
  • reduce the heating energy demanded by eliminating waste and minimising heat loss (ie with better insulation).

Homeowners invest significantly in home-improvements, especially in the able-to-pay sector, however this sector tends to have the highest GHG emissions, primarily because energy pricing is still low relative to incomes in that sector.

Whilst Climate Change is accepted as a serious threat by the majority of the population, including the able-to-pay-sector, it is still the case that, in general, they do not act to address their contribution to Climate Change.

Those who do act are faced with a plethora of solutions, deals and government incentives.  More often than not, many are either disappointed that their emissions and running costs have not reduced significantly or they do not measure the GHG emission reduction to find out.  One of the most common concerns is ‘can I trust the salesperson?’ followed by ‘will the builder do a good job?’.

To address this, ACT is considering an initiative, initially targeted at the able-to-pay, to identify local commercial organisations with the expertise and quality of work, backed by relevant industry standards, to deliver bespoke whole house retrofit solutions.

By identifying suitable customers, designers, architects, builders and material suppliers we hope to demonstrate that a sufficient market can be stimulated to become self-sustaining.  This will of course represent a small percentage of the retrofit needed, but it could be a model to deliver more ambitious initiatives such as in the Carbon Coop model. 

Teignbridge District Council does not currently have plans, or resources, to formally address this and Housing Associations will develop their own specific supply-chain solutions.

Teignbridge has a large number of older, poorly insulated, rural properties.  Increasingly these properties are owned by those wanting to undertake significant improvements and having the budgets to do so.  Normally a piecemeal approach, based on little (if any) measurements or holistic assessment, results in costly retrofits and inappropriate heating solutions.

As an impartial community-based organisation ACT is ideally placed to bring the different parties together under a replicable scheme of effective retrofits, helping to develop a template scheme for both homeowners and service providers.

The initial model proposed is that adopted by the Carbon Coop, based around an assessment/design phase and using suitably experienced local builders/crafts people.

To get the scheme started, ACT would need someone to either volunteer or be paid (grant funding may be available) to identify suitable providers and customers and liaise with similar groups to discover their approach and put a proposal together on how it could work in Teignbridge.

Ideally, we should also find a customer with a retrofit project willing to work with ACT’s Built Environment & Energy group to pilot some of the approaches already well understood.  Trialling each of the elements of the scheme to identify an appropriate supply chain should help identify problems that may occur.  Several such projects are likely to be needed before a Teignbridge-specific model is developed.

Are you interested? If so, drop us an email with your details.

Extracted from a paper written by Fuad Al-Tawil

Why carbon intensity apps are greenwash

There is an app for almost everything. One that recently drew my attention is a carbon intensity app, which at first sight looks really helpful in alerting you to when you can put washing on or charge up batteries while the electricity grid in your area has low carbon emissions.

Renewable energy is not yet stored in sufficient quantity so needs to be used when it’s available. Carbon intensity apps tell you when output from renewable sources of electricity is high and the carbon intensity of the grid is therefore low. 

What’s not to like? Well, the devil is in the detail, as the saying goes. The claims made for these apps are little more than ‘greenwash’, says ACT energy expert Fuad Al-Tawil. Teign Energy Communities (TECs) has produced a detailed explanation of why this is so.

Essentially, the only sure way to lower grid carbon emissions is to increase the renewable energy that feeds into the grid. Point in time readings from a carbon intensity app are not a reliable indicator of surplus low-carbon electricity being available. If demand for electricity from users of the apps increases when intensity is low and there is no renewable surplus, it will just lead to gas being switched on. A gas-fired power station is currently the easiest type of electricity generator to turn on and off at short notice.

There are additional complicating factors due to the way the national grid operates. The financial settlement system for generating, transporting, distributing and consuming electricity is based on price. There is no accounting for carbon emissions. This can lead to renewable generation being turned off and a gas fired power station being turned on to maintain the balance of the grid, so generation and consumption are matched. 

By all means download a carbon intensity app, but don’t assume you will be increasing the use of renewable energy and thereby reducing the carbon intensity of the electricity you buy. 

The only way to help reduce the carbon intensity of the national electricity supply is to encourage the market to build more renewable generation.  You can do this by buying a 100% green tariff from a provider.  Ideally use one of the few providers that buys directly from renewable generators or generates its own supply. TECs names Good Energy and Ecotricity as two such companies. The more people who use such providers, the greater the demand for renewable energy as part of the energy mix of the grid. 

The 100% ‘green’ tariffs offered by other energy companies will not help so much in this regard as they are achieved by a form of offsetting using tradable certificates called REGOs (Renewable Energy Guarantee of Origin). Despite the name, they will not be adding new renewable generation to the grid, simply offsetting against existing renewable generation.  This will not reduce the carbon intensity of the grid. The TECs paper explains this in more detail.

Of course, the most reliable way to reduce emissions from electricity generation is to lower your usage. Use the carbon calculator to work out your carbon footprint then consider what changes you can make to reduce it. Generating your own renewable energy also helps, as does buying from Good Energy or Ecotricity. Sadly, timing your energy consumption to coincide with low carbon intensity periods via an app will not help and could even increase carbon emissions.

Local Plan consultation extended

Teignbridge District Council has extended the consultation period on its Local Plan, moving the closing date from 15th June to 13th July. The change has been made to give people more time to comment, given that face to face meetings are not currently possible.

ACT encourages everyone to submit a response. Feel free to use ACT’s draft response as a reference/template. Please continue to send ACT any comments or suggestions on the draft response as we will not submit it until early July.

The Local Plan and its associated documents can be viewed at: www.teignbridge.gov.uk/localplanreview.

The FAQ section of the documents explains that a Local Plan guides decisions on where and how development takes place. It contains a set of rules, called ‘policies’, which are used to guide decisions on applications for development. The Teignbridge Local Plan is in two parts, with Part 1 guiding decisions on HOW development takes place in Teignbridge, and Part 2 on WHERE developments take place. The consultation is on Part 1.

If you would like to comment on the Local Plan you can your comments by:

ACT responds to Teignbridge Local Plan consultation

The ACT coordinating group is preparing a response to the TDC Local Plan consultation.  We have prepared an initial draft response here.

Your input/comments are very much welcomed, please send these to fuad@actionclimateteignbridge.org

It is important that everyone responds to this consultation by the 15th June as the new Local Plan will shape development in Teignbridge for the next 20 years.  It is a key opportunity to demonstrate community support so the council is strengthened in its resolve to put Climate Change at the centre of everything it does. 

We will share a final version before the consultation closes, you can use this or the current draft to help you prepare your own response.

Teignbridge District Council Local Plan Review

On 23rd March Teignbridge District Council announced the Local Plan 2020-2040 Review. The review survey runs until 15th June 2020, and ACT will be publishing a response towards the end of April.

Details of the local plan review can be found at https://www.teignbridge.gov.uk/planning/local-plans-and-policy/local-plan-review-2020-2040/

What you can learn from Energy Performance Certificates

All domestic and commercial buildings in the UK available to rent or buy must have an Energy Performance Certificate. The Certificate provides details on the energy efficiency of a building, gives it a rating from A (very efficient) to G (inefficient), and tells you what you can do to improve that rating. It is valid for 10 years.
ACT has analysed certificates since 2008

An EPC lets the person who will use the building know how costly it will be to heat and light, and what its carbon dioxide emissions are likely to be.

In the Teignbridge area EPCs have been issued for more than 37,000 of around 54,000 dwellings. Nearly two-thirds of these (62% or 23,137) are rated D or worse, with just 58 rated A. Only 27 dwellings have zero or negative carbon emissions, but of those, 10 are new estate houses built by Redrow in Kingsteignton. This shows it can be done so why aren’t all new build estate houses zero carbon? Most have a B or C rating.

Total emissions from dwellings rated D or below currently amount to 127kt of CO2, against 31kt for the higher rated ones.

The top recommendations in Teignbridge EPCs for improving energy efficiency are to install: solar panels (29,642 certificates), solar hot water heating (26,591), low energy light bulbs (24,075), a new condensing boiler (11,994). There are also various insulation recommendations.

If all the suggested improvements were carried out, only 5,949 dwellings  (16%) would be rated D or worse and emissions per dwelling would drop by nearly half, from 4.23 tonnes to 2.37 tonnes. But those low rated dwellings would still account for around a third of CO2 emissions.

EPC data is a useful starting point for Parish and Town councils that have declared a climate emergency. It will help to set carbon targets and implement initiatives designed to reduce emissions.  For more details, and maps showing current and potential CO2 emissions by parish, please visit https://actionclimateteignbridge.org/index.php/energy-performance-certificates-epcs/

Energy Performance Certificates (EPCs)

An Energy Performance Certificate is required for properties when constructed, sold or let. The Energy Performance Certificate provides details on the energy performance of the property and what you can do to improve it. This estimates primary energy consumption and associated emissions for only certain elements of a property, so does not represent all emissions. Notably it does not include emissions from domestic sources such as cooking, white goods and entertainment. Primary energy sources can be: electricity from the grid, mains gas or LPG; heating oil; coal; and biomass.  On-site renewable generation estimates are used to offset these.

When an EPC is issued it lasts for 10 years. EPCs are issued by Domestic Energy Assessors.

An EPC includes:

  • A rating A to G for current and potential energy efficiency
  • Estimates of:
    • Current and potential CO2 emissions
    • Energy consumption
    • Environment impact
  • Cost estimates for:
    • Space heating
    • Hot water heating
    • Lighting

What do EPCs say about housing in Teignbridge?

EPCs have included values for CO2 emissions since October 2008. EPCs for an area can be downloaded from https://epc.opendatacommunities.org/domestic/search. 1 This shows that in Teignbridge EPCs have been issued for over 37,000 of approximately 54000 dwellings. Currently average annual emissions per dwelling are 4.23 tonnes of CO2 equivalent.

The distribution of energy ratings current and potential is shown in the following chart:

Currently 23,137 dwellings (62.1%) are rated D or worse. These dwellings emit 127 kt of CO2, whereas the better rated dwellings emit just 31 kt of CO2.

Just 58 dwellings in Teignbridge currently have an energy rating of A, and only 27 of these dwellings have zero or negative carbon emissions. Most of the 27 are one off custom builds, but 10 are new estate houses built by Redrow in Kingsteignton. Most new build houses have a B or C rating, but this shows that zero carbon is possible for new build estate houses, so why aren’t they all zero carbon?

How might we improve

For many dwellings EPCs contain recommendations for improvements and estimates of potential CO2 emissions and energy consumption. If all the suggested improvements were carried out then:

  • Emissions per dwelling would drop from 4.23 tonnes to 2.37 tonnes, a reduction of nearly 44%.
  • Only 5,949 dwellings (15.97%) would be rated D or worse, against 23,137 (62.1%) currently. Despite the great reduction in numbers, those households rated D or worse would still account for 36.5% of CO2 emissions.
  • Dwellings that are rated A,B or C would emit 1.79 tonnes each or 56 kt in total, whereas those rated D and below would emit 5.42 tonnes each or 32 kt in total.

Many of the measures recommended in EPCs are quite expensive, so it is reasonable to assume that many have not been implemented.

If more radical measures were applied to the difficult cases to ensure these were at least as good as those rated C and above, then total domestic emissions could reduce to 67 kt, an overall improvement of about 68%.

In addition to improving the existing stock, we need new buildings to be zero carbon or negative as soon as possible. Ideally negative, to mitigate emissions from existing dwellings that are difficult to treat.

What are the EPC recommendations

The top EPC assessor recommendations are:

  • Install Solar PV 2.5 kWp (29,642)
  • Install Solar hot water heating (26,591)
  • Install Low energy light bulbs (24,075)
  • Replace boiler with new condensing boiler (11,994)

The number of certificates with each recommendation is shown in brackets.

These are followed by various insulation recommendations.

As we need hot water all year round, solar water heating will reduce energy imports in the summer.

Low energy lighting is probably the simplest measure to apply, LED lights are now available in a wide variety of fittings and in many cases all that is needed is to directly replace an existing bulb with an LED one.

It is optimistic to assume that fitting half of all dwellings with Solar PV would reduce emissions significantly as solar panels are only really effective in the summer during daytime, when energy is not required for heating or lighting. Solar panels are only likely to reduce emissions in the summer if the electricity generated is not exported. A storage battery can ensure that you have electricity at night, but there is no prospect of storing energy in the summer for use in winter. Now that time of use based tariffs are appearing following smart meter roll out, a battery could also be used to take advantage of low off peak rates, when hopefully more of the energy mix comes from renewables.

Electric heating has the potential of being zero carbon, whilst gas does not, so it is disappointing that heat pumps do not feature as a possible solution in the recommendations, but that gas boilers do. This probably reflects that:

  • Heat pumps are more expensive than gas boilers
  • Heat pumps work best with lower flow temperatures, so need larger emitting surfaces, ideally underfloor heating.

How well do EPC emissions estimates match reality

According to EPCs the total emissions for Teignbridge are 157.7 kilo-tonnes (kt).

An estimate is made for each year by BEIS for local authority emissions by fuel and sector, this can be found here https://www.gov.uk/government/statistics/uk-local-authority-and-regional-carbon-dioxide-emissions-national-statistics-2005-to-2017. Domestic emissions for Teignbridge for 2017 from this source are 183.1 kt. This estimate is based on actual consumption figures, so is more accurate.

EPCs only represent 37,247 dwellings, whereas there are about 54,000 dwellings in Teignbridge. EPC derived emissions are increased by a factor of 1.45 (54000/37247) to 228.7 to take this into account, so adding up EPC derived emissions overestimates by about 25%. This is probably down to a number of factors:

  • Space heating calculations used in EPCs assume a standardised temperature of 21C during heating periods in the living area. It is likely that most houses are heated to lower temperatures.
  • When assessing existing buildings assessors have to make assumptions about construction, as the assessment must be non-destructive.
  • Calculations derive CO2 emissions from calculated energy consumption using standard conversion factors for each fuel type. Over time these factors have changed, most noticeably the electricity factor to reflect increased use of renewables. This means that EPCs will overestimate emissions from some fuel types.

A more accurate estimate of domestic emissions for small areas could be calculated from actual consumption. Domestic gas consumption is available by postcode, and electricity is available at census LSOA (Lower Super Output Area) level. This article and associated data will be updated once this analysis has been done.

EPC data is a useful starting point for Parish and Town councils who have declared a Climate Emergency.  It will help to set carbon targets and implement initiatives that help reduce emissions.  An alternative approach would be to calculate emissions from BEIS data on a pro-rata basis, or use the results of our consumption based analysis once it is available.  Ultimately the most accurate and up-to-date method is for individual property owners/occupiers to do this assessment themselves, either by commissioning a new EPC, or by simply reading their energy bills or meters.  Please contact ACT’s Built Environment group for information on how to do this.

Where are domestic emissions in the district

The EPC data includes a postcode for each property, so EPCs can be analysed against a number of geographies including:

  • Parish boundaries
  • Census 2011 output areas
  • Teignbridge wards
  • Teignbridge district

Mapping Emissions

To finish this article here are maps. If you click the mouse over an area on the map, you will be shown some statistics about the area. Both the maps below are synchronised so that they always show the same place at the same scale.

Here are some links to map only pages:

Footnotes

  1. If you follow the link to the opendatacommunities site you may get a security warning, this can safely be ignored.