1 Name of Programme (activity), Project (activity), or Policy

EPC data strategy and policy proposals

This is:

New policy/activity

A change to existing

policy/activity

Existing policy/activity

A pilot programme or project

2 Screening undertaken by:

Director or Deputy Director

Peter Matthew

Policy Developer/Lead

Other people involved in the screening

We plan to consult on increasing access to energy performance data; with a view to implementing regulatory change in 2010. The Secretary of State is the `keeper' of energy performance data which is collected through Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs). As these contain address level data we are treating them as personal data.

In restricted circumstances, address data would be shared to allow named organisations to provide tailored advice and support to owners/occupiers of domestic and non-domestic buildings on help available to improve the energy efficiency of the building. This advice would be free, impartial and with no obligation to take action, either to respond to the offer of help, or to carry out energy efficiency measures.

4 Relevance to Equality and Diversity Duties

Does the policy have relevance to the department's:

Race Equality Scheme?

Disability Equality Scheme?

Gender Equality Action Plan?

Other (departmental or national) equality priorities?

Please explain:

How will these aims affect our duty to:

Promote equality of opportunity?

Elminate discrimination?

Elminate harassment?

Promote good community relations?

Promote positive attitudes towards disabled people?

Encourage participation of disabled people?

Consider more favourable treatment of disabled people?

Protect and promote Human Rights?

For example, think about the policy from the perspectives of different groups in society. Will the policy affect, positively or negatively, any group(s) differently to others? Will it differentially affect:

Are there any aspects of the policy, including how it is delivered, or accessed, that could contribute to inequalities? This should relate to all areas including Human Rights.

Yes

No

Please explain:

If you have indicated there is a negative impact on any group, is that impact:

Legal?

Yes

No

Please explain:

Intended?

Yes

No

Please explain:

5 Evidence Base for Screening

List the evidence sources used to make the screening assessment (i.e. the known evidence)

2007 English House Condition Survey Report (CLG, Sept 2009)

Consider whether there are any significant gaps in the known evidence base and list here your recommendations for how those gaps will be filled.

The data we are proposing to share relates to buildings rather than individuals. The EHCS evidence base does not clearly relate energy efficiency of buildings to different equalities groups. Some evidence can be derived by analysis such as that carried out as part of the EHCS (now the English Housing Survey). Greater sharing of anonymised data for research purposes may allow us to identify and assess trends in the energy performance of buildings against other socio-economic or equalities factors.

6 Remembering the requirements of the equality duties:

Will there be/has there been consultation with all interested parties?

Yes

No

Please explain: In late 2010 we will be publicly consulting on our proposals, including how they may impact positively or negatively on different equalities groups.

Yes

No

Please explain: The Register contains a unique set of data covering the built environment for both England and Wales. It spans both domestic (existing homes, rental and new build) and the non domestic (commercial sale/rental/new build/publicly accessible) buildings. In respect of EPCs, information is collected about the fabric of a building, the plant (air conditioning, heating, etc) used in a building, its existing energy performance. In respect of DECs, information is collected on the actual energy use of the building based on energy consumption. This information, with the supporting advisory recommendations, can be used by the building owner to reduce both the energy usage, and therefore carbon emissions, of the building as well as reduce the costs related to energy use.

Yes

No

Please explain: The Energy of Performance Buildings Directive has already been transposed into UK; as such EPCs and DECs are legal requirements.

Yes

No

Please explain:

Yes

No

Please explain:

From the known evidence and strategic thinking, what are the key risks (adverse impacts) and opportunities (positive impacts & opportunities to promote equality) this policy might present?

Opportunities might include:

Targeting of advice and support may be focused on buildings with poor energy performance in the first instance - F&G rated properties (this equates to the definition of a `cold home' under Housing Health and Safety Ratings System). Often the worst performing dwellings are large semi or detached properties, and owner occupied; there is no direct correlation with certain groups identified above. Where these are occupied by those on a low income or priority groups for tackling fuel poverty, then grant funding may be available to help with the costs of making energy efficiency improvements. Those that choose to take action are likely to benefit from reduced fuel costs and greater thermal comfort.

The homes of social tenants and vulnerable private sector households (in receipt of a means tested or disability-related benefit or tax credit) have improved more on average than those in more affluent areas. Cross Government programmes such as Warm Front, Decent Homes and Carbon Emissions Reductions Target (CERT), targeted at the condition and energy efficiency of homes occupied by social tenants and vulnerable private households are a key factor in narrowing disparities. The proposals to improve data sharing may help support such initiatives by ensuring tailored advice is provided directly to such households.

The picture regarding black and minority ethnic groups is complex. Ethnic minorities (and also those in poverty and worklessness) are more likely to live in homes with serious mould or condensation. But they are also less likely to live in homes that are difficult to heat. This is likely to be a consequence or a greater proportion of black households in social rented housing where these problems are more likely to occur, and larger, more overcrowded households than average for Asian households.

The private rented sector has a greater proportion of energy inefficient homes (G-rated EPC) (but also greater proportion of very energy efficient homes). Vulnerable private tenants were most likely to be living in non-decent accommodation (52% compared to 35% of vulnerable home owners). Older households (vulnerable or non-vulnerable) who were living in their homes for 30 years or more were particularly likely to be living in non-decent homes (42% of them). Vulnerable families with children who were privately renting were also particularly likely to live in non-decent homes (46% compared to only 28% of families with children living in social housing).

Our proposals would allow local authorities access to data to help them target private sector landlords and properties to improve energy efficiency and so support the most vulnerable tenants and families.

Risks (Negative)

Opportunities (Positive)

Race

NA

Yes

Disability

NA

Yes

Gender or Gender identity

NA

NA

Sexual Orientation

NA

NA

Age

NA

Yes

Religion/Belief

NA

NA

Human Rights

NA

NA

For policies affecting staff, those with flexible or agreed working patterns

NA

NA

7 Proportionality

Describe the scale and likelihood of these risks and opportunities:

Low

8 Decision

Set out the rationale for deciding whether or not to proceed to full impact assessment (refer to guidance notes)

A full assessment is not required. No medium or high impacts have been identified for any of the equalities groups listed in section 4. The proposals relate to buildings, rather than individuals. The relationship between the energy efficiency of a building and the profile of the owner/occupant is a mixed one, so targeting the worst properties would not necessarily target the equalities groups. Finally, there would be no legal obligation on those contacted to make energy efficiency improvements, although vulnerable and low income occupants are more likely to be able to have grant support to make improvements and may be more likely to benefit in terms of health and thermal comfort.