Even though much has been done with regards to improving the energy efficiency of homes, energy prices are still rising and 34% of households across Scotland are still in fuel poverty1 according to new statistics from Energy Action Scotland. Energy Efficiency Standard for Social Housing (EESSH) is intended to contribute towards improving affordability and comfort by setting minimum energy efficiency (EE) ratings for social landlords to comply with by December 2020. The Scottish Government has just convened an EESSH working group to look at progress to date and looking to set a standard beyond 2020. However, should the focus be on increasing efficiency standards or should we be looking at a more comprehensive approach to achieve the outcome we want of affordability and comfort for tenants?

Changeworks recently conducted research for the Scottish Federation of Housing Associations (SFHA) with approximately 20 housing associations and co-operatives to establish the likelihood of achieving EESSH compliance by 2020. From this research it is evident that while the majority are finding upgrading their housing stock to comply with EESSH a challenging task, they do have plans in place to deliver. However, a reoccurring challenge highlighted in our research is ensuring that the measures installed to meet EESSH deliver improved affordability and comfort in practice. Changeworks’ experience of post installation EESSH monitoring and evaluation has identified inconclusive or negligible results, suggesting that an improved theoretical EE rating is not equating to energy savings with improved affordability and comfort in reality.

Improving affordability

People consume energy, not the buildings themselves. With this in mind, I think our approach to improving affordability needs to evolve from considering homes in isolation to assessing the socio-economic system that is the relationship between a home and its user. Changing the physical structure of a system, as we are trying to do when we install insulation or more efficient boilers into a home, is not necessarily the most effective intervention on its own. This is because it is a simplistic approach and doesn’t account for the cause and effect consequences of installing measures and the complexity of human behaviour. For example, tenants may have a perception that a ventilation system is draughty and uses more energy. This may result in the ventilation system not being used correctly and increasing the likelihood of condensation and higher fuel bills.  A more effective approach to tackling fuel poverty would be to make householder education and support a central consideration rather than a peripheral when installing measures. This may be by creating information for tenants such as positive case studies from other tenants, advice sheets and face to face engagement at the point of installation. Monitoring and feedback on how much energy they are using can also take place pre and post installation.

Improving comfort

The word comfort is preferred over warmth here because a warm home can become too warm (increasing overheating risk) and have mould or condensation, both causing adverse health impacts. There is a growing body of evidence relating to health risks in energy efficient retrofit. A recent study highlighted a two fold increased risk of asthma for people living in homes with >71 EE rating (a typical EESSH compliance rating). A key reason for this can be attributed to poor indoor air quality due to a lack of controlled or correctly operated ventilation. This can often be overlooked in retrofit projects, as there is little in the way of funding for this measure and is not mandatory for EESSH compliance. Therefore, I think our approach to comfort needs to evolve from one of just increasing warmth in a home to one of creating a comfortable indoor environment. Ventilation is essential to achieving this. 


Improving the energy efficiency of homes is important, but it is crucial that this work is done holistically.Focusing on an energy efficiency (EE) rating for EESSH compliance must go hand in hand with the following:

  1. Tenant education, support and behaviour change being central rather than peripheral considerations. Face to face engagement and positive informative stories and case studies are required. 
  2. Focusing on creating comfortable indoor environments, not just increasing warmth in a home, to ensure we are not storing up building performance and tenant health problems in the future. Ventilation combined with tenant education and support is required.

Ultimately, it must be realised that all the aforementioned issues are interdependent on each other. If we don’t address them all simultaneously, we won’t achieve the outcome we want of affordability and comfort for tenants.

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Chris Martin, Changeworks





Chris Martin is Changeworks’ Senior Consultant 

  1. A person is living in fuel poverty if, in order to maintain a satisfactory heating regime, they would need to spend more than 10 per cent of their household income (including Housing Benefit or Income Support for Mortgage Interest) on all household fuel use. Source: Scottish Government