― In principle, Common Weal supports mandatory improvements for houses owned by owner-occupiers and private landlords however we note a number of problems with the proposals covered by this consultation.
― We object to energy efficiency being measuring using Energy Performance Certificates due to the severe shortfalls in the methodology used to determine them.
― We consider that mandatory improvements should be made at point of sale, point of change of tenancy or when a property is extended by 25% or more of its floor area. Following a one year grace period, properties that have not been improved by the owner should be barred from sale, lease or further extension until improvements are made.
― The onus of improvement should not be entirely on individual action even when it becomes mandatory. Collective energy efficiency improvements such as installing heat networks or the economies of scale of “whole street” improvements can only be done by collective action at government level.
― Where individual actions are appropriate, grant funding and other resources should be made available to ensure that owners comply with mandatory efficiency improvements.