Waterwise response to DECC and CLG consultation on Amendments by xfo14057



Waterwise response to DECC and CLG consultation on the Heat and Energy
Saving Strategy
May 2009
Overall response
Waterwise very much welcomes the innovative strategy and policies detailed in the HESS

However, we consider that not including water efficiency in the HESS would be a missed

Water heating within the home, for cooking, bathing and cleaning, accounts for about a quarter
of domestic fuel bills, and 5% of total UK greenhouse gas emissions. The Energy Saving Trust
estimates that, once the low hanging fruit of space insulation and boiler upgrades has been
picked, domestic hot water consumption will be the dominant component of domestic energy
consumption. Hot water efficiency measures will therefore save families money. Buildings will
also save money through installation of these measures. In addition, water efficiency measures
across the board, including toilets and urinals, will reduce the carbon footprint of the UK water
industry (accounting for almost 1% of total UK greenhouse gas emissions) as it will need to treat
and pump less water to and from homes and businesses – helping government meet the 80%
greenhouse gas emissions reduction target.

There are also wider government policy drivers for delivering water and energy efficiency
measures in tandem – not least making less water go further as climate change adaptation
means less available water, and the population continues to grow. So homes and buildings of
the future will not only need to be energy efficient, and zero carbon, but they will need to be
climate-resilient – any nationwide retrofit scheme must include water efficiency alongside
energy efficiency to meet the challenges of projected drought and intense summers. Quite
apart from the government’s current target of a reduction from the average 150 litres per
person per day to 130 or 120 by 2030, it is inconceivable that even in the next 5 years, let alone
the next two decades, homes which have received a whole-house energy efficiency makeover
might still be wasting water, but this would be the effect if water efficiency is not included in
the HESS. Combining the two also saves considerably on cost.

The consultation recognises the need for this when it states in paragraph 1.39, that “whatever
action we take must be done in a sustainable way. In particular, we must consider the impact of
the changes to our climate we already know will happen.” and, at paragraph 1.41, that “We
need to put together a more comprehensive programme of work for a whole house, rather
than the current (sic) of installing individual measures one at a time.”

Water efficiency measures in the HESS would fulfil the government’s four stated targets as
outlined below:

       Reducing domestic fuel bills both now and in the long term – heating less water for
       cooking, cleaning and bathing

       Reducing UK emissions – heating less water in homes and buildings, and treating and
       pumping less water by the water industry

       Maintaining secure, diverse energy supplies – wasting less energy through heating less
       water in homes and businesses

       Taking advantage of the economic opportunities presented by the shift to a low carbon
       economy in the UK – training skilled practitioners to carry out joint energy and water
       retrofits. The consultation document cites 34,000 jobs on energy retrofits - it is
       estimated that there are currently 25 million houses in the UK, and Waterwise estimates
       that ten homes a day can be retrofitted. Therefore over 20 to 25 years, we estimate that
       approximately 500,000 jobs could be created in water alone: linking energy and water
       retrofits would result in even more significant potential for green jobs.

We set out in detail our proposals on how this could be achieved, in our answers to the specific
consultation questions, below.

Waterwise’s UK Manifesto, launched in April 2009, sets out ten steps through which water
efficiency can help build a climate-resilient economy – including through linking with energy
efficiency retrofit schemes, and further developing the green economy. Waterwise’s UK
Manifesto can be found at www.waterwise.org.uk.

We have also responded to the parallel consultations on the Carbon Emissions Reduction
Target (CERT) and the Community Energy saving Programme (CESP).

Responses to specific consultation questions

Q1: Do you agree with the level of ambition and the indicative pathway set out in this chapter?
If not, why, and what alternative would you suggest?

Waterwise wholeheartedly supports the level of ambition. We believe the HESS to be radical,
proposing a new approach, linking policies and behaviour change intimately, and committing to
further moves if the strategy set out does not deliver enough carbon savings. However, we
propose that the pathway set out needs to include water efficiency.

To meet the government’s 80% greenhouse gas reduction target, water efficiency will need to
be progressed alongside energy efficiency.

The home energy audits in the HESS will immediately identify the use of energy to heat water
for cooking, bathing and cleaning, which accounts for around 25% of domestic energy bills
(second only to space heating) – 5% of total UK greenhouse gas emissions. For all homes and
buildings to be zero carbon by 2050, they will need to be water efficient, to cut down on their

own energy use in heating water. Water efficiency measures will also cut the carbon footprint
of the water industry, which is currently 0.8% of total UK greenhouse gas emissions: as less
water is wasted, less energy will be needed to pump and treat water to and from homes and
buildings. So including water efficiency measures – such as water efficient showerheads and tap
flow regulators for hot water use, and the installation of showers in homes where only baths
were in place before, as well as “cold” water efficiency measures such as toilet retrofits – in the
whole-house energy efficiency retrofit programme for every home by 2030 will contribute
significantly to the 80% target.

In addition to water efficiency being essential in mitigating climate change, it is also one of the
key tools in adapting to it – current climate change predictions include hotter, drier summers
and more frequent droughts, so less water will need to go further. Government plans to deliver
homes and buildings which are genuinely sustainable in the next few decades must include
those homes and buildings wasting less water.

Waterwise’s Evidence Base for Large-scale Water Efficiency in Homes, which we produced in
October 2008 for the Environment Minister’s Water Saving Group, shows clearly that the main
cost of a full domestic retrofit is the visit itself, by a skilled plumber, so combining energy and
water efficiency retrofit schemes is clearly the most efficient way to make all homes both zero
carbon and resilient to climate change, as well as to save families money. (The Evidence Base
can be found at www.waterwise.org.uk )

The water industry also has its own water efficiency targets, and has now been brought by
government into the Carbon Reduction Commitment, and the government has a target of 120
or 130 litres of water use per person by day by 2030, down from the current average of 150.
Linking water efficiency with the HESS will also help deliver these targets.

In Australia, ten joint energy and water retrofits are delivered every day per person, so the
potential for green jobs from training a skilled workforce to deliver joint energy and water
retrofit schemes to every home in the UK is huge. One UK water company is already taking
forward a large-scale energy and water retrofit project, in partnership with an energy company.
These opportunities for joined-up delivery should not be missed.

Q2: Do you agree with the Government’s policy approach set out in paragraphs 1.31 onwards
to achieving our ambitions on heat and energy saving?

We do agree, except that water efficiency should be mainstreamed alongside energy efficiency
in the HESS – the consultation document states clearly that we will need “a step change in how
we all think about how we use energy”. As part of this, we will need to think of water
consumption as an energy use issue – both in terms of heating water for use within the home,
and the carbon footprint of the UK water industry in treating and pumping water to and from
homes and businesses.

Waterwise agrees that raising awareness, and making it easier for householders and businesses
to take action, is important. We are currently working with the Energy Saving Trust, with
funding from the European Union LIFE programme, to deliver joint water and energy advice
through their network of advice centres. We also work closely with retailers, manufacturers and
faith organisations such as Muslim Aid to raise awareness.

We also agree that the installation of energy saving measures needs to be co-ordinated. Our
Evidence Base, discussed in the response to question 1, found clearly that the biggest bang for
retrofit buck can be made when retrofit schemes are delivered in partnership, for example
through housing associations – which is why we welcome the Community Energy Saving
Programme (CESP), to which we have responded separately. (We have recently begun work on
Phase 2 of the Evidence Base, which amongst other issues will attach carbon savings to water
efficiency measures.)

Waterwise has researched the behavioural aspects of energy and water use when linked
together, such as in shower use (an area which does not traditionally enjoy a big evidence
base). A recent Waterwise report on this can be found at www.waterwise.org.uk.

We agree that government procurement has a huge potential role in transforming markets: we
would like the government to introduce a revolving, spend-to-save fund to help public sector
buildings waste less water, supported by procurement standards which reflect the best (rather
than average) available technologies on the UK market.

We support the government’s aim of ensuring that social housing meets, and where possible
exceeds, the aims it is setting for all housing on energy efficiency and low carbon energy.
Waterwise, with other partners, recently delivered a water retrofit scheme of around 400 social
housing units in Preston in Surrey, and is sharing the results with government. (The final report
of the Preston Water Efficiency Initiative can be found at www.waterwise.org.uk ) As part of
this scheme, showers were fitted in 160 homes which had only previously had baths:
considerable water savings resulted, and residents were delighted with their new showers.
Because on average showers use around a third of the hot water used by baths, significant
energy savings can be reaped from such programmes, as well as water savings (which in
themselves will help government meet the statutory 80% cuts in emissions, through reducing
the carbon footprint of the water industry, in pumping and treating water to and wastewater
from homes). In our response to the CESP consultation, we propose that low-flow showerheads
and flow regulators be included in the CESP list of approved measures. In addition, fittings of
showers for the first time (in homes which only previously had baths) should be included in the
HESS and the CESP, as well as the replacing of existing fittings with water-efficient ones. This
will help reduce fuel bills – as well as reducing the UK’s carbon footprint and providing valuable
social gains.

As a footnote, many stakeholders agree that it is a missed opportunity that neither water
efficiency measures nor specifically the presence of showers are required under the Decent

Homes programme – we would like to see such measures included in any future social housing
standard. This would fit with the reference in the consultation to the “wider social benefits of
reduced energy consumption”. As well as the potential impact on fuel bills, homes of the future
will need to be water efficient as climate change takes further hold, with predicted overall
reductions in the amount of water available, combined with population and housing growth,
meaning that the remaining water will need to go further.

The introduction of showers into social housing would also represent a significant improvement
in quality of life: Waterwise experience from past shower retrofits and interviews with social
housing authorities in London has shown a strong demand for showers from tenants.

Q3: How can the Government encourage people and communities to change behaviour to save
energy? What is the appropriate balance between changing attitudes, and providing advice and

Working with retailers and manufacturers is key to this – Waterwise has run campaigns with
B&Q and Ariel (Procter and Gamble) and both have led to changes in customer behaviour. It is
also important to link energy and water use in terms of savings on fuel bills, as well as the need
to waste less water as climate change bites harder: Waterwise is taking this forward with the
Energy Saving Trust, as outlined in the response to Question 2.

We also work with faith groups such as Muslim Aid and Christian Aid. In our experience, such
partnerships can deliver significant behaviour change.

As part of the Preston Water Efficiency Initiative, which Waterwise recently delivered with
other partners, and which is detailed above in the response to Question 2, the community shop
was involved in promoting the initiative to householders, and displaying water efficient washing
machines and dishwashers which were used as prizes for involvements in the scheme. The local
nature of the running of the project was key to the success it delivered in terms of water

Q4: How can home energy audits be made most useful, and do you agree that the Government
should use Domestic Energy Assessors, who have been suitably trained, to deliver them as
widely as possible?

Around a quarter of energy use in the home comes from heating water for cooking, bathing and
cleaning – this will be identified by individual home energy audits as soon as they are
undertaken. We believe therefore that Domestic Energy Advisers should include basic advice on
not wasting hot water, as, for the reasons outlined above, an energy efficiency programme
which doesn’t include this will not be meeting its full potential. We also urge the government to
include water efficiency advice as it develops the National Occupational Standard, which will
“set out the skills and competences and training levels required to provide behavioural advice
on ways of improving energy efficiency and energy savings products to individual

Q5: Should the Government work with industry to develop accreditation standards for advice
about, and installation of, energy efficiency technologies? What would be the best model for
such a scheme, and why?

Such schemes should include water efficient fittings and products such as water efficient
showerheads and tap flow regulators. Due to the variability of UK plumbing, there should also
be clear guidance at point-of-sale and in any promotion material, and minimum standards for
performance in showerheads in order to ensure consumer confidence.

Q6: Are the information, advice and support services provided by the Government to
businesses effective in encouraging them to reduce their energy use and their CO2 emissions?
What other types of support services are useful and how can these be provided cost
effectively? Is there scope to do more on behaviour change through businesses and their
employees? Please support your suggestions with evidence.

For the reasons of cutting energy bills and climate change mitigation and adaptation outlined
above, the advice should include water efficiency measures. Specifically, compatibility, project
savings, and details of procurement.

Q7: Are the existing commitments for public sector buildings sufficient for the public sector to
fulfil its role in driving improvements and leading by example?

No. Currently the product procurement standards (Quick Wins) set for public sector buildings
only reflect the average performers in terms of water efficiency currently available on the UK
market – they should require the best available technologies, to drive and transform the market
in water efficient technologies, and should be regularly updated. Water efficient showerheads,
taps, dishwashers and washing machines will waste less hot water so will save public buildings
money: and as all non-domestic buildings are metered for water, they will save money on water
bills too, as well as reducing the carbon footprint of the UK water industry through wasting less
water with water efficient toilets and urinals. Public sector buildings are also well-suited to low-
cost, high-return investments in water efficiency, such as simple toilet flush devices, altering
urinal flush rates, and tap aeration; because these usually result in short payback periods, they
would make revolving fund structures effective.

Q8: What will be the most effective way for Government to develop RHI and FIT policy so that
combined financing packages of insulation, renewable heat and small-scale low carbon
electricity technologies might be offered?

No comment.

Q9: What action, if any, should the Government take to enable finance to be arranged for the
higher cost energy efficiency and low carbon measures? Are there other options the
Government should consider? Please provide evidence to support your response.

No comment.

Q10: What should the Government do beyond these initiatives to promote investment in
energy saving and low carbon energy technologies in business and the public sectors?

Include hot water efficiency measures such as water efficient showerheads and tap flow
regulators in the Carbon Emissions Reduction Target, and reduce VAT on water efficient
products, as well as tighten product procurement standards for public buildings.

Q11: Should levels of support through the Renewable Heat Incentive vary by technology and/or
customer group? Are there any other ways of differentiating levels of support under the RHI?

No comment.

Q12: How can we introduce the levy to fund the Renewable Heat Incentive so as to minimise
suppliers’ administrative costs and reduce uncertainty among suppliers of fossil fuels for heat?

No comment.

Q13: Do you think that financial institutions, such as banks or other loan companies, would be
an effective way of assisting potential small-scale heat generators (such as householders) with
financing of the initial capital cost of renewable installations? What other considerations, if any,
should be taken into account when determining eligibility for an up-front payment (for
example, only generators with equipment below a certain size can apply, such as domestic

No comment.

Q14: How can we maintain demand for renewable heat technologies before we introduce the
Renewable Heat Incentive?

No comment.

Q15: Do you agree with the proposal to continue with a CERT-type obligation until December
2012? Do you also agree that the proposed CESP framework should run concurrently to the
same end date?

We do agree with these timeframes. But we believe (as outlined in our response to the parallel
CERT consultation) that CERT should include hot water efficiency measures.

It makes sense for the carbon savings from hot water efficiency measures to be included in the
CERT scheme. Mixer showers represent about 60% of showers owned in the UK and generally
compatible with efficiency retrofits. A flow regulator has already been accepted into the CERT

scheme, but at the time of writing efficient showerheads - arguably the most effective hot
water efficiency device - are not. Where there are taps present with standard metric screw
heads, efficient fittings are also possible. The carbon savings from showerheads should be able
to be counted under CERT, by either water or energy companies, or both. We believe that
Ofwat and Ofgem could work together to develop a standard mechanism for this process to be
recorded. This, from the two regulators, would result in significant carbon savings: with
incentives for both energy and water companies. Since both industries have demand
management targets – for energy and water respectively – there is also a significant financial
incentive to carrying out joint retrofits (not least because the biggest cost of a retrofit is the
visit to the home itself).

Q16: Do you agree with our analysis of the potential impacts of a cap-and-trade approach to
delivering energy efficiency in homes? Please support your answer with evidence.

No comment.

Q17: Do you have views on the merits of moving to a different approach for delivering energy
efficiency to households? Do you have other suggestions of alternative delivery models which
might be effective in achieving our objective?

We believe that both a central, national delivery model and a less centralised model have
merits. However, we believe that in any delivery model, it is essential that water efficiency
measures are mainstreamed alongside energy efficiency retrofitting measures – to save families
more money, to contribute to the 80% emissions reduction target, and to ensure that homes of
the future are climate-resilient (wasting less water).

Q18: Would you support a voluntary code of practice on energy performance for landlords
and/or builders? How high do you think uptake would be, and would it achieve much additional
action? Please support your response with evidence.

We agree that this would be useful, including in building the evidence base for a potential Code
for Sustainable Refurbishment. It should include energy use within the home from heating

Q19: Should we require marketing material for property sales and rental to feature the EPC
rating more prominently? If so how? What delivery bodies or industry groups could be given
access to the EPC database, and how could they make best use of it whilst ensuring that it is not

Please support your answers with evidence.

Yes – and water efficiency should be included in the Home Information Pack.

Q20: Besides removing the threshold for consequential improvements, which will be
considered in the consultation on changes to the Buildings Regulation in 2009, are there any
other options for wider building regulation that you would like to see considered in the longer
term? Please support your answer with evidence for the effectiveness of your suggestions.

We continue to support the government’s addition of water efficiency into the Building
Regulations for the first time, at a whole-house standard of 125 litres per person per day.

Q21: Do you agree with the approach of conducting a review in 2012 to assess the effectiveness
of other policies before considering further policy interventions for the energy performance of
existing buildings? Are there other options you think should be part of our strategy? Please
support your answer with evidence.

We agree that committing now to considering stronger regulatory measures if necessary in
2012 is an innovative and welcome approach.

We would like to see hot water efficiency measures included in the Landlords Energy Saving
Allowance scheme.

Q22: Do you agree that the Heat Markets Forum should consider regulatory arrangements for
district heating to ensure consumer protection? Are there specific issues you think it should

No comment.

Q23: There are a number of ways to tackle commercial barriers to district heating. These
include using the planning system and heat mapping, encouraging or requiring certain buildings
to connect to networks and engaging property developers.

Which of these options should be taken forward and why?

No comment.

Q24: What are your views on the options for reducing the risks of poor returns on investment in
district heating networks? Which do you think would be most effective and are there other
more appropriate solutions?

No comment.

Q25: Will the ETS and other policies, such as the Carbon Reduction Commitment and support
for renewable combined heat and power, send a strong enough signal to encourage the
development of CHP schemes and more efficient use of surplus heat? If not what measures do

you believe would provide sufficient stimulus to accelerate new CHP capacity build? Can you
provide evidence to support your view?

No comment.

Q26: As electricity generation overall becomes much less carbon intensive than today, the
advantages of CHP powered by fossil fuel in reducing carbon emissions will diminish, although it
will continue to be a cost-effective energy efficiency measure. When do you think CHP powered
by fossil fuels will no longer help to reduce emissions because the alternatives are less carbon

No comment.

Q27: Should the Government do more to publicise the opportunities and benefits of CHP and
surplus heat? If so, how should it do this, and which are the key audiences we need to reach?

No comment.

Q28: Do you consider such cooling technologies can play a role in delivering a renewable and
low carbon energy mix? What opportunities exist for their exploitation in the UK? What further
factors do we need to consider?

No comment.

Q29: Do you agree with our analysis of the likely impacts of the proposals in this document and
in the associated impact assessments on:

●● carbon dioxide emissions?

We do not agree that the proposals “explore the best ways to deliver the carbon savings …….
Identified in previous strategies”, because they currently exclude water efficiency measures, so
the full potential of carbon dioxide emissions reductions will not be realised.

●● energy prices?

●● fuel poverty?

●● security of supply?

●● sustainable development?

Not as currently defined, namely to the exclusion of water efficiency measures. In the next few
decades, as homes and buildings across the country are made energy efficient, and zero carbon,

through the HESS, they will also need to be made climate-resilient – water efficiency measures
will need to be included to ensure that homes and businesses can function when less water is
available, as predicted in climate scenarios. At the very least, there should be no emissions from
heating water.

In addition, as the consultation document identifies, many low-carbon energy sources (such as
carbon capture and storage) require water for cooling purposes, putting pressure on water
resources and water quality. This is a very strong argument for mainstreaming water efficiency
in the HESS – to maintain supply-demand balances as these become more challenging under
climate change.

The consultation document also quotes the Stern Review’s conclusion that the benefits of
strong, early coordinated action against climate change far outweigh the economic costs of
inaction. This applies just as much to adaptation – making less water go further, through water
efficiency measures – as to mitigation.

●● the economy?

Are there any other wider issues that we should consider? Do you have any other comments on
the Impact Assessments?

No comment.

Waterwise is a UK NGO focused on decreasing water consumption in the UK by 2010 and
building the evidence base for large scale water efficiency. We are the leading authority on
water efficiency in the UK. In England, we sat on the Environment Minister’s Water Saving
Group alongside the water industry and regulators.

The following documents can be found at www.waterwise.org.uk:

       Waterwise’s UK Manifesto (April 2009)
       Waterwise’s Evidence Base for Large-scale Water Efficiency in Homes (October 2008)
       The final report of the Preston Water Efficiency Initiative (April 2009)
       The Water and Energy Implications of Bathing and Showering Behaviours and
       Technologies (April 2009)

Nicci Russell

Policy Director, Waterwise

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