Toothless legislation is not the answer

with cavity walls have CWI installed. This leaves us with roughly 356,400 dwellings (around 13% of the housing stock) with unfilled cavities.

However, some indeterminate number of these will have cavities that, for various reasons, cannot or should not be filled. This in itself is hardly ambitious, but it also ignores those properties with CWI where the insulation has settled or been damaged and so needs replacing. We’ll never know how many homes need this as we won’t be inspecting them, and given that poor maintenance is a fundamental problem for improving energy efficiency, it’s a glaring omission that the word maintenance appears not once in the entire consultation document.

Or we could take another measure, draught-proofing. This is so lacking in definition in the consultation that it could apply to almost all or none of the entire housing stock. A similar argument could be made about what is meant by “heating controls”.

Having responded at length to the consultation, I have to conclude that the Scottish Government has only the faintest idea of the scale of the task, insufficient data on which to base the policy solutions, very little understanding of even basic energy efficiency measures, and no real idea of where the money to implement them will come from.

Returning to RECOs, top of my long list of pet hates of Scottish Government policy-making is the regularity with which ministers take a perfectly good policy proposal and butcher it. I don’t know if those behind the HiB were aware of RECOs – although I did recommend that the Scottish Government adopt one in a 2012 report for them.

We’ve seen this with the National Investment Bank, the National

Care Service, the use of zoning for deploying district heating without first implementing a Heat Supply Act (something Denmark passed in 1979), and many more examples.

I understand that many people may baulk at the idea of being forced to upgrade their properties, but if we don’t tackle energy inefficiency we can kiss our climate change targets goodbye. However, what we will be made to install must be appropriate, affordable, and result in measurable improvements. The proposals in the HiB are way off meeting these criteria and in some cases may leave householders with problems such as overheating.

What is needed now – as Common Weal set out in the Common Home Plan – is a major programme of public works to future-proof our buildings to 2045. This will not come for free, but it’d be cheaper and more effective than leaving our society and economy exposed to the impacts of climate change and a volatile global energy market.

We can, and we must, do better.