In December the Scottish Housing Regulator published its Technical Guidance on EESSH. I’m sure many minds are focused on both meeting the reporting requirements of EESSH as well as cost effectively upgrading properties to meet the standards and to benefit tenants.
Below is an outline of how our CROHM service (costing in the region of a single kitchen and bathroom upgrade) can comprehensively meet the reporting requirements and put you in the very best position to plan and carry out works.
I’ve included the exact wording from the technical guidance and then outlined how our service not only fulfills the requirements but also offers real value.
EESSH Technical Guidance Responses
In the preamble to the specific requirements is a section on accuracy of data. In all our dealings with housing providers the length and breadth of the UK, we’ve never come across an organisation whose data is as bad or as good as they think. Even more importantly, none are able to quantify their data confidence either at a property, estate or stock level. An integral part of our CROHM process is collating and cleaning data from multiple sources, and then intelligently cloning remaining gaps.
Accuracy of data
It is important that we, tenants and other service users, have confidence in the performance data produced by landlords. We use the data submitted by landlords to assess risk and decide on our regulatory engagement. It is landlords’ responsibility to ensure that the data they give us is accurate and we will check the accuracy and reliability of the EESSH data by including that in our regulatory work with a range of landlords. Landlords should, as a matter of course for their own internal audit or for their performance management systems, retain the calculations and workings for the EESSH. This should be readily available to provide assurance about the accuracy and reliability of the reported data. Through time we will compare the results with previous years and against other landlords. We will discuss with you the reasons for any differences. It is important that you give us the data in a consistent manner every year.
Importantly, we assign reliability scores to each and every data point depending on their providence. This gives us the ability to provide data scores on everything from individual data points, to properties as a whole, to entire whole stocks and to specific data fields across your stock. In addition to being able to show in detail the accuracy of your data, you also know where to target your efforts to improve your data. As not all data points are equal, improvement strategies may be targeting EPCs on some properties, tightening up your heating controls information through annual boiler maintenance, or targeting a few estates for easily identifiable external data.
One of the key problems we encounter with regards to stock comparisons from year to year – and I’m sure the Regulator will seriously struggle once they get into the meat of trying to do this – is the there are changes due to:
- Different SAP versions being used for new EPCs compared to old data
- Updated data, where it overwrites inaccurate data – i.e. no real improvement has happened
- Updated data where it actually reflects works being carried out
- Disposals and additions
Luckily, change tracking is a process integral to CROHM and allows progress to be shown without all this interference. For instance, for most people we’d expect them to want to show general progress, updated with the best data (i.e. excluding data improvements), normalised for the latest version of SAP, and excluding disposals -which can be reported separately.
Percentage of properties meeting the EESSH By dwelling type and fuel type as at the end of the reporting year, please state: (i) The number of self contained properties (ii) The number of self contained properties not in scope of the EESSH (iii) The number of self contained properties in scope of the EESSH
These are all easily extracted from the CROHM database once the data has been collated and can be presented in many different formats.
(iv) (a) The number of properties in scope of the EESSH where compliance is unknown (iv) (b) Where EESSH compliance is unknown for any properties, please explain why
We should be able to generate estimated RdSAP scores for every property and so we would expect to be able to determine whether they are compliant or not. You could however decide to report properties that have a data score below a given amount as unknown. Again, this would be an easy output from the CROHM data.
(v) The number of properties in scope of the EESSH that do not meet the standard
Easily extracted once the data has been cleaned and run through our RdSAP engine.
(vi) number of properties in scope of the EESSH that are exempt the standard
Through discussions with yourselves, we can determine and set a level for what is deemed ‘excessive cost’, and this can be varied for different property types.
(vii) The number of properties in scope of the EESSH that meet the standard.
Easily extracted once the data has been cleaned and run through our RdSAP engine.
Working towards the EESSH By dwelling type and fuel type, please state: (i) The number of properties you estimated to bring up to the EESSH during the reporting year.
If you can provide your schedule of works planned for the year we can apply this to the data and determine the effect. One of the main benefits of CROHM is to evaluate, order and present all the measures for each property. This can combine cost and practical considerations to build the most realistic and cost effective programmes for your stock.
(ii) The number of properties brought up to the EESSH during the reporting year.
As long as we are provided with list of works carried out and properties affected we can show your progress. Usually the works cover a range of programmes such as boiler upgrades, external decorations and even kitchen and bathrooms.
(iii) If the figures at (i) and (ii) are different, please explain why.
The detail provided by CROHM will allow you to investigate any variances down to individual properties. You can then identify potential causes such as inaccurate data assumptions, programme delays and cost overruns.
(iv) The number of properties you estimate to bring up to the EESSH in the next reporting year?
Again, helping you decide on work programmes is the real power of CROHM.
Anticipated exemptions from the EESSH (i) By dwelling type and fuel type, the number of properties you anticipate will require an exemption from the first EESSH milestone in 2020. (ii) The reasons you anticipate properties will require an exemption (iii) If other reason or unknown, please explain
There are 6 possible categories of exemptions that can be used. We can quickly identify all those that might fall into 3. Excessive cost, and 6. Unable to secure funding (from 2017) and can help with 1. Technical and 5. Disposal.
Energy Performance Certificates (EPCs) (i) (a) The number of your properties which have a valid EPC as at the end of the reporting year. (i) (b) The number of EPCs lodged in the reporting year. (ii) Of the properties with a valid EPC, please state which version of the SAP was used for generating the EPCs. (iii) If other procedure or unknown please explain
As all the data is marked as to its provenance, we would allocate one of the tags to show whether the data has come from an EPC, its version and also its date of issuance.
Investment in the EESSH (i) The total number of properties brought up to the EESSH during the reporting year. (ii) Of the total amount invested in bringing properties up to the EESSH, please state how much came from: (a) subsidy (b) the landlord’s own financial resource (c) another source (d) total amount invested (iii) Please give reasons for any investment which came from another source
By comparing the CROHM data between two dates we can identify all the properties that have reached the target, summarise the measures that have been installed, excluding and reporting separately improvements due to data only, and show costs in various informative ways.
Please get in touch if you want us to contact you about your EESSH strategy and reporting: