NexGen recently submitted a comprehensive response to the Consultation on a reformed Decent Homes Standard for social and privately rented homes. Our feedback focuses heavily on the critical link between home heating, thermal comfort, and the growing threat of damp and mould.

The Urgency of Damp and Mould: Why We Need Faster Action

The health and financial costs of poor housing are staggering. NexGen advocates for the rapid introduction of the proposed Criterion E, which requires properties to be free from damp and mould. We argue that this standard should be implemented sooner than the suggested dates of 2035 or 2037.

The urgency is clear:

• Damp and mould already cost the NHS an estimated £1.4 billion per year.
• Improving just 65,000 homes with a Category 1 damp and mould hazard would cost £250 million but yield a massive £4.8 billion benefit to society over 30 years.
• In the English Housing Survey, 44% of households in the Private Rented Sector (PRS) and 39% in the Social Rented Sector (SRS) reported problems with condensation, damp, or mould.

“Waiting 10 years before introducing the new DHS, with its stricter provisions around damp and mould, fails to address the scale and urgency of the issue in the rented sector, and would fail tenants in desperate need of support”. We believe Criterion E should be introduced ahead of the full implementation dates because of the “significant threat of damp and mould to physical and mental health”.

Redefining Disrepair and Thermal Comfort

NexGen also submitted several key recommendations to update how disrepair and thermal comfort are defined within the Decent Homes Standard (DHS).

 Heating System Disrepair

We agree that the thresholds for defining disrepair should be updated to be more descriptive. Critically, the definition for a heating system should be expanded:

“We believe the definition of disrepair for the heating system should be updated to include where a heating system is unable to maintain a reasonable temperature and level of thermal comfort for tenants“.

A system can fail to heat a property adequately, if it is unsuitable or undersized, without being technically broken. In such cases, it should be considered non-compliant with the DHS. In fact, we argue this inadequate heating should also be recognised as a potential cause of damp, and the definition of disrepair should reflect that.

Challenging the ‘Whole Home’ Requirement

We disagreed with the proposal that the primary heating system must be sufficient to provide heat to the entire home. While optimal in most cases, this may not be “practical or cost-effective” for all properties, especially given the diverse UK housing stock.

“In homes of certain typologies, for example those with a separate annex, it is likely to be more cost-effective to install a separate heating system with a lower CAPEX to provide space heating in those parts of the property than cannot effectively be heated using a single heat pump”.

NexGen argues for flexibility, allowing a qualified assessor to determine if a multi-technology approach would be more favourable to a single system.

NexGen’s Far Infrared Solution

NexGen’s innovative Far Infrared Heating technology offers a sustainable and effective solution to many of these problems. It uses an electric ceiling paper fixed to the ceiling and plugged into the electricity supply.

Our system is founded on breakthrough Intellectual Property using Carbon Nano Technology. It delivers energy more efficiently than convection-based systems by emitting Far Infrared at the exact wavelength of sunlight, directly heating residents, objects, and the fabric of the room.

 Tackling Damp and Mould Directly

One of the key benefits of our technology is its ability to eliminate damp and mould.

“Case study evidence from residents’ homes in Scotland has shown that NexGen can permanently eliminate damp and mould within one to two weeks by drying out internal surfaces and maintaining a safe internal humidity level of between 40% and 60%”.

By deeply heating the fabric of the room, our IR system evaporates moisture and forces damp out, permanently removing moisture and reducing thermal bridging, which also cuts down on mould growth.

 Promoting Thermal Comfort

Our technology also provides excellent thermal comfort. Empirical evidence suggests that our system can provide the same level of thermal comfort at a lower ambient air temperature compared to convective heating. This is because the direct heating raises the mean radiant temperature, allowing occupants to feel comfortable even if the air is cooler.

NexGen’s controls system also enables occupancy-based zonal and sub-zoning control, meaning a specific room can be heated up within minutes, eliminating the need to continuously heat the entire house. This delivers “quick, dynamic heating and thermal comfort… and significantly reduce the system’s overall energy consumption and running costs”.

The Need for Updated Guidance

NexGen strongly believes that the best practice guidance accompanying the DHS needs to be updated. We recommend including guidance on identifying and addressing damp and mould problems to help landlords comply with the new Criterion E.

Specifically, the guidance should:

• Include a ‘Recommended Solutions’ section to raise awareness of effective solutions.
• Recognise the full range of innovative retrofit solutions available, such as NexGen’s Far Infrared technology, instead of only established measures like insulation and ventilation.
• Emphasise the importance of permanent solutions to ensure landlords don’t apply “cheap, temporary fixes”.
• Clearly define ‘all possible remedial action’ to prevent landlords from circumventing their legal responsibilities.

NexGen Carbon Zero Ltd is an innovative British manufacturer in the heating industry. We currently have innovation-funded installation and pilot programmes underway with the Scottish and Welsh Governments, as well as 60 social housing providers.