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Green Deal Consultation - September 2012 • CAN Response to DECC Green Deal Consultation- September 2012

2014-11-10T16:03:43

Attached below is the National Carbon Action Network's response to the Department of Energy and Climate Change Green Deal consultation, which was submitted on 5 September 2012.

Many thanks to everyone who emailed through their comments.

CAN Green Deal consultation response from website.pdf

Statistics:Posted by ALEO Admin — Mon Nov 10, 2014 4:03 pm

Green Deal Consultation - September 2012 • Re: Chapter 12: GD monitoring & evaluation and ECO admin

2012-01-18T15:26:01

My individual views only

61. One of the main failings of past activity has been the lack of an individual property database to record all activities. Either the regulator or Local Authoritiesw through their HECA functions could be charged with recording all data on GD, FiTs and RHI at least on Domestic stock if not commercial as well. This would help wityh targeting and fraud prevention.

62. I would prefer the function to remain with people who develop a leagcy of understanding so that they can inform future iterations, and unfortunately government departments are subject to regular change so I would suggest OFGEM is better placed.

Statistics:Posted by David — Wed Jan 18, 2012 3:26 pm

Green Deal Consultation - September 2012 • Re: Chapter 11: Setting the ECO and target metrics

2012-01-18T15:20:19

Please note these are my individual comments only.
56. No comment

57. Whilst the amount £1.3billion is substantial the split on the affordable warmth of 25% means the whole budget for the vulnerable is very low and below existing allocations. This is likely to mean fuel poverty targets will remain unattained. My concern is not with the amoount but with how the money could be aloocated. The removal of subsidies for basic insulation could destroy the cavity and loft insulation industry overnight and lead to many missed opportunities. If estimates for for unfilled cavities are accurate and remain quite high I would like to see a tapered support introduced as part of the Carbon saving element for eample a 50% subsidy in year one and 10% removed in each following year. This would give the industry time to adapt to solid wall insulation and keep basic and high carbon saving activity vibrant while many cavities are yet to be filled. A mass transition in a short space of time will lead to many technical errors that could set Soild wall insulation back many years, so allowing more familiar activity to continue and form part of the obligation will allow some elements of the targets to be dealt with in confidence allow more attention to the qulaity of solid wall insulation.

58. no preference

59. No real problems other than this will replace Warmfront and hance there is no Energy saving in repairing a boiler and little in replacing a 5 or 6 year old one so unless allowance is offered for affordable warmth SAP may be not be best.

60. Lifetime savings take account of the persistence of the measure so this is preferrable but expressing both not be a problem with the way data is collected.

Statistics:Posted by David — Wed Jan 18, 2012 3:20 pm

Green Deal Consultation - September 2012 • Re: Chapter 5: Delivering equitable support and tackling...

2012-01-18T14:52:50

Below are some comments received via email from Paul Maplethorpe, East Pennine CAN Chair:

Chapter 5
Q32 should be given a time frame with strict set response times and penalties for slipping

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 2:52 pm

Green Deal Consultation - September 2012 • Re: Chapter 4: The Golden Rule

2012-01-18T14:51:37

Below are some comments received via email from Paul Maplethorpe, East Pennine CAN Chair:

Chapter 4

Q25 5% too low should be 10% would not expect to offer additional consumer protection

Q27 keep interest in line with inflation or hold interest rate as an incentive

Q28 Pay lone of in full and not have it front loaded

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 2:51 pm

Green Deal Consultation - September 2012 • Re: Chapter 3: Green Deal provider and plan

2012-01-18T14:50:20

Below are comments received via email from Paul Maplethorpe, East Pennine CAN Chair:

Chapter 3
Q19 no bonds too high a cost

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 2:50 pm

Green Deal Consultation - September 2012 • Re: Chapter 2: Measures, products and systems

2012-01-18T14:48:38

Below are some comments received via email from Paul Maplethorpe, East Pennine CAN Chair:

Chapter 2
Q 12 NO other measures should be considered it should not be viewed as a solid wall ECO scheme consideration should be given to hard to treat cavities in all tenures.

Q13 again no for reason Q12 What about flats where external wall insulation may be impractical also what about listed buildings it should not be a package of measures offered but what is appropriate for the property in hand which may be only one measure.

Q15 only a A rated boilers should be repaired rest should be replaced to A rated Warm Front boilers should be replaced

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 2:48 pm

Green Deal Consultation - September 2012 • Re: Chapter 10: Consumer protection

2012-01-18T11:00:56

Thanks to Jane Mears, Vice Chair of East Pennine CAN, for emailing the comments on Chapter 10 below, which were discussed at the EP CAN forum meeting on Friday. These will be taken into consideration for CAN's response which is being prepared for today's consultation deadline.

With regards chapter 10 there was concern over mis selling to people eligible to ECO AW .
The feeling was that liability should be with the GD provider but GD assessor must be independent.
Great concern over cold calling zones and will they still exist in GD.

Yes the energy ombudsman should have a role but who will fund this?
In reality will it be the same as now and people aggrieved will come to the council/CAB etc and we will have to put a case together to get the ombudsman to take the matter up.

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 11:00 am

Green Deal Consultation - September 2012 • Re: Chapter 9: Delivering Green Deal and ECO

2012-01-18T10:53:08

Below are some comments on Chapter 9 emailed through from Rachel Jones, West Midlands CAN Chair. Thanks to Coventry City Council for most of these comments. They will be taken into consideration for CAN's response which is being prepared for today's consultation deadline.

Q51: Do you agree that stipulating strict regulatory quotas for partnering with specific types/numbers of third party delivery agents might be unduly burdensome, and the development of a brokerage model may be a more effective means of achieving the desired outcome?

Agreed. It will however be important for the brokerage model to operate in such a way that it does not work to the detriment of area based schemes delivering ECO obligations through partnership arrangements – please see response to question 32. This will be necessary in order to avoid a multiplicity of Green Deal Providers operating in the neighbourhoods designated by the partners in an un-coordinated way and with no economies of scale.

Q52: Do you agree that it is desirable that energy suppliers should have to fulfil some or all of the (carbon) obligation by spending money promoting measures through those organisations who are able to provide the most cost effective delivery options?

Energy suppliers should perhaps have to fulfil some of their obligation by the most cost effective means.

It would be of concern if cost was to be the sole determinant in the delivery of all carbon saving ECO obligations – this could prove detrimental to smaller local businesses trying to establish themselves in the installations marketplace against large nationally based organisations for instance. It would also potentially deter businesses from providing training opportunities for local people if this was to result in additional costs. Furthermore, it might result in external wall insulation being installed at the cheapest cost without incorporating detailing that reflects the character of some older buildings.

The PAYS trials have also shown that a lot of 'hand holding' is required to get uptake from householders. It could prove counter-productive if cost pressures drive down the level of support and guidance to minimal levels.

Q53: Do you agree that we should seek a firm commitment from the ECO suppliers that they will use brokerage for a defined and significant percentage (e.g. 50%) of their obligation? If so, what level do you consider this should be?

It would be reasonable for some of the ECO supplier's obligations to be delivered via the brokerage mechanism for the reasons stated in the consultation paper. It is difficult to say what the precise limit should be as we don't know how energy suppliers are going to behave. It is therefore suggested that ECO suppliers should commit to using the brokerage for say 25% of their obligation for an initial two year period. At the end of this period, the percentage could be reviewed in the light of the behaviours demonstrated.

Q54: Do you have any further comments on the detailed design of a brokerage, or any alternative mechanism that ensures the most cost effective delivery?

As stated previously in the answers to questions 32 and 51, co-ordinated area-based ECO delivery partnerships in designated neighbourhoods will provide economies of scale that cannot be achieved through ad hoc delivery by a multiplicity of Green Deal Providers. Unless the brokerage mechanism operates in a way that enables such neighbourhoods to be 'ring fenced', delivery will not be cost effective.

Statistics:Posted by ALEO Admin — Wed Jan 18, 2012 10:53 am

Green Deal Consultation - September 2012 • Re: Chapter 2: Measures, products and systems

2012-01-13T14:05:50

East Midlands CAN discussed chapter 5 at their forum meeting in Leicester on 9 December 2011. The results are given below and will form the basis of CAN's response to chapter 5 the Green Deal consultation. If you have anything else you'd like us to consider in our response to DECC please post it below or under the relevant chapter headings, alternative you can also email me your comments directly at rob.leeson@can.uk.net. Please note DECC's dealine for responses is 18 January 2011. Thank you for your help on this.

Q8:Which measures should be added to the list of qualifying measures in Annex A for non-domestic properties, and what evidence is there that these measures improve the energy performance of buildings?
Not relevant to CAN, as non-domestic properties, although voltage optimisation was suggested.

Q9:Will the existing Appendix Q process, which will allow new measures to be added to the Green Deal assessment tools, and to the list of qualifying improvements, support innovation in the market and how could the process be improved? In particular, what support could SMEs benefit from?
Not relevant to CAN

Q10:What innovative ways can the government use to encourage the uptake of a package of measures and could our existing proposals support this?
Publication of EPC database.
Incentivisation is vital.
Independent marketing by central government, so not seen as linked to companies.
Impartial advice is necessary.

Q11:Please provide views on the potential inclusion of hard-to-treat cavities (and potentially other measures of a similar type), and proposals for how properties might be accommodated in the ECO without excessive complication or perverse consequences.
Should be included to encourage utilities to innovate.
Quick assessment might not pick up on issues with hard-to-treat cavities.

Q12:We propose that the ECO Carbon Saving obligation should be achieved primarily by promoting and installing solid wall insulation. Should any other measures be supported, and how would these be defined?
Flat roofs, attic conversions, dormer properties.
Park homes – could sub-meter and pay back through council tax?

Q13:For the ECO Carbon Saving obligation, we propose that any other carbon saving measures should only be eligible when delivered as part of a package with solid wall insulation. Do you have any suggestions for the criteria by which eligibility within packages should be restricted, explaining why you think any such restrictions should be included?
No other restrictions

Q14:We propose that any measure should be allowed under the Affordable Warmth obligation, provided it allows eligible households to heat homes more affordably. If you disagree, or feel there are risks to this approach, please explain and set out any restrictions you believe should be put in place.
Prioritised list of measures, starting with insulation.
Priority/vulnerable customers should still get free insulation and not have to pay for it under ECO/Green Deal.
Modelling is not necessarily what happens in reality.

Q15:Do you have any suggestions for whether and how we should score, boiler repairs under the Affordable Warmth obligation, such that where repairs are more cost-effective than replacement systems, without significant impact on efficiency, these can be promoted?
Repair is better than replace but need to take in to account cost of repair and efficiency of boiler compared to new one.

Q16:We are proposing that any heating measures should be allowed under the Affordable Warmth obligation, including for households off the gas grid, and extra incentives should not be put in place for air or ground source heat pumps. Do you have any evidence to bring to bear on the performance of heat pumps to improve the ability of vulnerable households to heat their homes affordably?
No comment

Q17:To what extent can existing product lists, such as the list of Microgeneration Certification Scheme compliant products be used as the starting point for the Green Deal Products list?

Q18:Do you agree that allowing enhanced product performance to be recognised in the Green Deal financing mechanism is useful? Do you have any specific views on how this approach could be implemented?

Statistics:Posted by ALEO Admin — Fri Jan 13, 2012 2:05 pm

Green Deal Consultation - September 2012 • Re: Chapter 6: Consent, disclosure and acknowledgement

2012-01-10T13:46:14

Consent. The Green Deal concept is straightforward in the context of freehold, owner occupied property. It becomes more complicated in rented property, because the consent of both the owner of the building and the energy bill payer are required; and more complicated still in multi occupied buildings where there may be a mixture of tenants and leaseholders all of whose consent is required to carry out works to communal areas (such as external cladding of a block of flats). The Government has not come up with a solution of how to deal with situations where not all residents may consent to works and has called for evidence and suggestions of possible solutions. Without a satisfactory solution it could prove hard to implement schemes in multi occupancy buildings where one or more residents oppose the scheme, on the other hand, there are substantial legal obstacles to imposing, in effect, a credit agreement upon someone without their consent,

Statistics:Posted by sandra — Tue Jan 10, 2012 1:46 pm

Green Deal Consultation - September 2012 • Re: Chapter 5: Delivering equitable support and tackling...

2012-01-10T12:06:54

Question 33 - Do you have evidence or views to put forward on whether the benefits of ECO as a whole, or of the carbon saving obligation within it, are or are not as likely to be distributed equitable to all income groups? If so, do you think regulatory intervention is necessary to ensure a more equitable pattern of delivery and, in particular, do you have and comments on the likely effectiveness of setting a “distributional safeguard” as a means of achieving this?

Historically unless the system is a grant, or universal subsidy (such as CERT operates), the benefits of the obligations have predominantly gone to the highest bidders and hence are unlikely to reach the most needy areas unless there is some sort of regulation. Therefore we feel there is a need for some sort of Distributional Safeguard. There is a moral obligation to ensure this, as the ECO will be paid for out of all bills but this will have a disproportionate impact on those on low incomes.

Essentially 75% of the £1.3 billion will be used to subsidise the golden rule in hard to treat homes and the cost of that spread across all users. We have significant concerns that those that will in reality benefit will not only be the able to pay but actually the fuel rich (those that spend more and hence the higher cost insulation measures make more sense at that those thresholds). In essence if your gas bills are £600 [but should be closer to £800 but you cut back as you cannot afford it] there is little room to make significant savings, where as if your gas bill is £1,000 there is significantly more room for manoeuvrability. A typical solid wall insulation benefit of £300 per annum is more easily realised.

We propose that under the Carbon Saving element each ECA, (Energy Conservation Authority as defined by the HECA legislation 1995) be able to determine areas of priority based on local need that addresses those areas of greatest need. This would return an area based approach to green deal and ensure a more equitable distribution and fulfil the distributional safeguard. This would also provide a direct link between GD providers and the community through the ECA. It would also provide a means for ECA to monitor this annually through HECA returns and advise and feedback on the rollout of GD. Each ECA should be able to define vulnerable areas based on local priorities (although we suggest this should be informed by guidance from DECC).

Statistics:Posted by David — Tue Jan 10, 2012 12:06 pm

Green Deal Consultation - September 2012 • Re: Chapter 5: Delivering equitable support and tackling...

2012-01-10T11:37:19

Hi All,

P59, item number 50 addresses the point about householders not having to pay for a Green Deal Assessment if the best solution for these customers does not involve Green Deal Finance. Anyone qualifying for measures under the Affordable Warmth obligation should be provided with this information as early as possible in the Green Deal Process.

Unlikely that anyone eligible for Affordable Warmth obligation would ever apply for a Green Deal in any case. Also DECC know the details of everyone who would be eligible for Affordable Warmth obligation, so why not just contact them directly?

John.

Statistics:Posted by JohnMathers — Tue Jan 10, 2012 11:37 am

Green Deal Consultation - September 2012 • Re: Chapter 5: Delivering equitable support and tackling...

2012-01-10T11:02:30

Question 32 - We propose seeking a voluntary agreement with ECO obligated companies as to how they commit to following up referrals. Do you have any suggestions as to what this commitment should consist of?

The Green Deal legislation provides a market opportunity for providers to offer loans against energy bills. The ECO is an obligation on utilities and the artificial linking of the two is a concern. The obligation gives the utilities the market advantage as potential GD providers to control ECO payments and exclude certain players and therefore this needs to regulated not left to a voluntary agreement.

The proposals and DECC representative have alluded to a brokerage system and we understand this is for 50% of the obligation. The conflict is still there. We know under CESP many utilities offer differential rates if you just sell the carbon saving or you use their contractors. In other words whilst its an obligation and they have to procure on the open market its undistorted, when they procure from themselves the market can be distorted. We propose the whole amount £1.3 billion be passed to a third party for complete transparency. However this changes the obligation [ECO] from a delivery requirement to a payment, charge, levy or tax.

There is as yet no requirement for GD assessors to ensure a home is not eligible for ECO and we see this as major flaw which could lead to unintended consequences therefore we propose that GD assessors have a responsibility to ensure households are vetted for ECO eligibility.

Statistics:Posted by David — Tue Jan 10, 2012 11:02 am

Green Deal Consultation - September 2012 • Re: Chapter 5: Delivering equitable support and tackling...

2012-01-10T10:42:13

Question 31 - Do you agree that eligibility for Affordable Warmth measures should be restricted to households who are in receipt of the benefits and tax credits similar to the CERT Super Priority Group and who are in private housing tenures?

The proposed amount is too small, needs to be a larger amount, £325m is not enough to cover fuel poor and this will replace Warmfront so there will be no other programmes to deal with the fuel poor.

There are lots of poor people who can’t afford to heat or improve their homes that are not on benefits. It needs to be means tested but not benefit tested. SPG is not flexible enough – Warmfront does not help enough people as it is and the criteria are too restrictive (finding eligible clients is difficult as many have already had work done).

We mostly agree that the affordable warmth element should only be for private tenure, due to the higher standards of social housing. But we have concerns about Social Housing – how are the tenants going to be assessed or helped out of fuel poverty if no Affordable Warmth element?

In the private rented sector similar people – similar consumption may live in the property but this is not likely all the time and we have concerns about who takes over payment in future years and their ability to actually save.

This whole approach misses the learning of area based approaches. Complete area based approach for both benefit recipients and able to pay owners who may be on a slightly higher income but cannot afford works will lead to higher take up and neighbourhood improvements – stop “pepper potting” as the individual benefits are easily lost to the area.

Statistics:Posted by David — Tue Jan 10, 2012 10:42 am