Chapter 9: Delivering Green Deal and ECO

[ALEO Admin]

Questions from "Chapter 9: Delivering Green Deal and ECO" of the Green Deal Consultation are given below. If you have any comments on these questions please post them here.

More information including the full consultation documentation is available at:
http://www.decc.gov.uk/en/content/cms/c ... _deal.aspx.

51. 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?

52. 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?

53. 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?

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

[ALEO Admin]

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.