Oliver Myers
Chair of UK HECA
London Borough of Camden
Bidborough House
20 Mabledon Place
London
WC1H 9BF
Tel: 0207 9746370
Email: [email protected]
SEP6 – Partnerships Branch
Zone 3/G16
Defra
Ashdown House
123 Victoria Street
London SW1P 6DE
23 October 2006
Dear Sirs,
RE: EEC3: Initial Consultation Response
Please find enclosed the UK Home Energy Conservation Association’s (HECA) response to the
Energy Efficiency Commitment April 2008 to March 2011Initial Consultation.
We are happy for this response to be made publicly available and look forward to further discussion
on the development of the EEC programme.
Yours sincerely,
Chair of UK HECA
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The Energy Efficiency Commitment April 2008 to March 2011: Initial Consultation
Response from UK Home Energy Conservation Association (UK HECA)
1.
Introduction and general comments
1.1
The UK Home Energy Conservation Association (UK HECA) welcomes the
opportunity to comment on the initial consultation paper on the Energy Efficiency
Commitment. UK HECA, formerly known as the National HECA Forum, supports
local government officers in their efforts to improve domestic energy efficiency to
combat climate change and alleviate fuel poverty. We also act as a channel for
Government and other relevant agencies to consult with local government officers on
energy policy and programmes.
1.2
This response is supported by all UK HECA Regional Chairs and there is a
consensus amongst the group on each issue except ‘flexibility and innovation’, for
which we have included two separate views. Some UK HECA regions will also be
submitting their own response to this consultation to highlight issues of particular
regional significance.
1.3
We welcome Government’s commitment to increase the size of EEC from 20082011. However, we believe the Government is not doing enough to strategically align
or adequately resource its various energy efficiency programmes to meet its
overarching climate change and fuel poverty targets; namely the eradication of fuel
poverty amongst vulnerable groups by 2010 and all groups by 2018, and a 60%
reduction in carbon emissions by 2050. This creates a regrettable conflict within EEC
in the level of its contribution towards climate change and fuel poverty targets. Whilst
we would ideally prefer EEC to focus on maximising opportunities for carbon
reduction, we believe that the alleviation of fuel poverty should remain a key objective
of EEC owing to the rises in fuel prices and the Government’s reluctance to put
sufficient resources into other programmes to achieve its fuel poverty targets.
Furthermore, we believe there should be some relaxation on the cost-effectiveness of
carbon saved for measures aimed at the priority group, particularly for the fuel poor in
hard to treat housing.
1.4
We would welcome as early a start as possible for EEC3 and are pleased that
Government is working with all stakeholders to try and make this happen. We believe
that greater efforts must be made to ensure continuity of the EEC scheme both within
and across each phase in future. Further to the damaging impact on the energy
efficiency industry, many local authorities have suffered from the stop start nature of
supplier programmes and the frequent changes in the amount they offer for various
measures, in both delivery of programmes to their own stock and promotion of local
and regional able to pay schemes. This in turn impacts on the consumer experience
and the credibility of all energy efficiency schemes suffers.
2.
Carbon emissions reduction obligation
Inclusion of larger scale measures for increasing the amount of electricity generated, or heat
produced, using low-emission sources or technologies.
2.1
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We would welcome use of EEC to encourage CHP, particularly in the high density
urban setting where there is limited scope for traditional energy efficiency measures
such as wall and loft insulation, and where there are higher percentages of low
income and vulnerable groups. We also note that CHP has been omitted from the
‘First Draft Illustrative Measures for the EEC 2008-11” and trust that this is by error
and not design.
Inclusion of microgeneration measures
2.2
UK HECA believes that the key priority for EEC should continue to be the installation
of the most cost-effective insulation and heating improvements. However, we would
welcome the inclusion of microgeneration for members of the priority group in hard to
treat housing such as properties with solid walls and/or those not connected to the
gas network. This could be assisted through linkages with other Government
programmes such as the Low Carbon Buildings Progamme. This will also help to
raise householders’ awareness of these technologies and stimulate the market for
them.
Inclusion of measures for reducing the consumption of supplied energy
2.3
Whilst we recognise the important role that behavioural measures such as smart
metering might play in reducing climate change emissions in future, we have
reservations about its inclusion in EEC3 at this stage owing to uncertainty over the
extent of savings, the difficulty in quantifying these and the amount of traditional
physical measures that are still required in the housing stock.
2.4
If, in time, these meters are shown to achieve substantial carbon savings in
behavioural changes, Government could alternatively look to phase these meters in
under appropriate legislation/regulation.
How could EEC be developed to provide more flexibility for innovation
2.5
There are differing views on this issue amongst UK HECA regions. Some believe that
EEC is not the best mechanism for piloting innovative technologies, and that
innovation and flexibility could be more effectively achieved through R & D
programmes and grant aid and tax breaks for manufacturers. However, some regions
would welcome the opportunity to incorporate some innovation within EEC, but as
the primary objective should be to deliver maximum carbon savings as costeffectively as possible, that funding available for innovation should be restricted to no
more than 5% of total EEC money.
Use of lifetime carbon savings for the EEC3 target and scores
2.6
We would welcome the use of lifetime carbon savings as this will most closely align
the programme with its key objective of combating climate change. However, we
would want assurances that this will not have a detrimental impact on the priority
group.
3.
Transition to EEC3
Views on possible publication by the end of 2006 of scores to be attributed to individual
measures and the degree to which this is likely to result in an early start to EEC3
3.1
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It will be important to allow carry over of activity and savings from EEC2 to EEC3 if
activity is not to be substantially scaled down in the period running up to April 2008.
The stop start cycle has damaging effects on the energy efficiency industry, on
regional and local partnerships and also on consumer confidence when offers are
withdrawn or amended at short notice.
3.2
We agree that there may be advantages in early publication of the savings score to
be expected from individual measures as a means of enabling suppliers to make
early preparations for EEC 3. As cavity wall insulation is likely to remain the dominant
measure, much of their traditional EEC activity could then be ramped up.
3.3
We believe that the design of EEC3 should place as much importance on achieving
scheme continuity as it does on CO2 reduction. An obvious way to achieve this would
be to set extremely challenging targets for EEC3 with a guarantee for suppliers that
they will be able to carry over activity and savings to EEC4.
4.
Equity issues
4.1
We welcome the Government’s aim to make the priority group target less arbitrary
through an assessment of the costs, benefits and technical feasibility. However, we
believe the Government is not doing enough to adequately resource or strategically
align its various energy efficiency programmes to meet its overarching climate
change and fuel poverty targets; namely the eradication of fuel poverty amongst
vulnerable groups by 2010 and all groups by 2018, and a 60% reduction in carbon
emissions by 2050. This creates a conflict within EEC between the level of its
contribution towards climate change and fuel poverty targets.
4.2
Whilst we would ideally prefer EEC to focus on maximising opportunities for carbon
reduction, we believe that the alleviation of fuel poverty should remain a key objective
of EEC owing to rises in fuel prices and the Government’s reluctance to put sufficient
resources into other programmes to achieve its fuel poverty targets. Continuing to
prioritise priority group consumers is also justified because of the regressive nature
of the raising funds via consumers’ energy bills and by other market failings which
disadvantage low-income households. For example, switching rates among
pensioners and social classes D and E are lower, those in debt are barred from
switching and tariffs most commonly used by poorer consumers are higher. We
would additionally like the Government to consider an increase to benefits to
compensate fuel poor households for the EEC element of their fuel bill.
4.3
We believe the priority group target should be set at 50% of total EEC money spent.
This would be a reduction of the proportion currently spent on EEC which is 65%.
While we accept that there are limits on the level at which the priority group target
can be set in relation to the number of opportunities that remain to fill cavity walls, we
also note that fuel poor households are over-represented in ‘hard to treat’ housing.
We would therefore welcome a wider suite of improvement measures than simply the
cheapest and easiest carbon saving option since it has the potential to deliver
measures which offer genuine remedies to fuel poverty. Requiring the EEC
programme to examine whole house solutions would maximise the social and
environmental benefits which can be achieved.
4.4
We are not entirely satisfied with the use of benefits as a proxy for fuel poverty in the
targeting of the priority group and would urge Government to explore the use of a
SAP score instead, similar to the < SAP 35 that has been established for the likely
presence of a category 1 hazard from excess cold in Decent Homes. We doubt
whether such a low figure would be appropriate for EEC, as 52% of fuel poor
households live in dwellings with a SAP >30 (source: Detailed breakdowns of fuel
poverty in England in 2004 Version 1, April 2006, BRE on behalf of DTI/Defra).
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However, we would urge the Government to consider an appropriate SAP figure to
suit this scheme.
4.5
We strongly welcome the idea of the ‘total’ exemption option, particularly if this
exemption could be paid to regional and local authorities that are well placed to
prioritise and target improvements to priority group households in their areas.
4.6
The exclusion of benefit entitlement checks or fuel vouchers as possible EEC
measures is welcome. We do not believe that low-income energy consumers should
pay for work that is the responsibility of the DWP, nor should some consumers pay
twice, once as taxpayers and once as a gas/electricity user. We strongly believe that
the EEC contribution to the cost of physical improvements in low-income households
is essential and should not be diluted by services which can and should be paid for in
other ways.
5.
Opportunities for trading
5.1
While there may be some advantages to trading, we believe it may be too
complicated a mechanism for single homes to benefit from and also question
whether the priority target group will be seen as an attractive market in which to trade
carbon savings. We would however like to see the idea explored further.
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