ECO: Help to Heat Consultation closes in 7 days
As previously advised DECC (now BEIS) have issued a 60 page consultation for "ECO: Help to Heat", the replacement for ECO 2, which will run between April 2018 and March 2022, with 2017 being considered a transition year. As our member's will expect we are currently drafting our response to the consultation which we will publish to Members as soon as it is complete.
The closing date for the consultation response is Wednesday 17th August and we urge all energy assessors to consider the proposal and give feedback.
The essence of our response will focus on these 4 points;
1. The proposal does not focus on fuel poor families.
Throughout the proposal reference is made to the fuel poor and we are convinced that the move to deemed scores, which does not consider the current condition of the property, will miss this critical group. Elmhurst believes that the reduced pot of money will be spent on homes that have been considered "too good for improvement" under previous initiatives, but will be easy to identify and access.
Elmhurst believe that installers should be incentivised to go looking for those homes that are in most need of improvement and will be requesting that a 25% uplift be applied to the deemed score; when the improvement is being made to our least energy efficient homes, i.e. those rated E, F or G.
2. The proposal will reduce the amount of money spent on energy efficiency .
The proposal sees a significant reduction in spend and Elmhurst consider describing any aspect of the change as an "increase" to be misleading
3. Deemed Scores are a retrograde step and will result in bad decisions.
Energy Performance Certificates are a measurement tool and the adoption of "deemed scores", which are an estimate based upon an ‘average of an average’, will reduce accuracy. Reduced accuracy will lead to bad decisions both at a home and national level.
4. The proposal does not create meaningful success criteria.
The current proposal is focused on how much we can spend. So not to make the mistake of previous Government initiatives, the Government need to require a measurement process is in place with meaningful targets against which success can be gauged. Elmhurst will be requesting that post install EPCs be introduced to ensure that improvements can be measured.
It has been said that "you don't need an RdSAP assessment to prove a house needs insulation" but what is an undeniable truth, is that when spending public money you need an RdSAP assessment to identify which home is in most need, what solution is most effective. If you can’t measure it, you can't manage it!
The consultation period is for seven weeks and expires on 17 August 2016.
Elmhurst will be responding to the consulation and will publish our full submission for our Members to read as soon as it is available. In the mean time, to read the consultation document please click here.