ECO2 Deemed Scores- Elmhursts Response

Elmhurst Energy has replied to the Ofgem Consultation on deemed scores. We thought it useful to our members and the wider industry to see our response to this important consultation.

Ofgem and DECC are looking to implement a ‘deemed scores’ method for calculating CO2 and £ savings for ECO measures starting in April 2017.  It is worth pointing out, that DECC are also consulting on the wider implications of the ECO policy and therefore clarify things like fuel poverty indicators and where the targets for the policy need to go – and how this will work. This is something Elmhurst will be keeping a close eye on and responding to, as this also includes the proposed removal of RdSAP and EPCs and their use within any reformed new policy.

Elmhurst has commented on the use of deemed scores in many news articles over the past few months. If you wish to see Elmhurst’s full response click here Otherwise we have summarised our responses to each question below. We believe that they are a reflection of our thoughts on this methodology:

Q1. Do you agree with our selection of the key variables to use as the main inputs for calculating the deemed scores?

Strongly Disagree: Elmhurst object to the key variables on the following grounds;

  • The policy is no longer about families and fuel poverty – but a tick box approach with little or no accuracy.
  • There is no measurement involved – so success is only measured in volume of installs
  • It is ignoring the National Audit Office report on ECO and Green Deal published in April 2016
  • Families will be the biggest losers – after all what is the ECO policy about?


Q2 - Do you agree with the method used in developing typical property archetypes in order to remove the need for measuring property dimensions?

Strongly Disagree:

  • This is fundamentally flawed
  • Number of bedrooms is open to fraud
  • To suggest all flats can be averaged as top floor flats is wildly incorrect

Q3 - Do you agree with the approach to accounting for all primary heating sources present in the housing stock?

Strongly Disagree:

  • No this is the most important part of any energy efficiency improvement
  • Even the attached papers claim the CO2 and £ savings have no relationship to the actual savings that families will obtain


Q4 - Do you agree that we have appropriately accounted for heating systems present in the housing stock either as an input for the deemed scores or in Table 1?

Strongly Disagree:

  • It is completely illogical to suggest that a heat pump (300% efficient) should claim the same carbon and cost as mains gas boiler with 83% efficiency.
  • It is illogical that biomass which is great for CO2 (low carbon source) is averaged into solid fuel
  • As the document states ‘community heating’ can adequately be dealt with in RdSAP/SAP – why shouldn’t all the systems be allowed to use RdSAP/SAP. This whole area seems odd.

Q5 - Do you agree that the deemed scores include all measure types?

Strongly Disagree:

  • The document claims not all measures are catered for
    • if RdSAP/SAP can be used, then they would be options for all households
  • Can’t see differentiation on ‘virgin loft’ and ‘top up loft’ – if these have been grouped together then same credit for top up as for a when a property has zero insulation in the first place is wildly inaccurate.

Q6 - Do you agree with our proposals for differentiating within measure types?

Strongly Disagree:

  • Only 2 are broken down (solid wall and cavity)
    • Solid wall is going along the right lines
    • But a cavity wall in 1940s is the same carbon as cavity fill in a 2010 home makes this wildly inaccurate
  • There is no product differentiation, therefore there will be no innovation and it will be a drive to the bottom for standards.
  • Families will be the biggest losers!


Q7. Are there any measure types where you think that further differentiation is warranted? If so, please clarify which measure type could benefit from further differentiation and suggest an approach.

  • All of them require further differentiation
  • More work definitely required on Cavity, Solid and Boilers as these were the big three in terms of previous installs under ECO

Q8. Are there any areas where you could benefit from further guidance in using deemed scores?

  • As per all other answers

Q9 - Do you agree with the deemed scores produced? If not please clarify which particular score(s) that you believe do not accurately reflect the savings for a measure.

Strongly Disagree:

  • Deemed scores are ‘averages of averages of averages’.
  • Real RdSAP data should have been used not EHS data.
  • Industry should have the ability to use RdSAP or SAP as an alternative to deemed scores.


Q10. Do you agree that it would be useful to also provide the deemed scores as lifetime savings (i.e. after applying all relevant multiplication factors), to make the relative value of each measure easier to identify?

Strongly Agree

  • Yes all values should be clear in the spreadsheets – for full transparency
  • BUT the values currently indicated are extremely misleading in our opinion

Q11 - Do you agree with the proposal to use ‘percentage of property treated’ to identify whether 100% of a score should be claimed?

Strongly Disagree:

  • If Deemed scores are ‘averages of averages of averages’ then this is another ‘average’ again, it is wildly inaccurate
  • Open to misinterpretation and fraud

Q12 - Do you agree with our proposed approach for applying for a new score from April 2017? If not please explain your reasoning, which specific parts of the process you do not agree with and inform us of your preferred approach.

Strongly Disagree:

  • Should use RdSAP/SAP as an alternative
    • Build upon current existing and proven infrastructure
  • It is ok for a brand new measure – which is not catered for in RdSAP or SAP

Q13 - Do you agree that we should determine whether or not to accept an application, and specifically what is a ‘significant’ improvement in score, on a case-by-case basis? If not, please provide reasoning and an alternate approach.

Neither agree / Nor disagree:

Q14 - Do you agree that a DEA is not required to check inputs used when identifying a deemed score for a measure?

Strongly Disagree:

  • An RdSAP EPC should be produced at the end
    • Not to calculate the CO2 and £ for ECO scoring system – leave this with deemed scoring
  • Gives 3rd Party Oversight
  • Tells occupants (families) the truth
    • How much warmer is my home
    • How much carbon has it saved
    • Shows families other measures they can apply to make home warmer and cheaper to run
  • Make homeowners/tenants the most important part of the policy – not completely ignored
  • Have a measure of Fuel Poverty and Energy Efficiency
    • Only this week the Annual Fuel Poverty 2016 reports highlights that there are more households in Fuel Poverty (2.38m). That those most likely are those in E, F and G rated homes – but deemed scores and the new ECO do not want to measure using this national agreed rating.
  • Take heed of NAO report on previous failings

The Consultation and associated documents can be found in link below, and we encourage our members to respond with their own thoughts, but hopefully you find some of the above useful. The deadline is this Friday, July 8th.

We want to make clear that Elmhurst do not want to stop energy efficient installations from occurring; we just want to make sure that the right people and the right properties get the correct help; we fervently believe that DEAs using the RdSAP and EPCs has to be included in the policy, to ensure that the families affected are put back at the heart of the policy. We believe the DECC consultation on the overall ECO Policy will also address these issues, and we will comment more when we investigate the detail of this.



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