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DECC

Amendments to the Carbon Emissions Reduction Target – ACE response

ACE have submitted a written response to the DECC consultation on the Amendments to the Carbon Emissions Reduction Target.

In summary, ACE are extremely concerned that the carbon scores attributed to the new ‘behavioural’ measures do not represent a realistic assessment of their actual carbon savings since they are not backed up by supporting evidence, and therefore threaten to undermine the CERT programme and reduce the carbon savings delivered by it. Exaggerating the carbon scores of individual measures increases their cost effectiveness and could result in them becoming the dominant measure under CERT. Generating carbon scores in this way is inconsistent with the ‘evidence based policy’ approach preferred by Government.

ACE does not consider that there is sufficient evidence for Real-time display devices (RTDs) being attributed an annual carbon saving equivalent to saving 3.5% of electricity demand. The trials mentioned in the consultation document are ‘opt-in’ trials where the householder has to regularly report on their savings. There are insufficient requirements to ensure that the householder both wants and uses an RTD to prescribe a 3.5% saving. It is likely that many will end up in drawers not being used.

ACE is especially puzzled at RTDs accruing this annual carbon saving for fifteen consecutive years. No evidence for such a figure is given in the consultation document. Since there is no requirement for the energy supplier to check that an RTD is being used each year, it seems highly unlikely that a device will be saving electricity for that length of time. This is especially true given that: the consultation document admits that many won’t replace batteries once a device fails (often within one year); the average householder lives in their house for less than ten years and is unlikely to take it with them when they move; the Government’s ambition to have smart meters in every home by 2020 would make them obsolete before 15 years; there is no requirement for suppliers to replace an RTD if it breaks before the 15 year period is over.

Similarly, ACE does not believe that there is any empirical evidence to justify the provision of a single visit to a property and a follow up report being attributed savings of 2% gas and 1% electricity over 7.5 consecutive years. We have concerns about both the form of this advice and the number of times it can be given to an individual household.

The scores for both of these behavioural measures appear to be ‘notional’ (or rather ‘fantastical’), and grossly exaggerated. ACE warns Government that this is a dangerous approach that risks undermining the more considered methodology used to assign carbon savings for the original CERT measures, and certainly runs counter to the preferred ‘evidence based policy’ approach.

 

Click here for the full response

The issue is also addressed in the latest Warren Report by ACE Director Andrew Warren: ACE Warren Report (2009-03) – If it works dont fix it unless its a successful energy saving programme

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