Community Energy Saving Programme
ACE have submitted a written response to the DECC Community Energy Saving Programme consultation.
In summary, ACE believes that the design of CESP should be vastly simplified whilst ensuring that the programme is as ambitious as practicable. The proposed CESP contains an ambitious and complex list of aims: cutting CO2, piloting community partnerships, delivering ‘whole house’ refurbishment, addressing hard to treat homes and targeting those most in need. At the top of this list of objectives is to learn from the experience of the pilot programme to inform future strategies and implementation. ACE believes that in order to fulfil this headline objective the programme needs to be simplified and made more prescriptive to ensure that the types of projects that Government intends to learn from are actually delivered.
ACE is deeply concerned that, as a pilot designed to inform future strategy and implementation, the proposed CESP contains only very limited reporting or review requirements. The primary aim of CESP is learning rather than delivery (as indicated by the small £350m outline budget) but this opportunity to learn will be lost if more penetrating and representative reporting is not established. ACE also calls for a reporting framework that requires partners to report on both the technical and ‘softer’ elements of the programme. Energy Performance Certificates (EPCs) should be prepared for each home treated under CESP before and after the package of measures is installed. ACE also has concerns that without stronger reporting requirements double counting of carbon reductions between CESP and CERT will occur.
ACE believes that uplifts to incentivise essential elements of CESP (like multiple measures and community penetration) should be replaced with clearer requirements for these elements to be delivered. The complicated range of uplifts for community penetration and numbers of measures installed in each house serve to produce enormous uncertainty and create far too many opportunities for unintended consequences. This will impact both on the success of the programme as a learning experience and on the communities involved. Uplifts in the programme also serve to reduce the amount of carbon saved.
ACE believes that, although the natural incentives are strong, local partnership should be more firmly written into the delivery of CESP. Only by instituting a requirement for local partnership can we be sure from the outset that it will happen. A requirement for partnership creates an environment in which the partners can negotiate the projects and most importantly allows the programme to capture the experiences of more than one perspective to inform future work.
ACE believes that in order to ensure the delivery and subsequent learning from projects targeting hard to treat homes, rural areas and mixed tenancy, each energy company should be required to include at least one project that addresses each of these objectives in their portfolio of projects. If a full range of projects treating different construction types, tenancies and geographies are not represented in the projects delivered, the lessons will not be captured and CESP will have missed an essential opportunity. The current targeting approach and list of eligible LSOAs under represents rural and hard to treat homes so refinement, though the direct targeting of projects is essential to delivery.
ACE calls for the Government to be realistic about the number and types of homes that will be reached by CESP. In the illustrative outline, it is expected that 100 projects will be delivered, reaching 90,000 homes. Given that the average number of households in an eligible LSOA is 650 (CSE, 2009), if all 100 projects achieved 100% penetration of these communities the number of households reached would only be 65,000. Within the eligible LSOAs identified, much lower than average numbers of solid wall and off gas properties are included. Given that these properties will probably be more expensive to address it is improbable that projects that focus on these homes will be many. It is important that the expectations within communities being raised by CESP are managed and that the ability of the programme to deliver is not overstated.
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