Ofgem Consultation on the Community Energy Saviing Programme Generator and Supplier Guidance
ACE have submitted a written response to the Ofgem consultation on CESP generator and supplier guidance.
ACE response to the consultation:
- From the monitoring and reporting outline set out in this consultation document it is clear to ACE that Ofgem have lost sight of the main aim of the Community Energy Saving Programme, which is to learn from the pilot of this new delivery method. The objectives of the scheme, as set out in the Department for Energy and Climate Change (DECC) consultation earlier this year – to pilot community partnerships, deliver ‘whole house’ refurbishment, address hard to treat homes (HTTH) and target those most in need – are not the same as those of CERT – to simply delivery carbon savings. ACE is seriously concerned therefore, that Ofgem are proposing to monitor energy suppliers’ and generators’ activity under CESP (a pilot and lesson learning programme) based on the same principles as CERT (a delivery programme). The processes used for demonstrating compliance with CERT are not fit for the purpose of CESP monitoring without serious additions.
- Consultees responding to the DECC consultation on the design of CESP in May so clearly aired their concern that reporting and evaluation of the programme had been overlooked that DECC, in its reply in June, clearly stated that “CESP will therefore be subject to comprehensive evaluation both during and after the programme”. Whilst Ofgem’s outline of how compliance with the complex technical requirements under CESP will be checked seems robust, what is lacking is an outline of how the all important lessons, particularly on partnership working, acceptability of HTT measures and reaching those most in need, will be captured. If these lessons are not captured, CESP will have served only as a very expensive extension to CERT.
- ACE is also concerned that there is no mention in the consultation document of how the industry regulator will encourage the Government’s expectation “that obligated companies will seriously consider targeting action at a variety of different areas around the country, including rural areas” . Unless suppliers and generators are at the very least encouraged and at best required to undertake some CESP activity in rural areas, it is very unlikely that any activity will occur in these areas and no experience will be gained or lessons learned from one important element of this pilot programme.
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