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DECC Consultation: Extending the Carbon Emissions Reduction Target

ACE have submitted a written response to the Department of Energy and Climate Change consultation: “Consultation on Extending the Carbon Emissions Reduction Target”

In summary the extension of CERT presents an opportunity to sustainably increase the delivery of cavity wall and loft insulation, whilst developing the solid wall industry to a point where it is in a position to meet Government’s ambitions as set out in the Household Energy Management Strategy for the period post-2012. Meeting these twin objectives requires the introduction of a professionally installed insulation minimum at 65-70% of the overall CERT obligation, and a solid wall insulation minimum at 5% of the CERT obligation. The long term vision of Government is to increasingly focus on those homes in need of solid wall insulation. The solid wall industry therefore needs to be developed so that as lofts and cavities are filled, there is a smooth transition from cavity wall and loft insulation to the delivery of solid wall insulation.

The sustainable increase in cavity wall and loft insulation could be threatened however by the nature of the measures delivered during the extension period. ACE has concerns that if the space left by the removal of CFLs is filled by other dubious measures [and we have serious concerns about delivery of low flow shower heads under CERT] instead of through increasing the delivery of proven energy saving measures, then there is a real danger that insulation will not increase at the required rates.

Similarly, a failure to remove micro-generation measures from CERT for all but the super- priority group will seriously threaten the integrity of the programme by creating a real potential for installations to receive a carbon score under CERT that would have been installed under FIT anyway. If this happens, those installations will have saved no additional carbon and will reduce the number of other effective measures that are installed. Government must ensure that this does not happen.

Overall, with the notable exception of CFL delivery, CERT has proved a successful programme for reducing carbon emissions, providing a net benefit to the UK economy. This does not disguise the fact that CERT is a regressive policy to those in fuel poverty; the nature of CERT means that the fuel poor will always receive disproportionately few measures from the programme, whilst the costs are felt by all households. Government must understand that the small changes in targeting, whilst welcome, will not overcome the fundamental problem – that programmes funded through levies on energy bills will always worsen fuel poverty unless the benefits are targeted exclusively at the fuel poor. Instead, Government must acknowledge that any further extension to an overall positive scheme such as CERT must be complemented by a commensurate increase in spending on publicly funded fuel poverty programmes (currently Warm Front).

Click here for the full response.

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