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ACE’s initial response to the Clean Growth Strategy

Dr Joanne Wade, CEO of the Association for the Conservation of Energy (ACE) welcomes the aims, targets and aspirations outlined within the Clean Growth Strategy. There is recognition of the value of energy efficiency at very core of the strategy and a commitment to further developing policies, and we see the strategy as a clear step in the right direction.

The scale of the opportunity of energy efficiency in buildings is huge. ACE research shows that the net present value of energy efficiency to the UK is at least £45 billion in energy efficiency savings[1]. The UK’s building stock is in dire need of urgent action. Therefore, we welcome the government’s intervention to stimulate energy efficiency markets in both the domestic and non-domestic sectors – to deliver the scale and pace of change that is required to meet current and future carbon budgets. However, there is a lot of work still to be done to drive energy efficiency in the UK and to develop a low carbon economy that works for everyone.

We welcome the government’s proposals surrounding the energy performance of domestic buildings, especially the proposal to further consult on the Minimum Energy Efficiency Standards (MEES) regulations, an enhanced trajectory for the regulations – taking homes in the private rented sector to band C by 2030 – and a commitment to looking at replicating the target in the social housing sector.

We are also pleased that the Energy Company Obligation (ECO) will be extended to 2028, providing longer term certainty for the energy efficiency industry. While it is right that ECO will focus on eradicating fuel poverty, ACE questions whether the investment needed in this area needs to be higher.

The Government have demonstrated leadership in enacting a target to reduce carbon emissions from the public sector, however we are disappointed that the target is voluntary rather than mandatory. We welcome the call for evidence consultation to further develop policies and programmes.

The team at ACE are taking the time over the coming days to analyse the Clean Growth Strategy and supporting documents to identify where there are still gaps in the market, and will then begin to develop the evidence base that the government have called for, thus ensuring that the voice of the energy efficiency industry is heard.

 

[1] £26 billion for homes, and £20 billion for business, ACE & RAP (2016) Buildings and the 5th Carbon Budget.

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Cost of Energy Review: will it deliver lower bills?

Yesterday, BEIS announced details of its ‘Independent review to ensure energy is affordable for households and businesses’.  Here are my initial thoughts on whether or not it will deliver lowest cost, sustainable energy services for consumers.

First the ambition: the government defines this as ‘for the UK to have the lowest energy costs in Europe, for both households and businesses’.  Assuming that they mean energy service costs, rather than fuel costs, I have no problem with that as a starting point.  But, looking at the detail, I do have one or two concerns.

The review will be led by Prof. Dieter Helm and will look at how the cost of electricity can be kept as low as possible, as we meet our climate targets.  Which is my first concern: is electricity really the only form of energy that we should be concerned about?

No, it isn’t.  Electricity use accounted for only 17.5% of final energy use in 2016 (DUKES, 2017), whilst gas accounted for nearly 30% and petroleum products almost half of total use.  Of course, for this review we are interested in the cost to the consumer, rather than the amount used.  And electricity costs are dominant for industrial and commercial users.  But in homes, expenditure on gas and electricity account for roughly equal shares of the money spent.  And for our transport, virtually all our fuel expenditure is on petroleum products.  So, shouldn’t the review be looking at the costs to consumers of all energy services, not of any given fuel?

Perhaps those who defined the scope of the review believe that the future is all-electric.  Indeed, a report published last Thursday by Forum for the Future included the following quote from Prof. Helm:

‘Decarbonisation should eventually bring about the end of fossil fuels, but they face a much more immediate threat.  That threat is digitalisation. Everything digital is electric.  The future of energy is therefore electric too.’

And we have seen recent government announcements of future bans for fossil-fuelled vehicles, albeit 20 years hence.  So, perhaps we are heading towards an all-electric energy system.  But what about heat?  Will this become all-electric?  And, if so, how quickly?  National Grid’s Future Energy Scenarios 2017 offers four future scenarios, and in only one of these (admittedly, the one in which we meet our climate aims) does gas use in homes decrease dramatically.  Even in this scenario, the replacement of gas takes more than 30 years. And, surely, the next 30 years of consumers’ energy bills is something that we should be thinking about.

Which brings us to my second concern: the review ‘will consider the whole electricity supply chain – generation, transmission, distribution and supply’.  What about demand?  As we all know, one of the most cost-effective ways to reduce consumers’ energy costs is to reduce the amount of energy they have to buy.  Indeed, in the National Grid scenario, one of the main drivers that reduces gas demand is the fact that consumers ‘live in housing stock that is good at retaining heat’.

The terms of reference do give some hope.  They state that the review will consider ‘the key factors affecting energy bills’, and energy efficiency is included in the list.  The question is whether demand reduction and response – particularly for heat and transport – will be given sufficient weight, given the clear emphasis on the electricity supply system in the minds of those who have shaped the review.

If the review does not fully consider the costs and benefits of energy demand reduction, it will not deliver on the government’s aim of the lowest bills for consumers.

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Mind the Gap

Higher energy efficiency makes mortgage repayments more affordable, because less money spent on fuel means more money available for other bills. This is the core message that inspired the LENDERS project to explore how the energy performance of a home could be included in calculations of mortgage affordability.

The UK has the largest mortgage market in the world, with £234bn lent in 2016. At today’s launch of the project’s final report, BEIS Minister Claire Perry urged the mortgage industry to maintain the UK’s leading reputation for financial innovation and grasp the opportunity that improved home energy performance offers. She pointed out that higher energy efficiency improves and protects the collateral against which mortgage providers are lending, and improves home-owners’ ability to repay their debt.

The project has developed a tool that estimates the energy costs of a given property more accurately than the methods currently used by the mortgage industry. The tool can be used to show home buyers how the energy efficiency of their chosen home will affect their monthly fuel bills, and it could also be used in full mortgage affordability calculations, potentially affecting the maximum amount people can borrow – increasing this for more energy efficient properties and decreasing it for those with worse energy performance.

The ability to borrow additional money on a more efficient property will only affect directly the minority of borrowers who actually borrow close to their maximum mortgage amount. But the bigger prize is the potential effect on homebuyer perceptions: the option to borrow more on a given property could increase its attractiveness to buyers, whether or not they actually take up the larger mortgage amount; this in turn could lead to faster sales of more efficient properties and eventually to higher prices.

The Minister is clearly looking to industry to play a leading role in building demand for energy efficiency investment. And – to an extent – industry is willing to respond, as evidenced by the active involvement of mortgage lenders in the project.

However, the report acknowledges that making changes to affordability calculations is a significant process change and could take the industry some time, although promotion of the existing stand-alone tool by lenders and estate agents could begin now. The key question is: will either of these things happen?

Is the potential for additional mortgage lending to those who currently take up the maximum loan available to them a big enough financial incentive for lenders? Probably not.

Is the longer-term increase in lending on higher value energy efficient homes (together with a possible decrease in lending on less valuable inefficient properties) any incentive at all?

And is the ‘improvement in, and protection of, collateral’ that the Minister identified a clear enough motivator for lenders to invest time and money in promoting this new information to home buyers and in changing their systems?

If the answer to any or all of these questions is ‘no’, then there may well be a large gap between government’s expectations of an industry response and what actually happens, which would be a real opportunity missed. The questions then are: how do we close this gap? And whose job is it to do this?

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Energy Efficient Buildings,Non-domestic building,Public Buildings

Energy efficiency policy for workplaces: quick wins for the next Government?

We all know that there is no single ‘magic policy bullet’ that will support the growth of a self-sustaining market for energy efficiency investments, and that a jigsaw of policy pieces is needed to build the necessary framework.

This is the first in a series of blogs looking at ACE’s new policy tracker, and it considers commercial buildings.  It asks, are all the jigsaw pieces in place?  What more can we do easily? And what is going to be a little more difficult?

Where we are now

The Committee on Climate Change identified a least-cost pathway to meeting the 5th carbon budget.  Our analysis of the gap between this and the Government’s projection of emissions given the current policy landscape, shows that – by 2030 – commercial buildings will be emitting 42% more carbon than the ideal, and public sector buildings 34% more.  And the excess energy use involved is costing businesses a lot of money: in London alone, businesses spend over £4 billion per year on gas and electricity; if they could reduce their energy use by a third, that would mean over £1.3 billion every year for these businesses to use on something more productive.

In policy terms, a quick look at the policy tracker clearly shows that we’re really not doing very well.  We don’t appear to have a vision for our commercial buildings, nor do we have an overall target for their energy efficiency.  And we’re not very good at celebrating the achievements of those companies that are working hard to improve their energy productivity.

We have no comprehensive and engaging tax incentives to encourage energy efficiency investments, and there is little action by government to encourage the development of attractive finance offerings.

On a more positive note, the minimum efficiency standards for offices in the Private Rented Sector will result in improvements to our worst commercial buildings, making them better workplaces and hence supporting happier and more productive workers.  We do have energy performance certificates to give organisations information about the premises they are buying or renting, although the requirement for these could be better enforced.  And, in the past, central and local government has taken the lead, through energy demand reduction targets and National Indicators on carbon emissions.

And finally the good(ish) news: products policy has driven up the minimum efficiency standards of widely used appliances, and ESOS has ensured that larger business at least have the tools to understand their energy use and the potential for improvement.  Both these success stories are potentially at risk during Brexit, but we can act to avoid this.

The quick wins

There are some politically and practically easy steps that government and business can and should take right now. The Clean Growth Plan needs to set a high level of ambition for our offices, offering a vision of healthy, comfortable workplaces that support increased productivity; setting a target for commercial buildings energy efficiency and a trajectory towards achieving that target.

The public sector needs to once again set an example: we need targets for energy efficiency in the sector, and public reporting on progress towards these.  Implementing this will help Government achieve the efficiency improvements that it is looking for from the sector without taking money away from public services.

We need a clear message from Government that existing minimum efficiency standards for products, and requirements for energy auditing, will be retained as we exit the EU; and indeed that these policies, which have reduced business energy bills, will be enhanced in the future.

And we as businesses should collaborate on schemes that recognise those companies that are taking a lead in managing their energy use and celebrate their success.

Next steps

Beyond these easy wins, there are other things that won’t be quite as straightforward, but which really do need to happen.

Our existing minimum energy performance requirements for new buildings should be strengthened – by reinstating the trajectory to zero carbon – and our requirements to report on the energy performance of all buildings better enforced.

The review of business energy efficiency taxation has simplified the system but we are still not at the point where all fuels for all users are taxed equitably according to their impact on the climate; and we need to complement the tax with a requirement for public reporting on energy performance for larger companies.

And Government needs to work with the finance sector to ensure that all businesses wishing to invest in energy efficiency (including SMEs) can access attractive finance offerings to support these investments.

If we get these things right, and if we work with the construction trades, we could begin to tap into the already significant market for building refurbishment to ensure that energy performance improvement is a core part of any refurbishment project.

Difficult to do, but we must work out how

Expanding the use of minimum energy performance standards in existing buildings seems to be very difficult politically, and yet business is quite able to deal with regulation in all sorts of areas, provided that it is given sufficient warning and helped to understand how best to respond.  So we should be looking at how we can widen these standards out from the Private Rented Sector and how we can strengthen them.

And we need to bring energy efficiency investments to the top of the pile for business decision-makers: tax incentives for businesses to invest in energy efficiency again seem to be something that Government is reluctant to think about and yet, without them, energy audit recommendations risk being nice projects that get left on the shelf when something more interesting comes along.

 

We’re really not doing that well at the moment, but surely it is time now for Government to act on some of the easy wins whilst working with us on plans for the next steps.  And we should not shy away from the more difficult steps  – the prize: more competitive businesses, a happier and healthier workforce, and greater energy resilience, is too important!

 

Do have a look at the details in our snapshop policy tracker and let us know what your view is.  And if you are interested in finding out more about why we think some policy changes are easier than others, have a look at Chapter 6 in our 2016 report on Buildings and the 5th Carbon Budget.

We look forward to policies developing over the coming months and we will be updating the tracker in response to these changes.

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Energy efficiency: it’s not so special!

Not perhaps what you would expect me to say… but of course I don’t mean that energy efficiency isn’t a wonderful thing. I mean, we should stop trying to separate it out from the other things people do every day.

The Each Home Counts review talks about setting up a separate quality system for home energy efficiency work. Why? Of course we need excellent quality control and customer assurance. But don’t we need this for all work in people’s homes? Isn’t there a risk that, by highlighting the quality control for energy efficiency work, we make it seem like something inherently more risky than other home improvements?

The Green Deal has a ‘Golden Rule’ for finance that only allows people to borrow to a level that will be covered by energy bill savings. Again, the consumer protection benefits of this approach are clear. But someone lending for any other home improvement would only want to be happy that the client could repay the loan; they wouldn’t care about precisely which budget the repayments were coming from. Pay-As-You-Save has a point, but finance providers may want to sell the fact that energy bill savings will help cover repayments whilst at the same time offering additional money for an investment that also delivers comfort and asset value improvements.

Energy efficiency does indeed have some ‘special’ characteristics: it delivers social benefits (including health sector savings and reduced energy imports) that perhaps far outweigh the immediate private benefits to energy consumers. And it faces some barriers that other home improvements don’t (it’s hard to show off your new wall insulation…). So, there are good reasons to implement policy that specifically supports energy efficiency.

But as we develop this policy, we should think about how we make energy efficiency part of ‘the way we do things here’. Not how we make it special. We want to reach a point where people invest in energy efficiency in the same way that they invest in other building improvements – because they recognise that it will make their home / place of work ‘nicer’ to be in; because they believe that it will add value to their property; because it is ‘the done thing’. Not because it is something special, something they should do, something that will set them apart.
If we change our point of view, perhaps we will start to formulate policy that works with the existing refurbishment market, that takes into account the structure of the existing supply chain, and that is actually deliverable.

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Our response to the National Infrastructure Commission’s consultation on National Infrastructure Assessment

In its plan to establish the National Infrastructure Commission, the government set out a responsibility for the Commission to analyse the UK’s long-term economic infrastructure needs, outline a strategic vision over a 30-year time horizon and set out recommendations for how identified needs should begin to be met, through the publication of a National Infrastructure Assessment once a parliament. The Commission has consulted on the Assessment.

In our response, we provide evidence to support our strongly-held view that energy efficiency should be included firmly within the remit of the National Infrastructure Commission as part of a whole energy system approach to meeting the UK’s demand for energy services in a cost-effective way whilst meeting our climate change targets.

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Can the next Mayor make London a world-leading city for energy efficiency?

There are around 775,000 homes in London with a poor energy efficiency rating. We need investment in these homes to transform them into comfortable, healthy dwellings that are a pleasure to live in, contribute to managing our carbon emissions, and are resilient to future energy price rises. There can be a tendency to see London’s homes as too hard or expensive to treat, but let’s stop and think about that for a minute. Yes, there are around 800,000 homes that are in need of solid wall insulation, but there are also over 750,000 that could benefit from cavity wall insulation and over 500,000 that could use improved levels of loft insulation. And having a solid wall home doesn’t mean you can’t reach a reasonable level of energy efficiency. I’ve seen Energy Performance Certificates for London semis giving them C ratings or above, and there are 40 homes in London in the SuperHomes database.

It’s harder to find comprehensive statistics on the state of the non-domestic stock, but 70% of Display Energy Certificates and 66% of Non-Domestic Energy Performance Certificated lodged across London have a rating of D or below.

Domestic EPCs rated E, F or G

Domestic EPCs rated E, F or G

Display Energy Certificates rated E, F or G

Display Energy Certificates rated E, F or G

So, can the next Mayor build on what Boris has started, through RE:NEW and RE:FIT?  The front-runners certainly seem to think so, judging from their manifestos. Zac Goldsmith wants ‘London’s homes to be as energy efficient as possible’ and wants to trial low interest loans, stamp duty rebates and council tax rebates, as well as applying the Dutch Energiesprong model to retrofit London’s tower blocks. He has also pledged to include minimum energy efficiency standards in the London Rental Standard and to back the London Plan’s commitment to Zero Carbon Homes. Sadiq Khan plans to establish Energy for Londoners – ‘a not-for-profit company providing a comprehensive range of energy services to help Londoners generate more low-carbon energy and increase their energy efficiency’. He also refers to energy efficiency standards for new developments and commits to ‘make sure City Hall and all other GLA buildings maintain the highest environmental standards on heating, lighting and waste.’

All interesting ideas, with potential, but they are only a start. We look forward to working with the next Mayor to help make sure that not only do their current ideas achieve their potential, but also that the level of ambition is raised and London becomes a world leader in its low energy building stock. As a start, we have called for the next Mayor to introduce a London-wide minimum efficiency standard for rented homes of EPC Band C by 2025. The opportunity for improvement outlined at the beginning of this blog translates to £4.7bn investment in London’s built infrastructure, would directly support the full-time employment of 2,800 Londoners, along with a further 13,000 jobs up and down the supply chains, each year from now to 2030; not to mention the increased health and wellbeing that comes from living and working in buildings with high energy performance. An opportunity like this must not be missed.

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Our response to Public Accounts Committee Inquiry into Household Energy Efficiency Schemes

In 2013, the Department of Energy and Climate Change (DECC) launched two complementary schemes—the Green Deal and Energy Company Obligation (ECO)—to improve the energy efficiency of the UK’s housing stock. ECO obligates energy suppliers to install efficiency measures, such as loft or wall insulation, with the cost passed on to energy bill payers.

Through the Green Deal, homeowners funded installations by taking out loans, which they repaid through their energy bills. The Department of Energy and Climate Change made the decision in July 2015 to not invest further public funds in Green Deal loans.

The National Audit Office (NAO) examined what the schemes have achieved, and at what cost, the design and implementation of the schemes and whether DECC is learning lessons to feed into future energy efficiency schemes. The Public Accounts Committee have followed this up with an inquiry, to which we have provided a concise response.

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energy auditing,energy management,energy reporting,Non-Domestic

Our response to HMT and DECC’s consultation on reforming the business energy efficiency tax landscape

ACE has submitted its response to HM Treasury and DECC’s consultation on reforming the business energy efficiency tax landscape. We agree there is scope to simplify the landscape, but stress that in doing so, there is real emphasis on reporting publicly with board approval and ensure that cost-effective energy efficiency recommendations are acted upon.

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