DCLG: Review of Property Conditions in the Private-Rented Sector

Written by Pedro Guertler on . Posted in Consultation Responses, Perspective, Private Rented Sector Campaign


ACE and Friends of the Earth have long been concerned about the poor standards of energy efficiency (and high concentrations of fuel poor and vulnerable households) in the private rented sector (PRS). The PRS is a rapidly growing part of the housing market. Of the 22.8m households in England in 2011, 4 million were privately rented (17.5% of the housing stock). This was an increase of 1.6m in only six years – and is the highest level since the early 1990s. The Department for Communities and Local Government has issued a review of property conditions in the PRS, and invited stakeholder responses; ACE and Friends of the Earth have provided theirs together.

ECC Committee: ACE evidence submitted to Green Deal watching brief (part 2) inquiry

Written by Pedro Guertler on . Posted in Consultation Responses, Perspective


ACE has submitted written evidence to the Energy & Climate Change Select Committee’s inquiry into the Green Deal (watching brief part 2). In May 2013, the Committee published its first watching brief report, in which it outlined its concerns about the lack of clarity regarding the outcomes that DECC expected from the Green Deal and how it would measure the its success. The Committee identified key areas in which scrutiny would be beneficial, and outlined its intention to review the performance of the Green Deal and ECO at a later date – hence Part 2 of this Green Deal watching brief inquiry.

Questions for DECC on proposals tabled 2.12.2013

Written by Andrew Warren on . Posted in Articles and Blog, Consultation Responses, Perspective

In response to recent announcements regarding changes to energy efficiency policies (including this DECC press release), ACE have asked DECC to answer the following questions:

1.  On the announcement of a “Stamp duty rebate” for home-movers who install efficiency measures:

  • Is this really a stamp duty rebate (implying a return of money at some point after purchase for homeowners who can prove they have installed measures) or is it just a cashback by another name?  What will the delivery mechanism be?
  • Does this money come out of the existing £200m cashback pot, or does it come from somewhere else?  Is this Exchequer funding?
  • It is anticipated that 60,000 homes a year will be helped.  But what if a large number of homeowners opt to have more expensive measures installed?
  • If the share of the £450m allocated to this scheme runs out prior to April 2017, does this mean that the scheme will be closed?

2.  Help for private landlords:

  • The press release talks of a “scheme to support private landlords” and promises a share (unspecified) of £450m will be available to fund this.  However, the press release goes on to say that this scheme will  consist of “funding available through the Green Deal”.  It is therefore confusing as to whether this will be Government funding channelled through the Green Deal, or else some “tweaking” of Green Deal finance, or else some extension of the LESA scheme?
  • In an article in The Sun newspaper (1st December), Nick Clegg and David Cameron refer to “cash incentives to landlords of the least energy efficient properties”; the press release meanwhile talks of “helping landlords bring their properties up to minimum standards” – the implication of both of these statements is that the funding for landlords will only be available to landlords of F and G rated properties.  Can this be clarified/confirmed?
  • In the article in The Sun, Nick Clegg and David Cameron talk about the incentive being available to landlords “when they are between tenants” – will the incentive only be available during void periods?
  • Government is claiming this will deliver 1.8Mt of carbon savings .  If it is geared to existing F and G-rated homes,  surely all these savings must already be built into Government carbon estimates from the time the Energy Bill 2011 made it mandatory to outlaw F & G rated properties.  Therefore there will be no new carbon saved – it will just be a sweetener for landlords to get them to obey the law.
  • There are 440,000 F & G rated properties in the private rental sector. The new scheme will incentivise just 45,000 of them over three years,  e.g 10% of the total.  Can this be confirmed?

3. Spending breakdown:

  •  We’re told that there will be £450m of new investment for the two new measures above.  What is the breakdown of spending as between the two measures?

4. Carbon savings and public buildings:

  • What are the carbon savings associated with each of the above, and how much additional carbon saving is assumed to come from the £90m being allocated to schools, hospitals and other public buildings? What shape is deployment of this £90m – is it a grant? Or an extension of a finance mechanism (presumably Salix)?


We hope DECC will soon provide clarification on these important points.


Environmental Audit Committee: Inquiry into Housing Standards Review

Written by Pedro Guertler on . Posted in Articles and Blog, Consultation Responses, Perspective


The Environmental Audit Committee launched an inquiry into the Government consultation on the Housing Standards Review, which proposes “to wind down the role” of the Code for Sustainable Homes. It is taking oral evidence today. ACE submitted its written evidence to the Committee last week; the main points provided in evidence are:

  • The new Part L of the Building Regulations has not gone as far as anticipated in terms of the minimum standard it sets for new housing.
  • Against this backdrop, the justifications used for proposing to get rid of Code for Sustainable Homes energy standards and falling back to Part L alone, whilst proposing to amend or remove the Planning and Energy Act in consequence, are even flimsier and more narrow-minded than they would otherwise have been.
  • The proposals, if adopted, would reduce housing quality, increase running costs for occupants, damage localism and stifle construction innovation.
  • And the proposals are made all the more remarkable for their political naivety and short-sightedness.

Download our evidence, and read Andrew Warren’s earlier article on this topic.

DECC: Consultation on Energy Savings Opportunity Scheme

Written by Andrew Warren on . Posted in Consultation Responses, Perspective


ACE has submitted a written response to the Department of Energy and Climate Change consultation on the Energy Savings Opportunity Scheme.

Article 8 of the EU Energy Efficiency Directive requires all Member States to introduce a regime of regular energy audits for ‘large enterprises’ (non-SMEs) to promote the uptake of cost-effective energy efficiency measures. These audits must be undertaken by 5 December 2015, and then every four years thereafter.

The consultation sought views on the UK’s approach to meeting this requirement through implementing a new Energy Savings Opportunity Scheme (ESOS). The Government’s ambition is to “develop a proportionate and better regulation approach, which yields real energy efficiency rewards”.

Ofgem: consultation on requirements for hard-to-treat cavities under the ECO

Written by Pedro Guertler on . Posted in Consultation Responses, Perspective


In late August 2013 Ofgem published a consultation seeking views on its proposed requirements under the Energy Companies Obligation (ECO) for demonstrating the characteristics of a hard-to-treat cavity (HTTC) wall to which insulation has been installed.

The consultation put forward proposals to address concerns that a significant number of HTTC measures installed under ECO may have been installed to cavity walls that do not meet the statutory definition of ‘hard to treat cavity’. ACE’s and others’ views, put to Ofgem, is that its proposals are very poorly thought through.

Ofgem says they received a high number of responses to the consultation, many of which (including ACE’s) suggest changes to the proposals. In order to properly review all of the responses and consider modifications to our consulted position, Ofgem no longer intend to publish the outcome of the consultation by 1 October 2013 or to implement any new requirements relating to HTTCs from 1 October 2013.

Ofgem will confirm the ‘date of effect’ for any new requirements relating to HTTCs in its response to the consultation and additional guidance on HTTCs. These documents will be published at least one month before the new requirements come into effect. The date of effect for any new requirements will be no earlier than 1 December 2013.

DG Taxation: Consultation on existing legislation on VAT reduced rates

Written by Pedro Guertler on . Posted in Consultation Responses, Perspective


ACE has submitted a written response to the European Commission, DG Taxation Consultation on “Review of existing legislation on VAT reduced rates”.

The EC’s stated aim is to create a “simpler, more efficient and more robust” VAT system in the EU, partly by removing certain reduced rates which are believed to “constitute an obstacle to the proper functioning of the internal market”.

The EC has already conducted some evaluation of the existing VAT structure, and this consultation focuses on key areas that require further consideration, including the reduced VAT rate for certain energy products.

Download ACE’s consultation response here:  Consultation Response: VAT reduced rates

BIS: Consultation on energy intensive industries in the UK

Written by Jack Carrington on . Posted in Consultation Responses, Perspective


ACE has submitted a written response to the Department of Business, Innovation and Skills consultation on Energy intensive industries in the UK- maintaining international competitiveness.

In November 2011 the Chancellor announced that the government would implement measures to reduce the impact of policy on the costs of electricity for the most electricity-intensive industries, beginning in 2013 and worth around £250 million over the Spending Review period.

As part of this the government committed to compensate some electricity-intensive businesses to help offset the indirect cost of the Carbon Price Floor and the EU Emissions Trading System.

Government published a proposal setting out the eligibility and design of the scheme, and this consultation covers these proposals.

Read ACE’s response to the consultation here.

DECC: Consultations on the Renewable Heat Incentive

Written by Pedro Guertler on . Posted in Consultation Responses, Perspective, Uncategorized


ACE has submitted written responses to two Department for Energy and Climate Change consultations on the Renewable Heat Incentive (RHI).

The consultation on proposals for a domestic scheme sets out DECC’s proposals for longer term support to householders who install renewable heating kit such as biomass boilers, heat pumps and solar thermal into homes. The RHI for householders is aimed at any householder looking to replace their current heating with renewable heating kit or householders who have installed any such technology since 15 July 2009. It is intended that householders will get paid for each kWh of heat they would be expected produce under the current proposals.

The consultation on Renewable Heat Incentive: expanding the non-domestic scheme sets out DECC’s broad proposals to expand the existing scheme.

Read ACE’s consultation responses here:

Domestic RHI: ACE consultation response

Non-Domestic RHI: ACE consultation response

DECC: Triennial Review of the Fuel Poverty Advisory Group

Written by Pedro Guertler on . Posted in Consultation Responses


ACE has submitted a written response to the Department for Energy and Climate Change’s Triennial Review of the Fuel Poverty Advisory Group.

ACE has been privileged to be a member of the Fuel Poverty Advisory Group (FPAG) since its inception in 2002. The principal purpose of FPAG is reporting and advising on the effectiveness of the delivery of the Government’s Fuel Poverty Strategy on the ground.

The Government recognised the importance of establishing an independent Fuel Poverty Advisory Group as early as February 2001, when it published its consultation draft of the Fuel Poverty Strategy. ACE believes that the Government was absolutely right in its judgment in 2001 and that nothing has changed to make an independent advisory body less vital now than it was then. In fact, with the number of fuel poor households having risen sharply from 1.2 million in 2005 to 3.5 million in 2010 (and projected to surge to 3.9 million in 2012), there is clearly a greater need than ever for Government policies to be subjected to independent scrutiny.

This is particularly important when considered against the backdrop of slashed Government spending on fuel poverty – down by almost a third from 2009 to 2012 – and the fact that the number of low income and vulnerable households helped under the Warm Front programme dropped from 170,000 in 2010/11 to just 24,000 in 2011/12, a near sevenfold decrease in just one year.

Find ACE’s response here.