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

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.

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

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.

ACE has submitted a written response to the Department for Energy and Climate Change’s consultation on the Smart Meter Implementation programme – consumer engagement strategy.

ACE begins its response by pointing out the inexorable rise in the costs due to be incurred by the Smart Meter programme. It will be incumbent on Ofgem as the regulator to ensure that vulnerable customers are protected against the costs and that the benefits of the programme are shared by this customer group.

Find ACE’s consultation response here.

ACE has submitted a written response to Ofgem’s consultation on its Vulnerable Customers’ Strategy.

ACE supports the four themes of Ofgem’s strategy but points out that little emphasis has been placed on the coverage, by these themes, of environmental obligations. At least £540 million of the Energy Company Obligation’s notional annual budget will be spent supporting vulnerable households with energy efficiency measures. ‘Monitoring and enforcement’, ‘encouraging best practice and research’, ‘knowledge and influence’ and ‘information for consumers’ based on all the activities under the ECO must form a central plank of Ofgem’s new strategy – especially in the absence of (in England) any continued public expenditure on energy efficiency for vulnerable households after March 2013.

Find ACE’s consultation response here.

ACE has submitted a written response to the Department of Energy and Climate Change consultation on the new heat strategy – The future of heating: a strategic framework for low carbon heating.

ACE points out in the response that what is missing from the evidence behind the strategy is an analysis of the full extent to which demand for heat can be reduced. It is essential that we have a reasonable prediction of future heat demand and, if we follow a path that involved the electrification of heat, we have a reasonable prediction of future electrcity demand.

Find ACE’s consultation response here.

ACE has submitted a written response to the European Commission, DG Energy, Public Consultation on Financial Support for Energy Effieincy in Buildings.

In the response ACE stresses the importance of a robust Energy Efficiency Directive and the introduction of a mandatory energy efficiency target in driving energy efficiency investment. The response also points to a number of examples of best practice in Member States including the recycling of the revenues from the sale of the EU ETS allowances into energy efficiency programmes.

Find ACE’s consultation response here.

ACE has submitted written responses to the Department of Communities and Local Government Consultations on the Building Regulations in England Section two: Part L and Section four: the building control system.

The consultation on Building Regulations Part L was formed of two sections. The first was on the introduction of the requirement for “consequential improvements” to be required when an existing building is extended or when elements are replaced. Click here for our full response.

The second part of the consultation on Part L covered all other proposals under this section (Conservation of fuel and power). Click here for our full response. In appendix to this response we also submitted a paper on Improving Compliance with Part L drafted in collaboration with CIBSE, CPA, BSRIA and STROMA which can be found here.

Finally our response to the consultation on changes to the Building Control system can be found here. This response should also be read in conjunction with the paper on Improving Compliance with Part L.

ACE has submitted a written response to the Department of Energy and Climate Change Consultation on Comprehensive Review Phase 2B: Tariffs for non-PV technolgies and scheme administration issues.

This response is further to the written response to Comprehensive Review Phase 1: consultation on Feed in Tariffs for Solar PV. The ACE response outlines that a requirement should be in place for an energy efficiency standard to be met before a tariff can be received for any building mounted or related technology.

Click here for our full response.