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ACE’s response to the Mayor of London’s draft London Environment Strategy

ACE welcomes the vision and principles of the Mayor of London’s draft London Environment Strategy and the ambition for London to be a zero-carbon city by 2050.

We agree that the city’s most pressing environmental challenges are harming Londoners’ health and the city’s economy, and that the current pace of change is too slow. The Mayor highlights that big problems need ambitious responses. Therefore, we would like to see the Mayor’s activity and focus on air quality continue, but also expanded in relation to improving the energy efficiency of buildings, improving the lives and reducing health inequalities of those households that are in fuel poverty, whilst supporting economic growth in the environmental goods and services sector.

Our full response to consultation on this strategy can be found here.

 

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ACE’s response to the Mayor of London’s draft Fuel Poverty Action Plan

ACE welcomes the publication of the Mayor of London’s draft Fuel Poverty Action Plan for London to help support the eradication of fuel poverty across the capital. We agree that fuel poverty remains at unacceptable levels and that it has not received the attention that the issue deserves.

ACE’s response covers four key topics:

  • Supporting the roll-out of borough referral networks.
  • Improving the energy efficiency of London’s homes, with a particular focus on improving standards in the Private Rented Sector.
  • Energy for Londoners.
  • How the Mayor should work with the UK Government.

Our full response can be found here.

 

 

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Our response to BEIS’s consultation on ECO: Help to Heat

The Energy Company Obligation (ECO) is a programme to deliver energy efficiency measures in homes across Great Britain in order to reduce carbon emissions and improve the ability of low income and vulnerable consumers to heat their homes to comfortable levels. ECO was launched in January 2013 and is currently in its second obligation period (ECO2), which is due to end on 31 March 2017. The Government’s Spending Review 2015 announced plans for a supplier obligation to run for 5 years from April 2017 at an estimated level of £640 million per year. This consultation is on the shape of a transitional year from April 2017 to March 2018, paving the way for a subsequent 4-year scheme

While the overall size of the supplier obligation from 2017 is too small, many of the changes proposed appear sensible. However, under the proposals, there will be significant under-delivery to households during the transition year. This is due to the progress made to date under ECO2, the potential for over-delivery and carryover of excess work into the transition year, and the fact that proposed deemed scores are approximately one third lower than the evidence from RdSAP assessments under ECO2. We therefore strongly recommend that the extended CERO target is increased from 3MtCO2 to at least 4.1MtCO2, and the HHCRO target from £1.84bn to at least £2.08bn. This would comfortably keep the transition year’s delivery costs within its notional spending limits, and make sure BEIS and ECO’s stakeholders deliver what is possible with the (too modest) budget limits established by the last Comprehensive Spending Review.

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commercial sector,ESOS,policy design

Non-domestic energy efficiency – policy design principles

Dr Peter Mallaburn is Director of Policy and Governance at the Energy Institute, University College London, and Editor of Climate Policy Journal. He has represented the UK on air pollution, climate modelling and energy policy in the EU, OECD and the IEA and worked on international climate negotiations. Peter helped write the UK’s first Climate Change Programme, set up the Carbon Trust, was Salix Finance’s first CEO, and set up his own consultancy, Policy to Practice, in 2008.

The government is currently reviewing its non-domestic energy efficiency policies as well as its wider policy portfolio as part of the Carbon Plan. DECC’s 2016 Departmental Plan provides some context:

Although the energy intensity of the UK economy has fallen by 24% since 2004, there remains significant untapped potential for energy saving in the business sector. Realising this potential will improve businesses’ productivity and will also support growth. But the business energy tax and policy framework is complex and businesses tell us it does not provide the incentive it could to reduce energy consumption. 

This article contributes to this process by outlining our state of knowledge on energy efficiency and identifies some key policy principles around which a new energy efficiency programme could develop. It is drawn both from the literature and from direct policy experience in the UK and overseas.

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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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DECC’s Household Energy Efficiency Statistics: the good, the bad and the whaa…?

Liz Warren is a founder and director of SE2, a small consultancy helping individuals, communities and organisations build their capacity to respond to climate change. You can find out more about their work at www.se-2.co.uk.

DECC recently published statistics on the take-up of energy efficiency measures by households during 2015.  In this blog post, we unpick some of the data, exploring the good, the bad and the frankly baffling within the rich data set provided. How did policy announcements affect the market? Have whole-house energy assessments unlocked energy efficiency opportunities? And could we have found the elusive answer for improving the private rented sector?

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Our response to HMRC’s consultation on reduced rate of VAT for Energy Saving Materials

ACE has submitted its response to HMRC’s consultation on proposed changes to the reduced rate of VAT for the installation of energy saving materials in compliance with a recent decision by the European Court. In the summer of 2012, ACE took the lead in convening a broad coalition of interested organisations who were concerned about the implications of the Reasoned Opinion sent by the European Commission to the UK Government to the effect that its 5% reduced rate of VAT on energy saving materials went beyond the scope of the 2006 European VAT Directive. Over subsequent years we have led the coalition in:

  • encouraging the UK Government to respond robustly to the Commission in defence of its reduced rate;
  • providing the Government with a detailed report setting out the reasons we believed that the UK’s reduced rate did in fact form part of a social policy;
  • liaising closely with officials both before and after the CJEU judgment, setting out our view that the UK Government should use the vires in both Category 10 and Category 10(a) of Annex III of the VAT Directive to retain as much as possible of the reduced rate.

Notwithstanding a few concerns, we broadly welcome the Government’s proposals.

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Press Release: ‘Scandalous’ – winter deaths surge, but Chancellor slashes help for cold homes by 42%

Press Release, for immediate release

ACE’s reaction to Excess Winter Deaths figures and Comprehensive Spending Review

On the same day that official figures reveal that last winter’s Excess Winter Deaths were at their highest level for 15 years, ACE has described as ‘scandalous’ the Chancellor’s announcement of a 42% cut in the help available to households living in dangerously cold homes. They have also expressed disappointment that, despite allocating £100 billion for infrastructure projects, Mr Osborne has chosen to spend not one penny of this pot to make the UK housing stock more energy efficient.

Jenny Holland, Head of the Parliamentary Team, said:

“The appalling state of our housing stock is one of the key causes of excess winter deaths, which today’s figures show surged last winter to their highest level in 15 years.  Yet despite this, the Chancellor has today ignored industry-wide pleas to release infrastructure funding for an energy efficiency programme.  Instead, he has announced that the Energy Company Obligation – the only remaining help for householders living in cold homes – will be slashed to £640m a year from 2017, a drop of 42% on annual ECO spending to date.

”The Chancellor boasts that households benefitting from the ECO are expected to save £300 on their bills. But these lucky few will amount to just 200,000 per year. The other 5 million poorest households who struggle with their basic living costs won’t even get a look in until April 2022.”

In addition, while welcoming the proposal to build 40,000 ‘affordable’ homes by 2020, ACE points out that, having ditched the zero carbon homes standard earlier in the year, the Chancellor has needlessly saddled these homes with higher fuel bills.  ACE also describes as a missed opportunity the Chancellor’s refusal to announce variable rates of stamp duty based on a home’s energy efficiency.

Jenny Holland continued:

“It’s a bit rich for the Chancellor to trumpet these new homes as ‘affordable’ when he was the one who, without warning, ditched the zero carbon homes standard in July.  This means that these new homes will be needlessly saddled with higher running costs – or householders will be forced to have expensive and messy retrofits at some later stage to bring their homes up to scratch.

“Meanwhile, the Chancellor has again shown a willingness to adjust stamp duty as a policy lever, increasing it by 3% for buy-to-let purchasers.  But he has once again failed to incentivise energy efficiency investment by introducing a revenue-neutral adjustment to stamp duty based on homes’ energy performance.”

For more information, contact: Jenny Holland, jenny@ukace.org, 07875 629781

PDF version of press release

Notes for Editors:

The new Energy Company Obligation, to run for 5 years from April 2017, will cost £640m per year.  That represents a 42% reduction in the ECO’s actual expenditure to date (£1.1bn per annum on average over the 2.5 years to the end of June 2015, according to the latest available official statistics).

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Display Energy Certificates,Energy Performance Certificates,European Energy Performance of Buildings Directive,Zero Carbon Homes

Our response to the European Commission’s consultation on the Energy Performance of Buildings Directive

This consultation forms part of the evaluation of the Energy Performance of Buildings Directive. Under the terms of the Directive, the Commission is required to carry out this evaluation by 1 January 2017, with assistance from a Committee of Member States’ representatives. The evaluation should reflect the experience gained and progress made since the adoption of the Directive. If necessary, the Commission should make proposals on the basis of the evaluation.

The evaluation also follows on from the Energy Efficiency Communication of July 2014, which indicated that additional measures to be introduced to improve energy efficiency would need to primarily address the energy efficiency of buildings and products if progress is to be made by 2030. The Energy Performance of Buildings Directive is the main legislative instrument in force at EU level covering the energy efficiency of buildings.

With a primary focus the UK energy efficiency market, our response to the consultation highlights: the uncertainty following the abandonment of the zero carbon trajectory; the missed opportunities with respect to driving higher rates of renovation; the low level of compliance with EPBD’s provisions and the virtual absence of enforcement; the question marks hanging over Display Energy Certificates; the need to make EPC data more widely accessible; and the need to plug skills and capacity shortages in the energy services and energy auditing sectors.

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