We welcome the Scottish Government’s consultation on the topic of minimum energy efficiency standards in the Private Rented Sector and consider that this is a vital first step to ensure that all homes in Scotland are energy efficient, enabling tenants to be warmer in their homes and use less energy. Fuel poverty remains a significant issue in Scotland, and across the wider UK, particularly in the private rented sector. Increasing the energy efficiency of these properties is key to reducing this problem. This consultation on standards for the private rented sector represents an important step towards realising this vision.
We welcome the Scottish Government’s commitment to prioritise energy efficiency as a national infrastructure priority through a large-scale SEEP programme over the next 20 years. As part of this consultation response ACE recommends that the Scottish Government should:
– Set both interim milestones and final targets to set a clear direction of travel
– Prioritise the early implementation of energy efficiency measures while continuing to work on the decarbonisation plans for Scottish homes;
– Implement minimum energy efficiency standards in both domestic and non-domestic buildings, and
– Implement financial and fiscal incentives to support minimum energy efficiency standards in both domestic and non-domestic buildings.
The overall size of Help to Heat is too small to meaningfully tackle carbon emissions and fuel poverty. 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.
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.
We provide evidence to support our strongly-held view that energy efficiency should be included firmly within the Commission’s remit 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.
In April, Bright Blue launched its Green Conservatism research project. One of the strands they are taking forward is on renewed home energy efficiency policy. We submitted our response to the stakeholder consultation in May.
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. Having taken the lead in convening a coalition of interested organisations concerned about the implications of the European Commission’s view on the reduced rate of VAT, and through constructive and sustained engagement with the Government, we a pleased to say that – notwithstanding a few concerns – we broadly welcome HMRC’s proposals.
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.
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.
The All-Party Parliamentary Group for the private-rented sector launched an inquiry into energy efficiency in private-rented housing. Along with Friends of the Earth and Citizens Advice, ACE led a widely supported civil society campaign in 2010/2011, which led to the 2011 Energy Act placing a duty on the Secretary of State to introduce a minimum energy efficiency standard for private rented housing from April 2018 at the latest.
The Energy & Climate Change Committee is investigating the factors that contribute to investor confidence in the energy sector and wants to build an understanding of how DECC’s policy making process might impact on investor decisions.
ACE has submitted its evidence to this inquiry, highlighting issues with investor confidence in the energy efficiency sector and the role it can and must play in meeting our climate, energy security and affordability objectives.
ACE has submitted its written evidence to the Committee’s inquiry highlighting the successes of past programmes, the weaknesses of recent schemes and lessons that can be learned from them, including lessons from the US and elsewhere in Europe.
The Energy and Climate Change Committee is holding an inquiry to gather views on what areas of DECC’s policies will require particular scrutiny in the coming years. Responses to the consultation will help to inform the Committee’s work programme. Here are ACE’s answers to the two specific question posed.
What CLG is proposing is to abolish (or severely truncate) a DEC regime which is proven to drive energy savings in public buildings and therefore make savings to the public purse. Far from freeing up resources for frontline services, abolishing DECs would at best reduce any energy cost savings being achieved and at worst enable the public sector to hide their wastefulness from the taxpayer and encourage profligacy. At a time of increasing pressure on public budgets and the need for more transparency to better account for public spending, the proposals to abolish or truncate a DEC regime which demonstrably saves far more money than it costs to run is plain stupidity.
ACE has submitted a written response toe the Department of Energy and Climate Change’s consultation on a new fuel poverty strategy for England. A strategy is widely held to encompass the following elements, elements which we would have hoped to see after four years of deliberation: identifying the nature and scale of the challenge at hand; setting goals to meet that challenge; laying out policies, programmes and actions to achieve those goals; and earmarking resources to execute the policies, programmes and actions. Instead, the consultation contained a series of important but ultimately small picture questions. In our response, we focused on answering big picture questions not posed in it.
ACE has submitted written responses to The Department of Energy and Climate Change consultations on private rented sector energy efficiency regulations, for the domestic and non-domestic sectors respectively. Following a campaign by ACE and its allies, the Energy Act 2011 placed a duty on the Secretary of State to bring into force regulations to improve the energy efficiency of buildings in the domestic and non-domestic private rented sector in England and Wales.
Today, we submitted our response to DECC’s consultation on the future of the Energy Company Obligation (ECO). This is the consultation which seeks to rubber-stamp cuts to the ECO amounting to £30-35 off the average energy bill. We, and many others, have consistently argued that cutting Britain’s only national energy efficiency programme – designed to reduce household energy bills and carbon emissions in the long term – to achieve a modest one-off energy bill reduction is completely perverse.
But our analysis with the Energy Saving Trust, the Centre for Sustainable Energy and the Cavity Insulation Guarantee Agency finds that the cuts amount to more: nearly £42 per household – yet energy suppliers are only handing back around £32.50, on average, to each household. This represents an aggregate windfall to energy companies of £245 million this financial year.
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. Read ACE’s and Friends of the Earth’s response to CLG’s review of property conditions in the PRS.
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.
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’ve 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?
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.
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. ACE submitted its response to DECC’s consultation on the proposed Energy Savings Opportunity Scheme last week.