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Amendments to the Carbon Emissions Reduction Target – BEEF response

BEEF (the British Energy Efficiency Federation of which ACE is a member, and Director Andrew Warren is Chairman) have submitted a written response to the DECC consultation on the Amendments to the Carbon Emissions Reduction Target.

In summary, the Federation is extremely concerned by the proposals recommended in the consultation and stresses in the strongest terms that these changes will seriously undermine both the carbon savings achieved through the programme, and the energy efficiency industry at a time when it requires support, not additional barriers. We urge the retention of the rewards system for measures, as introduced as recently as April 2008. It would be completely detrimental to any claim to be seeking to provide consistent signals to the marketplace to alter this scheme so radically, so very recently after its launch.

CERT is an imaginative and progressive programme which has the potential to deliver substantial energy savings in the residential sector. It is less than one year old. It was developed only after the most careful consultation with all the relevant stakeholders, particularly regarding the anticipated real savings that can accrue from the installation of the hard energy efficiency measures it was always designed exclusively to deliver. The disruption caused to the marketplace by introducing new unverified measures into the permitted ‘mix’, will devalue both its reputation and its effectiveness. This is particularly as the savings ascribed to the new measures are completely unjustified and unjustifiable.

We are extremely concerned by the proposed inclusion of Real-Time Displays (RTDs) and Home Energy Advice, especially given the carbon saving scores currently attributed. Firstly, these scores far exceed those suggested by any empirical evidence, and will make them the measures of choice for the energy supply companies. These ‘notional’ scores are sufficient to ensure their installation beyond the 10% innovation band, and see them installed without the uplift as standard measures. There is a real danger that the entire remaining CERT budget will be delivered by measures offering ‘notional’ carbon savings rather than the hard energy saving measures that CERT was designed to deliver.

Secondly, there are no safeguards to ensure that RTDs are actually installed or behavioural advice acted upon. These measures have all the bearings of a potential scam, and are highly likely to destroy the credibility of the CERT scheme.

To compound this, the consultation proposes an uplift on DIY top-up loft insulation – a product already being ‘sold’ at negligible prices by retailers through the existing CERT weighting, and which strong anecdotal evidence suggests is being double counted. This uplift will only exacerbate the carbon lost to the programme, both through the uplift and increasing the number of times installers buy the retail product to install.

It is abundantly clear that this consultation seeks to present carbon scores for new measures that have no relation to the amount of carbon saved, purely to make them cost effective to install under the scheme. This is not an acceptable way to manage one of the few carbon reduction schemes in the UK.

Click here for the full response

The issue is also addressed in the latest Warren Report by ACE Director Andrew Warren: ACE Warren Report (2009-03) – If it works dont fix it unless its a successful energy saving programme

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