While the documents, as a package, didn’t ‘show as much leg’ as many might have hoped, they did include some interesting developments, and important areas of reassurance for consumers who may have feared that the Green Deal could end up being a breeding ground for corporate stitch-ups, con-men and dodgy workmanship.
The latter were covered in the shortest of the three documents, entitled “Consumer Protection in the Green Deal”, which set out some of the high level safeguards that would be in place to help ensure that those that take up the Green Deal can do so with confidence. Detail on the specifics remains relatively light, but the proposals included a statement of the intention to put in place a rigorous Code of Practice which would cover Green Deal Providers, Advisers and Installers; details of how these individuals/organisations would be accredited; a commitment to put in place an independent Government telephone and web-based advice service; and how customers with complaints can seek redress. As with most areas of the policy, there is a great deal more to be done to add flesh to the bones of these proposals, but it must be welcomed that Government is taking consumer protection seriously, in a bid to avoid the kind of disaster that the Australian Government experienced when implementing a similar policy.
The document on Green Deal measures contained relatively few surprises, but did explicitly pave the way for micro-generation technologies such as photo-voltaic panels to eventually be supported by Green Deal finance. While it clearly makes sense to bring these kinds of consumer measures together, I would prefer to see a clear emphasis placed on reducing energy first through energy efficiency before turning to renewables. It will also be interesting to see how the Government will approach the integration of existing incentives for renewables (e.g. Feed in Tariffs) into the Green Deal without introducing too much complexity for the consumers to bear.
Proposals for the Energy Company Obligation have been long awaited but are possibly the area that will leave the biggest sense of disappointment at the lack of detail and progress. The document set out the intention to leave previous obligations such as CERT and CESPS behind (along with their reputation for spurious savings and lack of transparency), and create a new scheme which would focus on lifting households out of fuel poverty (with targets for ‘Affordable Warmth’) and driving improvements of hard-to-treat homes (i.e. through the subsidy of measures that would not otherwise qualify for the Green Deal such as solid wall insulation). These aims, of course, are laudable, but the Government has failed to set out the level of ambition for these targets, what it expects the value of ECO to be, or how non-energy company Green Deal Providers will be able to access the funds (without which the market will be distorted and competition - and the potential to achieve cost-effective outcomes – will be diminished).
In all, some useful signs of progress, but with so many big issues still under discussion with only a few short months remaining before the Government intends to consult on the Green Deal regulations, the suspicion becomes ever sharper that the Autumn 2012 start date could be somewhat unrealistic.