So finally we have the Green Deal consultation document
in our hands. Was the wait worth it? I have to so that from my point of view it all seems a bit of an anti-climax. As someone that has been relatively close to the policy development over the last six months, it feels like there are relatively few surprises. Even things like the relatively controversial news on the level and split of ECO were very badly kept secrets (we now no for sure that it's going to add up to less than CERT and CESP (£1.3bn vs. £1.5), with an emphasis on hard to treat homes rather than ful poverty (25%)).One of the biggest omissions in the con-doc itself was on incentives, where most people were hoping for some mention of measures that would be put in place to make the scheme a bit more attractive to consumers. On Wednesday, this was sadly lacking, with attention subsequently focussing on the £150 "cashback" that Providers will be able to offer their customers. While some who didn't read between the lines got into a bit of a frenzy about this (showing the lack of excitement elsewhere in the 238-page mammoth), the rest of us were rather unimpressed with an incentive that consumers would effectively be paying to themselves. Fortunately, in one of the weirdest pieces of announcement choreography I can remember for a while, the Government let everyone fret about the potential lack of uptake
for 24 hours before releasing news of a £200m slush fund to aid the scheme during its first two years
. So now we have another announcement to wait for. Apparently the
details as to how this £200m will be spent will be set out by the Chancellor in his Autumn statement next week, having allowed the Lib-Dems a week of glory for finding this pot of money (wherever it has come from).Until then we must all wait in anticipation, perhaps only kept from over-excitement overload by the policy equivalent of Valium that is the con-doc, along with its annexes, customer research reports and impact assessments. A few key jobs for me over the coming few days are to try and understand from the various documents whether we now have a better clue as to how an rag-tag bunch of lacklustre DEAs will become an
well-polished army of Green Deal Advistors before Autumn 2012; how on earth the average punter is expected to understand and compare a range of "quotes" that they get on the back of their GD assessment; whether the plans for ECO will see the insulation industry collapse in to a despairing void of inactivity; and if the whole set of proposals add up to a proposition that has the power to attract either/both consumers and investors (the £200m potentially being an important filip on both fronts). I know all that sounds a bit negative, but it is simply the voice of someone that desperately wants the scheme to work realising that there is still - even now we've seen the consultation laid bare -
so much to do if we are going to have a workable scheme in place, especially if the Autumn 2012 launch target is to be hit.So for now, it's back to the reading, and waiting...
Yesterday DECC made the following documehts publically available for comment:
· A specification for the provision of Green Deal Advisor Services; and
· Guidelines for Certification Bodies who will certify against the specification. Obviously the big one - the Consultation document itself - is still eagerly awaited, but for those of you with an interest in Green Deal assessments, well worth a look. I'll post some thoughts on the docs when I have had time to read them!Below is the email sent with the documents, along with the drafts themselves.Dear Sir/Madam I am writing to you as I understand you have an interest in Green Deal and the Green Deal assessment. One of the key workstreams in this area has been the certification of the work of Green Deal Advisors (GDA), who will carry out the assessments. DECC will shortly be consulting on the Green Deal as a whole, but alongside this we are also developing the detail of what will be needed to deliver this aspect of the framework, seeking targeted input from stakeholders. Certification Bodies will certify that an individual GDA or company employing multiple GDAs is capable of providing the Green Deal assessment to an agreed standard. To maintain consistent, high quality Green Deal assessments the United Kingdom Accreditation Service (UKAS) has already been appointed to accredit Certification Bodies to the standard EN 45011 and additional requirements being developed for Green Deal. UKAS are piloting the proposed certification framework and in support of this DECC has been working on the following draft documents: · A specification for the provision of Green Deal Advisor Services; and · Guidelines for Certification Bodies who will certify against the specification. The specification explains how organisations shall be expected to deliver the GDA Service and the Certification Body guidelines explain how Certification Bodies shall be expected to monitor compliance against the specification.Please find drafts of these documents attached. It is important to note the following: · These are DRAFTS and should not be regarded or used as agreed standards; · As we have not yet formally consulted on Green Deal, a number of areas of policy are to be finalised and we have attempted to highlight these areas throughout; · The term ‘organisations’ is used in these documents to cover any size of business employing GDAs – they could be Sole Traders or much larger companies. The Service needs to be provided to the same standard, whichever company is delivering it. DECC is inviting comment on these draft documents by close of play on Monday5 December 2011, to be sent to: firstname.lastname@example.org. Emails sent to this address should contain the subject heading ‘RE: Green Deal Advisor certification documents’. A suggested template for structuring responses is attached, although comments are welcome in any format. You are requested to keep your comments as concise as possible. If you know of anyone else who may be interested in commenting, please feel free to forward this message on. DECC will review all comments received and prepare final versions of the specifications by the end of January 2012. Many thanks DOCUMENTS
There is now a little less than two months until the Green Deal consultation is due to be launched. That's not a lot of time. As someone with some experience of the inner workings of Government Departments, I can only presume that the writing of the consultation document must be well advanced if it is to have time to clear through DECC ministers and other departments before it's published. This means that DECC must be pretty sure of where it's going with the policy. Maybe this should be reassuring, but it is not. I meet with experts every day who remain unsure of what the Government is going to propose in all sorts of areas of the scheme. While this could just be a communications issue, it suggests to me that the policy is still being written in relative isolation and secrecy, away from the eyes of those with the knowlede and practical experience (and the hard-nosed commerical interest) to make it work.
The fact that apparently the consultation is being written alongside the production of the draft regulations, further strengthens the impression that (as is ususally the case with such things) the details of the scheme are already relatively fixed in the minds of ministers and officials, and there is little that 'negative' responses to the proposals will do to change them.
Now I am an optimist. I think that the Green Deal, if properly designed with genuine and open consultation, can be a success (even if it will never be the panacea that Government - Greg Barker in particular - would have us believe). I, like all of my peers, also desperately want the scheme to succeed. Reducing the emissions from our old and leaky homes here in the UK is absolutely essential if we are to reduce carbon emissions, fight rising energy costs and fuel poverty, and improve the UK's fuel security. But unless DECC considers opening up its doors a little wider, and - dare I say it - pushing back the start date for the scheme to allow for more meaningful dialogue with the industry and other experts, I can't help but think the GD may be doomed to achieve little.
This last week was a busy one for those interested in the Green Deal, with a raft of new information released by the Department for Energy and Climate Change (DECC) on the key aspects of the policy. These included documents covering consumer protection, Green Deal measures, and the new Energy Company Obligation (ECO).
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.
In a speech by the Deputy Prime Minister, Nick Clegg, it has been revealed that the Green Invesment Bank may have a role to play in providing finance for the Green Deal
. So far, detail is sparce, but it is speculated that the bank could play a role in offering finance at a lower rate of interest than commerical providers - something that may be important in the early years of the Green Deal to boost take-up and to enable a greater range of measures to fall within the confines of the "Golden Rule". While it is unlikely that such a role would be anything other than short-term, it could a vital 'primer' for the scheme, injecting momentum and helping to 'make the market' ahead of full participation by private financiers. A report is due out tomorrow which will provide further details of the Green Invesment Bank. Watch this space!
Secretary of State for Energy and Climate Change, Chris Huhne, confirmed yesterday that the government will adopt targets to halve carbon emissions by 2025
, with a goal of reducing emissions by 60 per cent by 2030. With a quarter of the UK's emissions coming from energy use in our homes, and with the majority of the homes that will be in place in 2025 already built, there is clearly a greater incentive than ever for the Goverment to deliver on the Green Deal. Such ambitious targets will require a lot of investment in each home, and for take-up of the scheme on an unprecedented scale. This immediately calls into question the desirability of a cap on the finance available per property, and places a further onus on Government to encourage homeowners to improve the energy efficiency of their homes
through either incentives such as tax breaks, or through minumum standards (and possibly even a combination of both). A beefed-up Green Deal will also need to work effectively in tandem with other policies such as renewable energy feed in tariffs and the renewable heat incentive, which may now also require strengthening.Both business and environmental organisations have long stated that in order to deliver the revolution in our homes that is intended, the Government must also include explicit targets for the Green Deal in the Energy Bill.
The latest announcement makes the case for aggressive targets and bold policy-making stronger than ever.
The Government’s Energy Bill – which will provide the legislative basis for the Green Deal – was yesterday given an unopposed second reading in Parliament. Following the earlier announcement on the increased per-household limit for Green Deal finance, a real boost was given to the policy with the of additional regulations to be placed on the private rented sector - which currently includes a high proportion of the UK’s least energy efficient properties. Under the new proposals, landlords will not be able to refuse “reasonable requests” from tenants to improve their property from April 2012, and will be banned from renting out properties with F and G energy efficiency ratings from April 2018. The announcements seem to be the Government’s first step in recognising concerns held by many that the level of take-up that the Green Deal will be low without additional incentives, and are great news for tenants that may previously have struggled to persuade their landlords to improve their homes. What remains to be seen is whether they will go further to offer further carrots (or sticks!) to encourage homeowners to get involved. Let’s hope so!
Today Greg Barker, Minister for Climate Change and Energy, announced (http://tinyurl.com/6gh5bs7
) an increase in the per-household limit in GD finance from £6,500 to £10,000. This sounds like good news, but one might wonder why there is a limit at all provided that the "golden rule" (that savings generated are greater than repayments) is met. It is as yet unclear whether such a limit will be enough to provide the whole-house retrofit that many houses will need if we are to over-haul the UK's ageing housing stock.
This page is intended to be a place where one and all can ask questions or post their thoughts about the Green Deal. I would welcome offers of guest blogs on any topic related to the GD. If interested, post a comment and I'll get in touch!