Energy Efficiency
115. The energy regulators
both share specific statutory duties with the Secretary of State
to promote the efficient use of energy, particularly among domestic
consumers.
The E-factor
116. OFGAS's primary tool
to promote energy efficiency, known as the `E-factor', was instituted
under the previous Director General, Sir James MacKinnon. Under
the RPI-X revenue cap, British Gas is allowed more revenue for
every extra therm of gas sold, therefore investment directed to
increasing gas sales clearly has revenue benefit for British Gas.
However, if an equivalent amount is invested in energy efficiency
schemes, there is no increase in the cap. The E-factor, allowing
British Gas to pass on to tariff customers the costs of investment
in energy efficiency measures, was introduced, as the current
DGGS told the Environment Committee in 1994, to "counteract
this specific regulatory distortion" created by the RPI-X
formula.[258]
Thus the schemes which qualify for the E-factor are those where
increased gas sales and energy efficiency are commercial alternatives.
"There is no scope within the E-factor for spending money
which would not be commercially viable if there were no regulatory
distortion".[259]
Schemes under the E-factor have to be approved by the regulator
and are, in practice, managed by the Energy Saving Trust.
117. The E-factor has been
used to provide some core funding to the Energy Saving Trust and
also to fund condensing boiler and residential combined heat and
power projects run by the Trust on behalf of British Gas. Under
the gas condensing boiler subsidy scheme some 9,700 boilers were
installed, representing a fourfold increase in sales over the
previous year.[260]
In the year ending 31st March 1995, the DGGS agreed that £2.3
million was eligible to be passed through as a charge to tariff
customers under the E-factor.
118. However, widespread
use of the E-factor has been suspended.[261]
The current DGGS told us that the E-factor was in effect a levy
on consumers and that "I do not see that it is the role for
an independent regulator, who is not fully accountable to Parliament,
to raise taxes on gas consumers ... that should be a decision
for Parliament".[262]
She also said that she would prefer a scheme to promote energy
efficiency parallel to that introduced in the 1995 Gas Act to
address social concerns, whereby a decision on any levy is taken
jointly by the regulator and the Secretary of State. We have
previously recommended that the Government, and not the regulator,
should take responsibility for any imposition of a levy for energy
efficiency.[263]
We have seen no evidence to suggest that our original recommendation
was misguided and therefore we broadly agree with the stance taken
by the DGGS, as we have done before. As Mr Eggar told us "It
should be a matter for Government to decide whether additional
charges should be paid by consumers for environmental matters,
rather than for the regulators".[264]
We recommend that the Government accept responsibility for
raising any levies on gas consumers to fund energy efficiency
measures and that, it introduce appropriate legislation to achieve
this.
Standards of Performance
119. OFFER created a scheme
similar to the E-factor through PESs' Standards of Performance
conditions. In 1991, the DGES set 16 Standards of Performance
for PESs on important aspects of customer service. One of the
conditions requires PESs to arrange energy saving projects for
their customers, the costs of which can currently be passed on
to tariff customers at a rate of £1 a year.[265]
Energy saving projects under this scheme must be approved by
the DGES and "to date over 280 projects have been approved
involving a planned PES expenditure of almost £59 million".[266]
Projects include insulating over 210,000 homes and distributing
4.75 million compact fluorescent light bulbs. OFFER estimate
that Standards of Performance projects already approved will produce
energy savings in the region of 4,300 gigawatt hours over their
lifetime.[267]
The Energy Saving Trust, who manage many of the Standards of
Performance projects on behalf of PESs told us that, overall,
such projects had already led to a 4.55 million tonne reduction
in carbon dioxide emissions - equivalent to the emissions that
might be expected from 900,000 households.[268]
The Department of Environment told us that for every £1
spent, customers should receive a £5 energy benefit.[269]
Most witnesses who commented on the Standards of Performance
scheme, like the Royal Society for the Protection of Birds, believed
that it had been successful.[270]
120. Some witnesses expressed
concern over the future of the scheme after liberalisation.[271]
The DGES has, to some degree, already addressed this concern.
In January this year he published his revised proposals for price
restraints in the post- liberalisation market which included proposals
for the continuation of the Standards of Performance levy from
1998 for 2 years.[272]
The scheme would then be reviewed again.
121. We have the same reservations
over the constitutional position of the Standards of Performance
scheme as those regarding the E-factor. Therefore, we recommend
that the Government accept responsibility for raising any levies
on electricity consumers to fund energy efficiency measures and
that, it introduce legislation to achieve this.
Other environmental regulation initiatives
122. Both regulators have
also attempted to discharge their environmental duties through
the operation of price controls and through other licence conditions.
All suppliers of gas and electricity to the domestic market are
required by licence to provide energy efficiency advice to customers
upon request.[273]
The proposed new price controls for British Gas Supply are more
cost-reflective and, consequently, will reduce any artificial
incentive to sell more gas. Similarly, the proposed controls
for TransCo, with a 50:50 split between fixed revenue and per
therm revenue will, according to the DGGS, remove artificial incentives
to transport more gas and increase incentives towards the efficient
use of gas.[274]
For its part, OFFER told us that recent revisions of price controls
for transmission, distribution and supply companies have reduced
the extent to which revenue is linked to volume or, in the case
of the NGC, linked to maximum demand on the system, thereby removing
artificial incentives, which existed in the original controls,
to sell more electricity.[275]
OFFER also pointed out that price controls promote energy efficiency
by increasing the incentives to reduce electricity losses in transmission
and distribution.[276]
The Environment Agency has welcomed these new price controls.[277]
123. Despite these measures,
some witnesses questioned whether the regulators were doing enough
to promote energy efficiency and discharge their wider environmental
duties. The Energy Saving Trust told us that there was "very
little evidence that much importance is attached to ... energy
efficiency and the environmental duties"[278]
and the Association for the Conservation of Energy said that "there
is scope for, and feasibility of, more positive action".[279]
As we have already stated primary responsibility in this area
should lie with the Environment Agency. We recommend that
the regulators do their utmost, within their respective remits,
to promote energy efficiency.
The impact of competitive supply markets on energy efficiency and energy conservation
124. There has been much
public debate on the likely impact of liberalisation in supply
markets on progress towards energy efficiency and energy conservation.
It has been argued that, if energy prices fall as suppliers compete
for market share as, for instance, they have in the gas trials
in the South West, there will be less incentive for domestic users
to conserve energy or invest in energy saving equipment and that
the pay-back period for such investment would be longer. Concern
focuses on the fact that, initially at least, competition is likely
to centre on price. This is certainly the message from the gas
trials in the South West where prices have fallen by some 20%.[280]
The DTI estimate that for every 10% drop in energy prices demand
is stimulated by 2%.[281]
125. The Department of Environment
told us that there "is not necessarily a conflict between
the desire of companies to increase their market share and the
need to promote energy efficiency, provided the overall market
does not increase in size".[282]
Moreover, the UK Round Table on Sustainable Development added
that "market forces can assist a move towards sustainable
development" provided that they operate within a regulatory
regime which addresses environmental concerns.[283]
OFFER believe that competition in supply "should strengthen
the incentive on suppliers to offer more efficient solutions to
customer needs"[284]
and British Gas, amongst others, supported this argument, stating
that "supply companies can gain market share by ... offering
better and additional services".[285]
These "better and additional" services are commonly
referred to as energy services.
Energy Services
126. If the development
of energy services is to compensate for the negative impact on
energy conservation that lower prices is likely to have, it is
important that such services develop quickly. The Association
for the Conservation of Energy told us "the free market alone
is not likely, in the short to medium term at least, to result
in an energy sector which meets society's needs in an optimal
way".[286]
The World Wildlife Fund estimated that energy services will not
emerge for several years.[287]
The UK Round Table on Sustainable Development, in their Report
on The Domestic Energy Market: 1998 and Beyond, expressed
similar concerns.[288]
We support the recommendation of the UK Round Table on Sustainable
Development that the government "should consider promoting
the development of energy services if these do not emerge quickly
on their own accord". [289]
127. Even if energy services
do emerge, there are a number of reasons, other than falling prices
reducing incentives, why consumers may choose not to take advantage
of them, as British Gas pointed out.[290]
Consumers may lack the necessary information to be able to assess
the impact of particular efficiency measures; they may not be
in a position to be able to receive the benefits of such measures
- for instance landlords or tenants; or they may not have the
funds required for the initial investment. The Government has
a number of initiatives designed to promote energy efficiency
to domestic consumers. For instance the Energy Efficiency Best
Practice Programme seeks to raise awareness of the considerable
scope for energy savings and the financial and environmental benefits
that can be gained; and the Home Energy Efficiency Scheme provides
grants to allow qualifying low income consumers to carry out energy
savings measures.[291]
Nevertheless, with the liberalisation of domestic energy supplies,
there is a need, and potential, for further initiatives. We
recommend that the Government consider further ways, for instance
through consumer education, building regulations, appliance standards,
labelling schemes and, where appropriate, financial incentives,
to encourage all consumers to invest in cost-effective energy
efficiency measures.
The Energy Saving Trust
128. Significant parts of
the Government's energy savings initiatives are implemented through
the Energy Saving Trust, for which it provides core funding.
However, the Government have not guaranteed long-term funding
for the Trust, stating that "the funding will be tapered
to reflect the Trust's role as a catalyst, stimulating investment
in energy efficiency and the development of self-sustaining markets
for energy efficient goods and services".[292]
At present the commitment to funding only covers the first few
years of a competitive market. Both the Trust itself and the
UK Round Table on Sustainable Development argue that the Government
should, to ensure the development of energy services and to counteract
the effects of liberalisation, make a commitment to the long-term
funding of the Trust.[293]
We agree. We recommend that the Government should make a
commitment to the long-term funding of the Energy Savings Trust.
258 Energy Efficiency: The Role of OFGAS,
Minutes of Evidence taken before the Environment Committee, HC
328, Session 1993-94, p.2. Back
259 Energy
Efficiency: The Role of OFGAS,
p.2. Back
260 Mem.
p.6. Back
261 Mem.
p.59. Back
262 Q.
893. Back
263 First
Report from the Trade and Industry Committee, Session 1994-95,
on The Domestic Gas Market, HC 23-I, para 45. Back
264 Q.
301. Back
265 Q.
1039. Back
266 Ev.
p.279. Back
267 Ibid. Back
268 Mem.
p.59. Back
269 Mem.
p.6. Back
270 Mem.
p.73. Back
271 Mem.
pp.60, 75. Back
272 The
Competitive Electricity Market from 1998,
January 1997. Back
273 Ev.
p.249, 279. Back
274 Ev.
p.250. Back
275 Ev.
p.279. Back
276 Ibid. Back
277 Mem.
p.10. Back
278 Ev.
p.59. Back
279 Ev.
p.161. Back
280 Q.880. Back
281 Unprinted
evidence. Back
282 Mem.
p.6. Back
283 Ev.
p.155. Back
284 Ev.
p.279. Back
285 Ev
p.301. Back
286 Ev.
p.162. Back
287 Mem.
p.79. Back
288 Report
by the UK Round Table on Sustainable Development, The Domestic
Energy Market: 1998 and Beyond, January 1996, para 7.13. Back
288 Ibid,
para 7.14. Back
289 Ibid,
para 7.14 Back
290 Ev.
p.301. Back
291 Government
Reply to the First Annual Report from the UK Round Table on Sustainable
Development, April 1996, paras 44 and 45. Back
292 Ibid. Back
293 The
Domestic Energy Market, para 7.22. Back