Memorandum from Energy Advisory Associates
We have the impression that the DETR replied
to the Committee in November 1999 and, in doing so, largely rejected
all the Committee's conclusions and recommendations (except, now,
the reduced VAT rate on insulation materials). The DETR's action
was extremely disappointing, because I and many colleagues thought
that the EAC's August 1999 report was excellent.
I personally sent 20 pages of detailed comments
and suggestions to DETR in January 2000 on how to spend the £150
million revenue from the climate change levy (CCL) which has been
allocated to energy efficiency or renewables. We, and I know many
other experts in the UK, criticised the emphasis on enhanced capital
allowances (ECA's). However, as the Chancellor announced very
detailed plans for ECAs in the Budget, it appears that the DETR
and Treasury had already made up their collective minds before
DETR received the hundreds or thousands of submissions. Some of
these were very, very detailed.
In other words, we faced virtually a fait accompli.
One is not pleased to find that the DETR is
clearly not listening to outside experts who have far more experience
on the application of energy efficiency measures to buildings
in the UK and elsewhere than many DETR staff. In particular, we
regard the DETR's "consultation" on the CCL as perilously
close to a total waste of outsiders' valuable professional time.
The 1998 consultation on Part L of the Building Regulations by
DETR's contractors, Oscar Faber, reached a clear consensus on
the basic energy efficiency levels to aim for. The Committee may
wish to ask DETR why a review which was apparently proceeding
to plan in 1998 has not yet led to a set of recommendations for
public consultation. The original plan, so far as we all gathered
in 1998, seemed to be to publish such proposals by December 1999.
As this firm was involved in preparing two sub-contract reports
for Oscar Faber in summer 1999, I must emphasise that concern
over this delay is no way intended as a criticism of Oscar Faber,
who at the time seemed to be doing an extremely thorough job.
I must also stress that the reports are covered by DETR confidentiality
clauses; the only matter which is currently in the public domain
is the timescale.