APPENDIX 12
Memorandum from the Energy Saving Trust
(EST)
EST'S INTEREST
This is the Energy Saving Trust's response to
the Environmental Audit Committee enquiry "The Energy White
PaperEmpowering Change?". This response should not
be taken as representing the views of individual Trust members.
The Trust was established as part of the Government's
action plan in response to the 1992 Earth Summit in Rio de Janeiro,
which addressed worldwide concerns on sustainable development,
and climate change issues. We are the UK's leading organisation
working through partnerships towards the sustainable and efficient
use of energy by households, small businesses and the road transport
sector.
This response is structured to highlight to
the Committee the benefits and the challenges for delivering household
energy efficiency in the Energy White Paper (EWP). The structure
is as follows:
1. Progress in the policy framework for
household energy efficiency;
2. Challenges for delivering the targets,
including:
(a) further action needed from delivery
agents such as EST,
(b) further policy action or funding needed
from government,
(c) further delivery action needed by government;
3. The disappointments for energy efficiency
in the EWP
1. ENERGY WHITE
PAPERPROGRESS
ON ENERGY
EFFICIENCY
We are very pleased with the recognition in
paragraph 1.14 of the Energy White Paper that:
"the cheapest, cleanest and safest way of
addressing all our goals is to use less energy. We have to improve
energy efficiency far more in the next 20 years than in the last".
We are also pleased (with some reservations
outlined in 2b and 3 below) that the major policies will be put
in place to deliver the 5MtC savings from household energy efficiency
per decade, as we have been calling for.
The two major policy changes are:
(a) the extension and expansion of EEC in
2005, and
(b) the early revision of the Building Regulations
in 2005, making condensing boilers standard for all installations
in England and Wales.
There are also a number of supportive policies
(such as expanding advice on energy efficiency to the consumer)
that will need further funding and development. There is also
a notable lack of fiscal measures, and this we address in paragraph
2b below.
(1a) Extension and expansion of EEC in 2005:
EWP paragraph 3.33:
"we will consult on an expansion of the
EEC[31]
to run from 2005 to at least 2008, at possibly twice it's current
level of activity".
In addition to the general framework there is
also a list of actual measures to 2010, as outlined in paragraph
3.5, and these targets are very helpful in defining the measures
that will need to be installed by 2010:
progressively raising efficiency
standards to that of the most efficient type, condensing boilers,
and installing around 5 million saving 0.6MtC;
4.5M cavity walls to be filled 2005-10
saving around 1.2MtC;
installing an extra 100 million energy
saving lights, beyond the 60 million already anticipated by 2005
saving around 0.5MtC;
faster improvements in the standards
of new household appliances and significantly increasing the uptake
of A-rated appliances which could save around 0.4MtC; and
other insulation measures, improved
heating controls, revisions to the Building Regulations and community
heating with CHP, saving around 1MtC.
This list of measures, and the specific carbon
savings, helpfully gives energy efficiency industries a clear
framework within which they can see the development and expansion
of their most energy efficient products. The actual detail of
the expanded EEC has to be set by Defra, after consultation with
energy suppliers, Ofgem and the energy efficiency industry this
year (2003), but the measures listed above give a clear framework
for where the savings will occur. EST will also participate actively
in this.
An expanded EEC now allows suppliers to develop
long term contracts with the manufacturers and installers of insulation,
condensing boilers, low energy lights, and A rated appliances.
The current EEC is beginning to show some innovative energy service
packages for the customer, and we hope that the security of an
expanded EEC will encourage them to develop more financing deals
for the consumer. EEC is also crucially important for the insulation
industry, as almost all insulation jobs are carried out for either
EEC or Warm Front. Achieving the cavity wall insulation target
of 4.5 million cavities filled 2005-10 will require a tripling
of current annual market activity. We address this issue in (2a)
below
(b) Early revision of the Building Regulations
in 2005
Paragraphs 3.16, and 3.13, and the Government's
response to the Royal Commission on Environmental Pollution's
22nd Report (page 8) announce the early revision of the Building
Regulations:
"Revision of the energy provisions of the
Building Regulations[32]
with the aim of bringing these into effect in 2005. We will use
the Regulations to further raise the standard required for new
and replacement boilers to the level of the most efficient boiler
typesnew A and B rated condensing boilers."
This is a very significant improvement on existing
provisions. It will apply to all new and replacement boilers and
so will have a very significant impact on the boiler manufacturing
ad installer industry. Five million boilers will be installed
in the 2005-10 period.
Condensing boilers currently account for 12%
of the market (doubled in the past year due to EEC but it took
10 years to achieve this level), and this will rise to around
80% in 2005 (comparable to the Netherlands now). All UK manufacturers
make condensing boilers. Some are in a good position to expand
their production of condensing boilers, indeed one exports its
current production to Denmark and the Netherlands. Ensuring a
smooth transition from 2003 to 2005 will be crucial, and this
is why EST is asking Treasury for 5% VAT in this year's budget,
on condensing boilers in this budget to reduce the purchase price.
There is also a big training exercise needed
to ensure installers are trained for condensing boilers, this
is addressed in 2a below.
By making condensing boilers the standard installation,
boilers will not be eligible for EEC credits after 2005. This
will mean energy suppliers will concentrate on insulation, appliances,
lighting and potentially micro CHP for additional carbon savings.
2. CHALLENGES
FOR DELIVERING
THE TARGETS
(2a) Further action needed from delivery
agents such as EST
EST is actively working to achieve the delivery
of the energy efficiency targets. There are two immediate priorities:
Ensuring the heating installation
industry is adequately trained in condensing boiler technology
by 2005.
Ensuring the insulation industry
is in a position to deliver 4.5 million insulated cavity walls
between 2005 and 2010[33]
EST is also aware of the need to expand the
provision of targeted advice to householders to influence their
decisions, and this will be developed more significantly once
new funding becomes available. Last year 670,000 people contacted
our energy efficiency advice, but with 24 million households in
the UK there is still a long way to go in turning around consumer
attitude to energy efficiency and reducing their carbon emissions.
HEATING INSTALLER
TRAINING
There are anything between 38,000-50,000 heating
installers in the UK, of whom only a small percentage (around
500 companies) actively perceive themselves as energy efficiency
specialists. EST has been operating a network of these 500 companies,
but is now addressing the issue of how to extend energy efficiency
training to the vast majority of heating installers.
It is essential that energy efficiency training
(meaning the installation and maintenance of energy efficient
heating systems with condensing boilers and efficient controls)
is a basic requirement for any trainee installer. EST is working
closely with the new Energy and Utility Sector Skills Council,
and the training qualification bodies such as City and Guilds
and the National Vocational Qualification (and Scottish equivalent)
to ensure that energy efficiency is part of the basic training.
Once this is achieved all new recruits will be adequately trained
for the new Regulations. This year there will be 4,000 new installers
trained through the GWINTO scheme.
However the vast majority of current installers
still have not undertaken any energy efficiency training, and
tackling this large and disparate body (many of whom are sole
traders) will be a challenge. Manufacturers, and the whole supply
chain, will play an important part in accessing installers. However
it will almost certainly be necessary to require formal accreditation
of an installer's competency, to ensure that installers do reach
the standard necessary, potentially linking it to current safety
standards such as CORGI.
We are acutely conscious that consumers need
reliable and good quality installation and maintenance, with the
security that any problems will be redressed. Our aim is to ensure,
with the help of Government and the training bodies, that this
expectation is satisfied.
INSULATION INDUSTRY
The target of 4.5 million cavity walls to be
filled between 2005 and 2010 is ambitious. Cavity wall insulation
is a key part of EEC, but this year (first year of EEC) there
has been no increase in demand despite significant cut-price offers
to the consumer. The industry fulfils the demands of EEC and Warm
Front, with almost no demand outside these programmes. There are
currently around 0.3 million cavity wall insulations per year,
so the Energy White Paper target implies a tripling of demand.
Manufacturing capacity is not a problem because
the industry expanded its production capacity before the launch
of Warm Front in year 2000 (in anticipation of a big increase
in demand). But as there are relatively few job orders (and all
these are for Warm Front and EEC) these companies are unwilling
to invest further in installer equipment and training. EST is
very much aware of the pressures on the insulation industry, and
is working to address this. The insulation group of the Energy
Efficiency Partnership for Homes is developing a plan of how to
approach the problem, and we will be taking this forward when
the strategy is agreed.
(2b) Further policy action or funding needed
from Government
There are no fiscal measures in the EWP to encourage
household energy efficiency. However Government does admit in
paragraph 3.10 "tax measures also have a role to play....we
would consult further on specific measures to promote greater
energy efficiency in households".
HM Treasury consulted on just this issue last
year, and to consult yet again will only delay action for up to
a further year.
There is one fiscal issue which EST feels deserves
immediate action, and this is 5% VAT for A and B rated condensing
boilers. The reason this is so crucial is because the condensing
boiler market needs to increase gradually from its current level
at 12% of the market to the 80% of the market that will occur
when condensing boilers become the standard installation for all
new and replacement boilers in 2005.
EEC has proved that price-matching condensing
boilers with non-condensing has been highly successful and has
doubled market share for condensing boilers. So to reduce the
purchase price of condensing boilers by 12.5% (with a VAT reduction)
would allow manufacturers to price-match their products, even
outside the EEC cut-price offers. We want to avoid an unrealistic
jump in market share so manufacturers can smoothly build up their
condensing boiler production immediately, and installers can gain
practical experience of them as soon as they are trained.
We at EST outlined our proposals for fiscal
incentives for home energy efficiency in our submission in 2002
to Treasury's consultation on home energy efficiency. 1 In essence
we recommend that a package of energy efficiency revenue-raising
measures are taken, to balance the incentives for energy efficiency
that reduce Government revenue. A summary of our recommendations
is:
An inefficiency charge on tungsten
light bulbs, and kitchen appliances with an energy rating of D
or below. This would raise £60 million in the first year
from a 50p charge on tungsten light bulbs, plus £60 million
from D-rated appliances and below; so raising £120 million
in total in the first year;
A & B rated condensing boilers
2003-05 (likely to cost c £12 million in the first year);
A-rated household appliances (especially
for cold appliances costing c£11.4M in the first year)
DIY draught-stripping and loft insulation;
Micro CHP once field trials have
proved its efficiency.
Tax credits, stamp duty rebates,
variable Council tax bands for home owners. Tax offsets for landlords
for energy efficiency work, and offsets against Corporation Tax
for installer training in the insulation and heating industry.
A tax incentive for housing developers
to build beyond the 2002 Building Regulations.
A change to the Winter Fuel Payments
to allow older people to opt for a 25% Energy Efficiency Bonus
for improving the insulation of their home, or installing a condensing
boiler, or heating controls. The payment currently costs £1.7
billion per year for 8.9 million elderly people, in 51 million
homes. We propose that the elderly should be given the option
to choose the 25% bonus. By improving the efficiency (such as
insulating the cavity wall) of their home, householders could
make savings of £100 per year for the lifetime of the measure
(30 years for cavity wall insulation). A copy of our brief on
how this could work in practice is attached as an Annex.
In addition to fiscal incentives, there is a
need for more funding to be allocated for the delivery of the
energy efficiency measures. The Energy White Paper acknowledged
(in paragraph 3.44) that advice to householders is important for
supporting consumer decisions, which is especially important to
ensure EEC offers are taken up. It also acknowledges EST's position
that our existing network of Energy Efficiency Advice Centres
could develop into Local Sustainable Energy Centres covering energy
efficiency, renewables and transport. However there is no funding
identified for this, and such a change cannot be made on current
EST budgets. We are this year attempting to run some pilots to
develop the idea at a practical level.
Over the medium term Government will need to
continue to commit spending, and probably expand current levels,
if they are to achieve their goal that no household should be
living in fuel poverty by 2016 in England and Scotland, and 2018
in Wales.
(2c) Further delivery action needed by Government
For energy efficiency, Defra will be developing
an implementation plan this year, with a report to be published
in February 2004, and the Devolved Administrations are taking
or considering similar action. There will be some crucial policies
to develop this year, which should be included in this plan:
the details of EEC2 negotiated between
energy suppliers, the heating, insulation, lighting and appliance
industries;
concrete progress on training and
capacity building in the energy efficiency industries, especially
installers. EST is actively working on this, and will be participating
in the Better Buildings Summit (paragraph 3.19) to be chaired
by Ministers from Defra, ODPM and DTI;
a coherent strategy of how Local
Authorities can proactively help deliver the energy efficiency
targets; and
progress on the role of micro CHP
in EEC2 and if appropriate in the new Building Regulations. EST
and the Carbon Trust are working together on field trials to verify
the energy efficiency and carbon saving advantages of the product;
Ofgem will also need to make progress on the 28-day rule which
energy suppliers and micro CHP developers believe inhibits long-term
contracts with consumers.
It will be the final framework of EEC2 that
will give the industry confidence, or otherwise, of their ability
to meet these ambitious targets. EST would also like to see a
longer-term timescale for EEC2 (beyond 2008) so the continued
framework for meeting the 2010 targets can be met. This is something
Defra, Ofgem and the energy suppliers should consider this year.
For suppliers, this would allow them to arrange longer-term contracts
that are more akin to their business planning cycles.
3. DISAPPOINTMENTS
FOR ENERGY
EFFICIENCY IN
THE ENERGY
WHITE PAPER
We are disappointed the government did not explicitly
adopt the PIU target for a 20% improvement in energy efficiency
by 2010 and a further 20% by 2020. However, there is an implicit
goal in paragraph 3.7 "savings of this magnitude would need
roughly a doubling through increased energy efficiency of the
rate of energy intensity improvement seen in the past thirty years".
In addition we welcome the fact that Michael
Meacher in his PQ answer to Sue Doughty MP on 10 March clarified
the position that the 5MtC saving from household energy efficiency
2002-10 "would correspond to an energy efficiency improvement
of approximately 20% relative to the year 2000."
In addition we believe targets are only as useful
as the policies in place to deliver them, and we are comfortable
with the policies in the White Paper, provided they are developed
as set out above.
We are also disappointed that there is no longer-term
ambition for where Building Regulations will go beyond the 2005
revision. EST called in its response to the PIU review, and the
Energy White Paper for a "requirement for new build to be
near zero emission from 2012". We believe that a longer-term
goal for construction would allow the industry to develop new
energy efficiency techniques and technologies. There are excellent
examples such as Bedzed in South London, where this has been achieved,
and where the occupants benefit from fuel bills one sixth of the
average level.
As outlined in 2b) and 2c) above, we are disappointed
there is no additional funding identified for energy efficiency.
It is clear that additional public funds and fiscal measures will
be needed to ensure the effective delivery of the targets for
installer training, and targeted consumer advice.
March 2003
Annex
Winter Fuel Payments for Energy Efficiency
INTRODUCTION
This paper outlines EST's proposal to modify
the Winter Fuel Payments made to all over 60s every year. The
proposal allows individuals to opt for a 25% bonus, if they choose
to invest in energy efficiency measures for their home. These
measures would include insulation (wall and loft), and efficient
heating systems.
Elderly householders are often not aware of
the measures they could take in the home which would lead to reduced
fuel bills, a warmer home, and which would help them avoid the
health problems associated with poorly insulated and poorly heated
homes. The purpose of the 25% energy efficiency bonus would be
to ensure householders contact their energy suppliers and then
take advantage of the cut-price offers for insulation and condensing
boilers.
CURRENT STATUS
OF WINTER
FUEL PAYMENTS
Each winter (usually in December) the Department
of Work and Pensions pays the Winter Fuel Payment to all individuals
over the age of 60. The payment is made via bank transfer or Post
Office cheque, and the level is:
£200 per elderly individual,
or
£100 per individual sharing
the home with another elderly person receiving the payment.
This payment costs the Exchequer £1.7 billion
per year. It is paid to around 8.9 million2 elderly people in
six million homes. Of these around two million3 are eligible,
as benefit recipients, for assistance under Warm Front and equivalent
devolved administration fuel poverty programmes.
EST'S PROPOSED
CHANGE
No elderly person would receive less than his/her
current level of eligibility. By agreeing to energy efficiency
work, the householder would receive a 25% bonus.
In early November all WFP recipients would receive
a letter from Dept of Work and Pensions which would give them
two options:
(a) to do nothing, and they would then receive
their normal WFP allocation (£200 per individual or £100
each for couples); and
(b) to return a reply form agreeing to receive
half their normal allocation immediately ie £100 for individuals
£50 each person in a couple, plus a £150 (or £75)
cashback for energy efficiency work done in the home. This way
the householder receives a 25% bonus for having energy efficiency
work done in the home.
HOW THE
PROCESS WOULD
WORK IF
THE ENERGY
EFFICIENCY BONUS
WAS ACCEPTED
BY THE
HOUSEHOLDER
1. If the householder returned the energy
efficiency acceptance coupon, half their normal allocation would
be paid into their bank account. The householder would receive
a coupon and covering letter with all phone numbers for contacting
energy suppliers or the Warm Front managing agents so they can
contact them to arrange a home visit.
2. At the home visit the supplier would
advise the householder whether they are eligible for Warm Front
cost-free installations (insulation and heating), or any EEC offers
for benefit recipients. The householder would be advised of the
measures they could install, and which offers are available.
3. Households eligible for Warm Front would
have the work done in the normal way, and the Warm Front managing
agent would give the householder a receipt to prove the work had
been done. The householder would take the receipt to the Post
Office to cash in the voucher (£150 or £75 for each
individual in a couple), or infirm people could send it to DWP
for payment.
4. Households not on benefit could take
any EEC offer from an energy supplier, but not this would have
to include a heating or insulation measure, and could not just
be limited to energy saving lightbulbs. This would include cavity
wall insulation, a condensing boiler, loft tank and pipe insulation,
and heating controls. The householder would have suitable work
carried out, would pay the supplier up front, would then take
the receipt for work and the voucher to the Post Office to receive
the £150. Alternatively, infirm householders could send the
voucher and the receipts to the DWP for payment.
CASE STUDY
1
The householder decides to insulate the home
cavity walls:
The energy supplier would allow the householder
to take an existing cavity wall offer, and the £150 voucher
would be offset against the cost:
The average cost for cavity wall insulation
on a 3 bedroom semi = around £468,
A current EEC offer with a supplier is a "50%
off" offer = £234
The householder would use their £150 voucher
to offset against this cost, while paying the money up front.
The supplier would give the householder a receipt for work done,
so the £150 voucher could be cashed.
The actual cost to the householder would be
£84 for the house walls to be cavity filled.
CASE STUDY
2
The householder decides to insulate the loft
with top-up insulation:
The energy supplier would insulate the loft
to Building Regulations standard (250mm), and would charge the
householder for the work, and give them a receipt. The householder
would either take the receipt plus the voucher to the Post Office,
or return both to DWP for payment.
A flowchart of how this would work in practice
is attached.
1 Energy Saving Trust Submission to HM Treasury
on Improving Household Energy Efficiency, Fiscal Incentives: Home
Energy Efficiency, November 2002 (see http://www.est.org.uk/est/est.html?est-homepage.html)
not printed here
2 Official Yearbook of the UKnational
statistics 2002
3 The UK Fuel Poverty Strategy 2001

31 The Energy Efficiency Commitment requires energy
suppliers to offer energy efficiency measures to their customers.
The current EEC runs 2002-05, and costs the customer around £3.60/fuel/year,
around 1% of average fuel bills. Around £165 million/year
is spent by suppliers on energy efficiency offers, and this will
achieve carbon emission reductions of 0.4MtC/year by 2005. Back
32
1% of average fuel bills. Around £165 million/year is spent
by suppliers on energy efficiency offers, and this will achieve
carbon emission reductions of 0.4 MtC/year by 2005. Back
33
Gas and Water Industry Training Organisation. Back
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