Proposal to drop RdSAP from ECO – the time to respond draws near
As reported to Elmhurst members in May 2016, OFGEM have issued a consultation document proposing “deemed scores” as a replacement to RdSAP as the method of calculating carbon saving and subsidy for ECO. The closing date for feedback is the 8th July and Elmhurst encourages all members to have their say. You can see an overview of Elmhurst’s response here.
In essence the new “deemed scores” methodology, if adopted, will;
- Remove the need for a DEA to verify the inputs, instead technical monitoring companies will get the responsibility on the small percentage they are required to investigate. The rest will be self declared.
- Classify dwellings only by the following simple questions:
1. Property type (flat, terraced house etc)
2. Size (number of bedrooms
3. Primary heating fuel (Gas, Oil, Electricity
4.Measure type to be installed (not all measures actually installed under ECO2 will remain available)
Having now read the consultation in detail we strongly believe the proposal is a retrograde step that has totally disregarded the advice of the National Audit Office (NAO) in its review of April 2016 which said that;
- be clear about the purpose of schemes from the outset, setting realistic priorities and clear success criteria,;
- understand and plan for how the desired outcomes will be delivered in practice.
- ensure it has sufficient information to track progress of the schemes towards each of its desired outcomes.
- consider the long-term impact of its decisions on the overall progress towards increasing household energy efficiency.
Deemed scoring fails on every one of these key recommendations
Elmhurst will provide Members with a more detailed breakdown of our response to the consultation, but to give you a flavour, we believe deemed scores will;
- Make the improvement of larger than average dwellings cost ineffective
- Will drive down the quality and standards of products & materials
- Stifle the innovation of new, high performing building products
- Require untrained and unregulated individuals to make judgements that can tax even the most experienced and qualified Domestics Energy Assessors.
- Puts the ‘process’ in front of the families who receive measures
- Removes any form of ‘reasonable’ measurement
Deemed scores can only ever be broad brush estimation of the carbon savings, meaning non standard properties will be disadvantaged, and higher performing and innovative measures disadvantaged.
An RdSAP EPC should always be maintained as an alternative to deemed scoring to ensure that the benefits of an installation (measure) can be calculated fairly.
Move ECO away from the current focus on ‘how much money is being spent’ towards ‘the actual improvement achieved’.
Government should insist that each installation is independently assessed by a qualified and accredited energy assessor after the installation is complete to demonstrate the success of ECO in objective terms.
For many households the improvement delivered by ECO will only be the start of the story. A householder presented with an EPC that demonstrate the saving made, and other potential savings, will help to change societies attitude to energy and energy efficiency.
Government should create a process where householders are supplied with an RdSAP EPC which is an authoritative independent report on the energy efficiency of their home and a list of cost effective recommendations for improvement.
The consultation closes on 8th July 2016, just four weeks away. Elmhurst encourages Members to read the full 24 page consultation here, and to have your say. We will certainly be responding and will continue to do everything we can to demonstrate the value of EPCs and the energy assessment process that produces them.