Retrofitting the Green Deal
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Table of Contents Foreword 1 Executive summary 2 Introduction 4 Closing the Green Deal funding gap 9 Further opportunities and better assessments 16 Conclusions and recommendations 19 End notes 21 This report was written by Nicholas Schoon on behalf of BioRegional and The Association for the Conservation of Energy. BioRegional is an entrepreneurial charity which establishes sustainable businesses and works with partners around the world to demonstrate that a sustainable future can be easy, attractive and affordable. We call our approach One Planet Living. www.bioregional.com The Association for the Conservation of Energy represents companies and other organisations engaged in energy conservation. It aims to encourage a positive national awareness of the need for and benefits of energy conservation, to help establish a consistent and sensible national policy and programme, and to increase investment in all appropriate energy saving measures. www.ukace.org 2
Foreword Britain badly needs the Green Deal and the accompanying Energy Company Obligation (ECO) scheme to work, for the sake of the economy, the environment and people’s wellbeing. If it succeeds in its big ambition of directing massive private sector investment into energy-saving retrofits in millions of homes and small businesses, it will have cracked one of the hardest of energy conservation nuts. The Government finds itself under real pressure this autumn from rising household energy bills. A thriving Green Deal, set to help millions of families to cut their gas and power consumption, could have relieved some of that pressure. Instead, Government is considering entirely the wrong response - cutting back on programmes which help the fuel poor to keep warm and ordinary households to cut their energy consumption. The Green Deal has got off to a painfully slow start. Unless changes are made, the pace will not pick up sufficiently and its potential will remain very far from being fulfilled. The Green Deal itself is in need of an urgent retrofit. In this report we offer practical, affordable recommendations for such a retrofit which should be implemented relatively quickly. Going with the grain of the Green Deal, our recommendations aim to build on the large amounts of work already done in setting up the scheme. Success depends, ultimately, on many different businesses, organisations and individuals involved in delivering energy-saving improvements. But Government played the lead role in creating the Green Deal and legislating for it; now it must take the lead in tackling some major shortcomings. We speak from experience and with a strong desire for the Green Deal to succeed. The member companies of the Association for the Conservation of Energy want to build viable, long term businesses on energy saving retrofits for homes and small businesses. BioRegional ran one of the Pay As You Save trials, with B&Q and Sutton Borough Council, which helped pave the way for the Green Deal.(1) Working with Cherwell District Council, we have delivered more than 100 Green Deal assessments and are organising Green-Deal style retrofits to 14 homes and small businesses in Bicester, Oxfordshire. Today’s homes and buildings are going to be around for many more decades. We cannot afford for them to carry on wasting warmth on such a huge scale – not if we are serious about cutting carbon, helping families, improving living standards and greening economic growth. We need a Green Deal, now, which can stay the course and make a real impact. Sue Riddlestone, Andrew Warren, Director, Chief Executive, BioRegional Association for the Conservation of Energy November 2013 1
Executive summary under the Green Deal. Most households which might be interested in taking out a Green Deal would find themselves having to pay at least Properly executed, the Government’s new Green £1,000 upfront. Deal energy saving loan scheme has the potential to transform energy saving in Britain’s homes, Green Deal assessments, the starting point for bringing in big gains to the economy, household the scheme, need improving and the bulk of budgets and the environment at the same time. them need to be provided free of charge. But it has got off to a disappointingly slow start We make several recommendations which, taken and seems on course to deliver a few tens of together, represent a retrofit for the Green Deal thousands of home retrofits a year, at most. – one which would enable it to fulfil its great Given all of the time and effort that has gone potential. into creating the scheme from government and the private sector and the scale of the original The Green Deal interest rate needs to be lowered; ambition behind it, this is a tiny sum. we suggest how it could be. We also argue for a government-backed incentive scheme for Green The Green Deal ought to be delivering several Deal retrofits. This would help to close the Green 100,000 retrofits a year. A goal of more than one Deal funding gap, but it would also encourage million homes per annum would be reasonable many households to use the Green Deal as an given the size of the task of improving the UK’s assurance scheme without having to use Green still highly energy-inefficient housing stock. Deal finance. The benefits in carbon savings, energy bill We make recommendations for improving reductions, maintaining and creating jobs and the assessment process, for encouraging more enhancing welfare and health from this level of small businesses and traders to be engaged in retrofits would be enormous. the scheme, and for the Green Deal to have a stronger impact in streets and local communities. The most important problem with the Green Deal, as it now stands, concerns a funding gap caused by its so-called ‘golden rule’ which places limits on how much a household can borrow 2
Recommendations at gaining a better fix on the typical energy savings actually achieved by the various Green Deal measures, in kilowatt hour, Incentives for retrofits and closing carbon and money terms. This should then feed into improvements in the modelling the Green Deal funding gap and methodology used to makes savings 1. Government needs to guarantee Green estimates in Green Deal assessments. Deal loans so as to reduce the APR to below 7. A long-term supply of free assessments 4%. should be offered to householders, lasting 2. Government should assess variable stamp at least three years and capped in the duty and Green Deal grants as incentives region of one million assessments a year. for household retrofits, then deploy one or This offer should be focused on households both of these for at least three years. that are most likely to benefit from a Green Deal package and most likely to take one 3. Government should explore the potential out. for a street-level Green Deal incentive, administered by local councils, aimed at 8. The Energy Performance Certificate and encouraging groups of neighbours to club the Green Deal Occupancy Assessment together in commissioning Green Deal Advice Report need to be restructured and retrofits for their homes. rewritten so as to align more closely with each other, with clear and simple messages 4. Green Deal incentives along the lines about their purpose and the differences we propose strengthen the case for between them. The explanation of ‘actual’ ‘consequential improvements’ measures in versus ‘typical’ estimated savings should the Building Regulations. This means that be improved, with clearer messages about if approval is sought for any alteration or the likely accuracy of these estimates and extension which would increase a home’s what factors determine whether they will energy demand, then its overall energy be realised. efficiency must be improved so as to offset this increase. Home improvements, 9. To further improve the accuracy, reliability along with house purchases, are the and credibility of Green Deal assessments: most important opportunity points for • DECC should commission research householders to make major energy saving on an adequate sample of Green retrofits. Consequential improvements Deal assessments, to determine their should be brought into the Building accuracy and share information on Regulations once a Green Deal incentive is the most common errors and how to deployed. eliminate them. Bringing more small traders and • If necessary, it should revise the Green SMEs into the Green Deal Deal Code of Practice to ensure errors in assessment reports are swiftly 5. Accredited Green Deal Installers should be rectified – by carrying out a second able to offer unfinanced (or self-financed) assessment if need be. Green Deal packages to households without a Green Deal provider being • The typical costs of recommended involved, provided appropriate safeguards measures used in all assessment are introduced. reports should be updated annually. On Green Deal assessments 6. The Department of Energy and Climate Change should commission research aimed 3
1. Introduction legal carbon budgets (housing is responsible for nearly a quarter of UK greenhouse gas emissions). A shared vision of a coming revolution for Britain’s 27 million homes has formed during This uplifting vision was propped up by a harsh the past five years. It was shared by government reality; unit costs for domestic gas and electricity and a wide range of people, businesses and had risen sharply and were likely to keep rising. organisations involved in housing, in promoting local economies and employment, in energy Self-interest would transform the vision into supply and environmental protection. substance. Most people would be willing to invest in upgrading their homes’ energy What did they envisage? A sea change in efficiency in order to control these rising fuel attitudes and understanding around energy in bills. The exception would be a low income the home. The nation’s enduring (and endearing) minority lacking savings or the ability to borrow; love affair with home improvement would come their home retrofits would have to be financed by to embrace home energy conservation. taxpayers, or by all energy consumers paying a small levy on their bills. When people bought or rented a dwelling, its energy efficiency would become a key factor in These kind of redistributive measures were the the price they were willing to pay. When they did means by which most of the work on retrofitting any kind of renovation or improvement work, the UK’s overall housing stock had been financed from a new kitchen to a loft extension, increasing over the previous two decades, most recently their home’s energy efficiency would be a prime by the Warm Front, Community Energy Saving consideration. Programme (CESP) and Carbon Emissions Reduction Target (CERT) schemes. But the Britain’s army of local tradespeople – small thinking, in government and beyond, was that building firms, plumbers, gas and kitchen fitters - such subsidy schemes were incapable of doing all would become energy retrofit ambassadors, with of the heavy lifting needed to complete the big the knowledge, training and contacts to integrate task of retrofitting Britain’s existing homes. energy efficiency upgrades into other home improvement projects. Such schemes had succeeded in insulating millions of lofts and cavity walls across the UK Houses and flats would become more like over the past 20 years, plucking much of the cars: people would pay close attention to fuel low hanging fruit. But not all of it. In any case, economy figures before making a purchase (or lofts and cavity wall insulation represents only a deciding to rent), then keep a close eye on energy fraction of the total domestic retrofit work which performance while living in the property. can be justified as cost effective, in that energy And so, within a decade, most UK households bill savings eventually cover the upfront costs of would have attacked rising gas and electricity the energy saving measures. (2) bills by radically upgrading their homes with This gap between what has been achieved so far much improved insulation and heating systems, and what ought to be done grows still wider if a lighting and appliances, and by installing their cost is put on household CO2 emissions and if the own renewable and low-carbon energy sources. health and wellbeing benefits which accrue from The nation’s heat-leaking housing stock would tackling fuel poverty are factored in. thus be transformed, its chronic fuel poverty There was also a consensus that in order to make curbed and tens of thousands of jobs related real progress individual upgrades needed to be to home energy use would be protected - or bigger, covering the whole house with a package even created - boosting the local and national of measures and offering correspondingly larger economy. energy savings. Direct and indirect carbon dioxide emissions from energy consumption in homes would fall, easing the burden of complying with the UK’s 4
A long way still to go The Committee on Climate Change (CCC) 2013 Progress Report to Parliament finds there The latest English Housing Survey, published are 5-7 million lofts with insufficient levels in July 2013 and covering the period 2011-12, of insulation and some 4-5 million homes found: with unfilled cavity wall. There are also some 7-8 million homes with solid walls in need of • 11.5 million homes, 55% of those with insulating. central heating boilers, were still lacking the more energy-efficient condensing Under its indicators framework, which aims type of boiler to guide government in cutting emissions and meeting its statutory carbon budgets, the CCC • At least 8.7 million homes, 37% of those proposes that: with cavity walls, still lacked cavity wall insulation • All remaining lofts and cavity walls be adequately insulated by 2015. • 7 million homes, 31% of the English total, have solid rather than cavity walls, • Insulation of 2.3 million solid walls by and only some 5% of these have had 2022. solid wall insulation installed. • Replacement of 12.6 million old, • 8.7 million homes, 48% of those with inefficient boilers by 2022 loft spaces, have less than 150mm of loft Its indicator trajectory sees direct and indirect insulation. The recommended depth is emissions from UK homes falling from 134 270mm million tonnes of CO2 a year in 2012 to 80 • 2.7 million homes (12%) still have no million tonnes of in 2022. Improvements double glazing or less than half of their in home energy efficiency, alongside windows double glazed decarbonising grid electricity, would have a leading role in delivering those carbon savings. • 36% of England’s homes (some 8.3 million) were in the bottom three Energy Efficiency Rating Bands – Bands E, F and G. Only 15% were in bands A-C. These bigger retrofits would save more energy but the big, familiar problem obstructing domestic they would also be more expensive. That makes energy conservation remained. Most households it harder to justify charging all energy consumers are unwilling or unable to spend significant sums a levy in order to finance them. Why should upfront in order to save energy in future. everyone pay when some of the households receiving the retrofits can afford them as well as They can understand the argument for investing benefitting from them? £5,000 in a new, high efficiency boiler and controls, topped up loft insulation and cavity Furthermore, there was always some danger that wall insulation, in order to cut their gas bill by the money raised by this kind of levy might be £500 a year. But few would be willing to write a poorly controlled and spent badly. Giving away cheque for it. vast quantities of unwanted low energy light bulbs, or even losing millions of them, as E.ON Why not? Because these savings lie in the future did, became the most notorious example.(3) and may not be as large as promised. And what if they sold their home in a few years and moved So, some argued, the time was ripe for self out? Someone else would then benefit from the interest rather than levy-funded subsidies to reduced bills. become the main engine driving retrofits. But 5
But the biggest obstacle is the plain fact that need energy-saving improvements so that the £5,000 (or even £500) is a great deal of money gas and electricity they are struggling to afford for most households. If they had that sum actually keeps them warm rather than going to in savings, or could borrow it at a reasonable waste. They could not afford to pay off a loan interest rate, many could find other things of through a charge on their electricity bill. more immediate personal benefit or importance to spend it on. The other ‘carbon reduction’ part of ECO tackles measures which deliver major energy and carbon 1.1 Enter the Green Deal savings but cost so much that they could never meet the Golden Rule. This covers interior or Three key features of the long awaited Green Deal exterior wall insulation for homes with solid launched by the Energy and Climate Change walls (lacking heat saving cavities) and insulation Department (DECC) in January 2013 (and for cavity walls that are more difficult, and the similar Pay As You Save scheme which the therefore expensive, to fill. previous government had begun to work up) were ECO places an obligation on energy suppliers to meant to break through these barriers. deliver target levels of carbon and energy saving, Together these three make it a pioneering loan in line with the objectives of reducing fuel scheme purpose-built for financing home energy poverty and delivering costlier retrofit measures. retrofits in which the upfront costs are gradually The energy suppliers are meant to find the paid off by an extra charge on electricity bills. cheapest ways of hitting these targets, and they They are: pass costs on to all of their customers. 1. If a household which has taken out a Green The hope was that together the Green Deal Deal moves out of a property the household and ECO would make a big impact on the great moving in takes over the remaining loan national task of retrofitting the UK’s housing payments. stock. The remaining low hanging fruit – under- insulated lofts, easy-to-treat cavity walls, old, 2. The ongoing savings in energy bills should inefficient boilers – would continue to be plucked. equal or exceed the ongoing costs of the loan More expensive, less familiar retrofit measures repayments so that there is no overall increase in such as solid wall insulation would enter the household costs. The Green Deal’s ‘Golden Rule’ mainstream. But there were warnings the pace tries to cover this. of work would slow compared to that acheived by 3. Before deciding whether to enter into a CESP and CERT. Green Deal, a household needs sound, credible ECO and the Green Deal form one of main advice and recommendations about what energy planks in the energy and environment policy saving measures it should install and the costs platform of “the greenest government ever”. and likely energy bill savings resulting. It gets Much time and effort has gone into their this from its own personalised Green Deal creation, not only from government and assessment. The deal-making process also gives legislators but from private sector organisations, assurances that the installation work will be councils and NGOs participating in extensive done well and that there is a means of redress if consultation then gearing up to deliver the Green things go wrong. Deal and ECO. But a loan scheme with these three essential features could not, of itself, transform that 1.2 A very slow start shared vision of a great national housing retrofit The Green Deal is in danger of becoming a major into reality. Some additional mechanisms would policy failure. If that happens, the cherished be needed. These are provided through the vision of a revolution in home energy saving will Energy Company Obligation (ECO). quickly become a mirage followed by lost years of One part of ECO (called ‘affordable warmth’ and inaction. ‘carbon saving communities’) covers low income households suffering fuel poverty. Many of these 6
The biggest problem to emerge is that the ‘The vision for the Green Green Deal finance mechanism can only cover a part (and often the smaller part) of a typical Deal and the new ECO household retrofit. Very often, households is an ambitious, far- will have to find much of the money for the installation themselves, defeating one of the reaching one … a world Green Deal’s founding purposes. where the UK leads with Extra loft insulation and regular cavity wall a dynamic new energy insulation can usually be fully covered by the Green Deal, with projected typical energy bill efficiency market, with savings equalling or exceeding the repayments. nationwide brands, But other typical retrofit measures frequently recommended in Green Deal assessments, such local businesses and as replacing a gas-fired central heating boiler with a more efficient model, fall far short of the community organisations Golden Rule. Green Deal finance will only cover competing to deliver the part of their cost. And the ECO carbon reduction scheme, designed to bridge this kind of funding best proposition for the gap, only applies to a small suite of energy-saving consumer.’ measures; it does not cover boilers. DECC consultation on Green Deal, 2011. Furthermore, the types of measures that can be fully financed by the Green Deal tend to be the At the last general election in 2010 the cheaper ones. But households may be loathe to manifestos of all three main parties promised enter a loan arrangement with an APR of some a Green Deal type scheme. During its party 8% lasting at least ten years in order to borrow a conference in October 2013 Labour announced few hundred pounds. that, if elected, it would overhaul the Green Deal In general, major retrofit packages costing and replace it with a new but as yet unspeficied several thousand pounds will only be part- Energy Save scheme. financeable by the Green Deal. The household The most obvious early sign of things going would have to provide at least £1,000 to get the badly wrong is the very low number of Green package installed, obtained either from savings Deal plans actually going through in the first or another loan. For many, that will be a deal- eight months of the scheme. According to DECC breaker. statistics covering the period up to the end of This is the largest of several problems facing October 2013, a mere 1,173 Green Deal plans the Green Deal. We discuss each of them, and were underway for individual households. Only potential solutions and improvements, below. 219 had actually been completed, with the installation work signed off and the repayments The intense political controversy of autumn 2013 having begun. (4) surrounding fast-rising household energy prices casts a shadow over all of the government’s Two years ago, ministers were speaking of 14 energy efficiency and low carbon policies. ECO million homes being covered by 2020. (5) So seemed particularly vulnerable after the Prime these low numbers signing up in the scheme’s Minister’s announcement that he wanted to “roll first year represent a dismally slow start. DECC back” green taxation on energy. has attributed this to Green Deal providers being slow to come forward, with the first of them Yet DECC’s latest estimate is that ECO is adding making finance available to households only only £50 a year, or some 3.5%, to the average from May 2013. But five months on from then, household energy bill of around £1,400.(6) take up remains at a trickle. 7
Its predecessor schemes, CEST and CERP, were Our starting point is that we need the Green estimated to be adding £41 to the average annual Deal and ECO to work well. Government must bill when they ended in 2012. (7) So ECO plays a act to prevent all the time, effort and resources tiny part in recent big increases in bills. expended in creating them going to waste. We share the vision of a great national housing Whether Government decides to fund ECO retrofit set out at the beginning of this report. through general taxation in future, or leaves it to be funded via energy bills, there is no case for To get back on track, the Green Deal itself abandoning or cutting back on a scheme which urgently requires a retrofit, one requiring aims to help the fuel poor keep their homes adaptation and fresh thinking but no major warmer and to help hundreds of thousands of legislation. The Government should launch an households to cut their carbon emissions. improved and updated Green Deal in 2014. Orange ticks and green The most frequently recommended green tick measure (25% of the 96 recommendations) ticks: the Green Deal was for thicker hot water tank jackets, costing funding gap a few dozen pounds. Green tick 18% This is a small sample of properties and it was In Green Deal assessment reports,Orange tick 82% not chosen to be representative.* Even so, the recommended measures that can be fully finding that the overwhelming majority of financed by the Green Deal (typical first year Green Deal recommended measures cannot savings equal or exceed first year repayments) meet the golden rule will apply across Britain’s are given a green trick. Those that can only be housing stock. See page 20 for an excerpt part-financed receive an orange tick, meaning from a Green Deal assessment report which the household would have to make an upfront illustrates how orange ticks dominate. payment. Working with Cherwell District Council as part of a project financed by DECC’s Green Deal Pioneer Places scheme, BioRegional 18% Green tick measures delivered 103 free-of-charge Green Deal assessments to households, in Bicester, Orange tick measures Oxfordshire in the spring of 2013. 82% A total of 523 measures were recommended in the Green Deal advice reports produced by these assessments – an average of just over five measures per property. Of these 96 (18%) Our sample was somewhat more energy efficient that the England average. For energy efficiency rating bands, the were green tick measures and 427 (82%) were distribution was: A&B 1%, C 26%, D 58%, E 12%, F&G orange tick measures. Furthermore, almost a 3%. The England distribution for these bands is 0.2%, fifth (19%) of these green tick measures were 15%, 49%, 28% and 8% respectively. solid wall insulation (internal or external), which would require ECO funding in order for the household to avoid making a large upfront payment. 8
2. Closing the would cover £1,079. So the householder would therefore have to pay for at least £1,121 (or 51%) Green Deal of the costs of the installation upfront. The Government’s temporary Green Deal Cashback scheme would also pay £270 towards the new funding gap boiler, reducing this outlay somewhat. Many have complained that these interest rates An example can be used to illustrate and explain are too high and will stifle the Green Deal. this Green Deal funding gap. Installing a new So imagine that, instead of an 8% APR, the gas-fired condensing boiler might cost £2,200 Government had devised a Green Deal with a and promise ‘typical’ energy bill savings of £100 0% APR. For our boiler example above, a £100 a a year, as set out in the Green Deal advice report year repayment spread over 25 years would cover following an assessment. the £2,200 boiler cost; it would fail to do so if For a typical UK house, £2,200 is at the low end the loan period was any less than 22 years. If, of costs for a boiler installation, while savings however, the estimated annual gas bill savings of £100 a year are towards the high end of were any less than £88 (£88 x 25 = £2,200) the estimated gas bill savings given in Green then even a 25 year loan with a zero interest Deal advice reports. So, for this example, we rate would fail to cover the boiler costs. Our have drawn on our experience of Green Deal experience suggests the estimated typical savings assessments to use typical figures which tend to would often be less than £88. minimise the funding gap.(8) So a long term, interest-free loan would usually Under the ‘Golden Rule’ this savings figure fail to close the Green Deal funding gap for a new of £100 a year sets the maximum repayment boiler, one of the most frequently recommended that can be made in the first year of the Green and cost effective of energy saving measures. Add Deal finance plan; savings would then equal in an interest rate and this gap widens. repayments leaving the household no worse The main cause of this funding gap is the small off. (This estimated saving figure relates to size of the estimated typical energy bill savings a typical household living in that particular achieved by different types of installation property, rather than the actual household. Thus relative to their costs. These estimates are based a large family with more than typical energy on the Reduced data-input Standard Assessment consumption might obtain higher actual energy Procedure (RdSAP) modelling and methodology bill savings after installing the measure.) used to draw up Energy Performance Certificates, Given this limit on the size of Green Deal with further downwards adjustment to make repayments, how much money could actually be them err on the side of caution. loaned under the Green Deal? This depends on These “in use” reduction factors, based on the interest rate used on the loan and how long (sometimes limited) data on actual savings the loan lasts. delivered by the different energy saving The Green Deal Finance Company’s initial measures, generally cut the energy and bill interest rate has been set at 6.96%, but a one saving estimates from RdSAP by 15-35%. off initial loan fee (£63) and an annual finance This tends to widen the funding gap. It is best charge (£20) make the actual APR somewhat that any error should favour caution over excess, higher – the exact figure depends on the size and in order to avoid promising energy savings which length of the loan. For this example assume an fail to materialise. But the estimates provided to effective APR rate of 8%.(9) households in Green Deal assessments need to be At that rate, a £100 per year repayment spread as accurate and robust as possible. over ten years (the minimum Green Deal loan period) would cover a loan of £687. Spread over 25 years (the maximum loan period) it 9
Recommendation : DECC should will not impress the substantial proportion of commission research aimed at gaining households who are able to obtain significantly a better fix what on the typical energy cheaper finance (including via their mortgages) savings actually achieved by the various for a wide variety of goods and services. They are Green Deal measures are, in kilowatt hour, likely to see the finance element of the Green carbon and money terms. This should then Deal as a rather poor deal. feed into improvements in the modelling and methodology used to makes savings This is not to argue that Government should loan estimates in Green Deal Assessments. all or most of the Green Deal finance off its own book. It was always intended that Green Deal But even if improvements in the modelling led finance should flow from private sector investors to slightly more generous estimates of typical via bond issues. Government needs to work with savings, the funding gap would still exist for the finance industry to devise a debt structure boilers and several other principal Green Deal with guarantees which will halve the interest measures. rate. The fact that repayments are made through a levy on a property’s electricity bills, irrespective So a choice has to be made. Government could of who occupies the property, gives relatively accept that the scheme will be unattractive for high security. the great majority of households, and that the Green Deal was not the solution for retrofitting It is worth noting that both the Government the nation’s housing stock that many hoped it and the state-backed Green Investment Bank would be. have already helped finance the GDFC, but only to ensure it had money to lend for retrofits in its Alternatively, it could try to recast the Green early days. Given the very slow initial demand for Deal in ways which make it attractive to millions Green Deal loan packages, the money raised by – rather than thousands – of households. the GDFC seems set to last for years. There are three essential ingredients of such a A long-term element of state backing aimed at Green Deal retrofit – cutting interest rates, bringing down interest rates would leave the encouraging households to enter into Government with additional liabilities. It could the Green Deal without using Green Deal contain its exposure through an annual cap finance and developing a significant, long placed on the total sum of state-backed Green term incentive for home retrofits. Deal finance plans. It could also devise a way of focusing these cheap, low interest loans on less 2.1 Cutting interest rates affluent households. The Government has made major interventions For example, there could be a maximum of to make it easier for house purchasers and small 500,000 state-guaranteed Green Deal finance businesses to borrow money. plans a year. With an average cost for each of Recommendation: Government now needs £6,000, the annual expenditure on retrofitting to guarantee Green Deal loans so as to homes would be £3bn but the government’s reduce the APR to below 4%. exposure would be a small fraction of this. This would shrink the funding gap, but in many Interest rates will have to be lowered if the Green cases it would not close it entirely. It would, Deal is to succeed as a loan scheme. But it also however, give householders a clear signal that has the potential to operate as an assurance and this was a government-backed scheme offering a help scheme, enabling hundreds of thousands highly competitive loan rate. of households a year to install energy saving retrofits without using Green Deal finance. The Green Deal Finance Company (GDFC) justifies its relatively high interest rate on the grounds that some 80% of UK households are able to access its Green Deal finance. But that 10
2.2 Using the Green Deal 2.3 The need for additional, as an assurance and help enduring incentive schemes scheme DECC has made it clear from the outset that the Green Deal Cashback is a temporary incentive A great deal of effort has gone into creating aimed at ‘kick starting’ the scheme. Now, assurances around the Green Deal. Hence however, a more permanent incentive is required there is the ‘Green Deal approved’ branding, to drive retrofits and revive the faltering Green accreditation processes for Green Deal assessors, Deal so as to fulfil its economic, social and providers and installers, a code of practice and environmental potential. Without it the scheme an ombudsman. Together, these aim to give is unlikely to reach more than a few 10,000s of households confidence that they will receive: homes a year (the ECO scheme will treat more, • Reliable information about the most cost- provided it survives) when it should be improving effective energy saving measures they can many hundreds of thousands. install and the likely costs and savings Such an incentive needs to give a strong, clear • Help in finding reliable firms to carry out benefit for improving a home’s energy efficiency. the installation At the same time it could: • Installations done to a high standard, and • Further close the Green Deal funding gap, reassurance that if anything goes wrong it to make it a more attractive loan product. will be put right. • Widen the Green Deal’s appeal as a simple If the Green Deal succeeds in providing all three assurance and help scheme, in addition to it has the potential to be marketed to a segment being a loan scheme. of households purely as an assurance and help • Emphasise that the Green Deal is a scheme; that segment which can finance a Green government backed scheme which Deal package upfront from savings or cheap benefits all of society, not just individual loans (i.e. via a mortgage). This represents a households. substantial proportion of the overall customer base. And there are early signs that it is already At present, the Green Deal is marketed primarily appealing to this segment. as a product to benefit households through a commercial deal between them and the DECC statistics on the Green Deal showed that private sector. It might have wider appeal if an 9.522 ‘Cashback’ vouchers had been issued accompanying message was that the nation and by government by the end of October. These the planet benefit from the Green Deal as well as vouchers help pay for the cost of Green Deal the individual household. installations. To obtain them households must go through the Green Deal process (starting with Each Green Deal installation reduces carbon a Green Deal assessment) but they do not have to emissions, helps protect the environment, take out Green Deal finance. Contrast this figure improves the housing stock and contributes of more than 9,000 with just over 1,000 homes to economic growth and employment. A intending to take out Green Deal finance over the state-backed incentive would be a reward same period. to households for doing some social good, reinforcing that positive message. This, after all, To date, the great majority of households using is the kind of message implicit in the Feed- in the Green Deal are keen to take advantage Tariff scheme for micro-renewables. of the Cashback incentive but do not want or need the loan facility. This also demonstrates Fresh burdens on the Exchequer will be resisted that incentives can play an important role in in a period of austerity and deficit reduction. It is, generating retrofits. however, possible to design incentives which are revenue-neutral or near revenue-netural. In 11
any case, the increased revenue arising from Before describing these incentives, we briefly more Green Deal installations and all the explain the other two incentives proposed by the economic activity accompanying them needs task group. These may have a longer term role in to be factored in; VAT, income tax, national stimulating energy saving retrofits. insurance payments and corporation tax. 2.3.1 Variable Council Tax Government needs to consider options and choose the best value incentives, the ones which Under this proposal, energy-efficient homes are most effective at stimulating additional would receive a discount on their council tax Green Deals and secure the largest energy while energy-inefficient homes would pay some and carbon savings per pound spent. The additional, penalty council tax. The size of chosen incentive can be capped and adjusted this discount or penalty, amounting to the low periodically, as with Feed-in Tariffs, to limit hundreds of pounds at most, would be based government exposure, ensure value for money either on the property’s SAP points or on its and conserve revenue neutrality. Energy Efficiency Rating Band (A to G). Using the latter would make the discount/penalty more For example, incentives for less cost-effective crudely graduated but easier to administer. measures (in terms of expenditure per tonne of carbon saved) should only be given if the more Variable council tax would raise awareness of cost-effective recommended measures are also the energy efficiency of homes. It could be made taken up. A home lacking easy-to-apply and revenue neutral for the councils that run it, with low cost cavity wall insulation would have to the ‘penalty’ tax revenue equalling the ‘discount’ have that installed at the same time as having a revenue. new high efficiency boiler in order to qualify for incentives for the latter. However, many homes still do not have a SAP rating and these tend to be more energy A task group set up by the UK Green Building inefficient. Some mechanism would be required Council considered the question of retrofit which applies the discount/penalty to these incentives in depth, reporting in July 2013. (10) unrated homes in ways which are justifiable and ACE was represented on this task group and this equitable and which encourages owners to obtain section of our report draws on its work. both a rating and an energy saving upgrade. Obtaining a rating requires a stand-alone EPC The group considered a long list of eight types of survey or a Green Deal assessment; both imply a incentive, each scored against 14 criteria. Three cost. of the four top scoring types of incentives were then further developed as workable policies and The impact of a variable council tax on low- presented to government as recommendations. income households would also have to be These three were variable stamp duty (which the addressed. Those who live in a relatively energy Committee on Climate Change has advocated), inefficient homes and pay council tax would find variable council tax and an energy efficiency their tax bill increasing sharply but be unable Feed-in Tariff. The task group is now asking to afford the energy saving upgrade required to government to do further work on these reduce it. The Green Deal could only help them if proposals and implement at least one of the the funding gap was closed. incentives. This incentive would also have to be adjusted We believe variable stamp duty could provide every few years in order to maintain revenue strong support for a revised Green Deal. We also neutrality. As more and more homes underwent favour a Green Deal grant which, in essence, energy saving retrofits and lowered their council would mean that the government’s existing tax bill, the SAP score or energy efficiency rating Cashback scheme became a more permanent band which served as the neutral balance point fixture. Such a grant scheme could be seen as one (higher scores earn the discount, lower scores version of an energy efficiency Feed-in Tariff, but face the penalty) would have to be gradually with all of the tariff payments lumped into one shifted upwards. upfront payment. 12
2.3.2 Energy efficiency Feed-in Tariff on their stamp duty land tax (SDLT) while those purchasing a relatively energy wasteful house Regular payments would be made to households would pay extra SDLT; a penalty. This could be for the energy and carbon they saved following used to make this incentive revenue neutral for a retrofit. These payments for ‘negawatts’ would the Treasury. The size of the incentive/penalty be based either on estimated (deemed) energy would be based on the property’s SAP rating, as savings or actual, measured savings compared set out in its Energy Performance Certificate. to the household’s baseline energy consumption before the retrofit. In a worked example, the task group’s report shows the purchaser of a £280,000 house at It might be argued that no retrofit was the bottom of Energy Efficiency Rating Band actually required to qualify for this kind of D (55 SAP points) having to pay extra ‘penalty’ energy efficiency feed-in tariff; instead, a SDLT of £1,200 above what it would otherwise household could simply pledge to cut its energy be (£8,400).In contrast, the purchasers of an consumption and be paid according to results. energy-efficient, £465,000 new-build home with But people could then game the system; parents 84 SAP points in Band B would gain a £2,000 who knew their grown up children were leaving discount on their baseline SDLT of just under home could enter the scheme just before they £14,000. left. The task group’s report shows that such a scheme This scheme could be costly – the task group’s could be fairly simple to administer. Variable modelling suggests a range of £52m to £273m stamp duty would sharply raise awareness of per annum. It would have to be financed by energy efficiency among prospective home taxpayers or energy bill payers (via a modified buyers, sellers and estate agents. Variable vehicle ECO scheme), with no prospect of revenue excise duty (the ‘tax disc’) based on car carbon neutrality for the Treasury. emissions has already proved itself a successful policy, lowering vehicle fuel consumption and It might be quite difficult to justify such a emissions while enjoying public acceptance. The scheme to the public (who might ask: “Why government should take heart and confidence should taxpayers/energy consumers pay money from that. to people who are already reducing their energy bills?”). The modelled benefits of additional Variable stamp duty would encourage a small retrofits, GDP and CO2 savings are all rather proportion of prospective house sellers to carry lower than for variable stamp duty and variable out retrofits, in the hope that the resulting SDLT council tax. discount would make their home easier to sell at the desired price. However, if the energy efficiency feed-in tariff succeeded in delivering the promised long-term More importantly, it could stimulate many more reductions in energy demand, it would cut costs post-purchase retrofits. The idea here is that for all energy bill payers by reducing the need to house purchasers who chose to improve the invest in costly new gas and electricity supply energy efficiency of their new home could then infrastructure. claim the appropriate SDLT discount based on their homes’ new, higher SAP rating (provided One important point to consider is that neither the retrofit was done with a year of purchase). a variable council tax nor an energy-efficiency Home improvement projects often follow a house feed-in tariff do anything to help close the Green purchase and these can readily be combined with Deal funding gap, because they only offer small an energy-saving retrofit in order to minimise but regular payments or discounts after a retrofit disruption and secure savings in the costs of the rather than upfront. combined works. 2.4 Variable Stamp Duty If the SDLT discount proved popular among buy-to-let purchasers, it would help to raise the Under this proposal, people buying a more generally very low energy efficiency standards in energy efficient home would receive a discount the private rented sector. 13
This variable stamp duty incentive proposal does once, upfront. Paying housholds in return have some drawbacks. It is only of interest to for them delivering long-term reductions in a segment of households likely to buy or sell a energy demand and carbon emissions has one home in the next few years. But this is a large obvious justification. (11) It can cut costs for segment, given that more than 900,000 homes all energy bill payers by reducing the need to are sold in the UK each year. invest in major new gas and electricity supply infrastructure. If, as seems likely, most of the retrofits it stimulates were post-purchase ones that would It can also act as a retrofit incentive for those undermine its revenue neutrality for the households able to organise their own finance Treasury because all these households would but still wanting to use the Green Deal process to claim the SDLT rebate. make energy-saving improvements, starting with an assessment. The existing Cashback scheme Variable stamp duty would be bound to face succeeded in stimulating more than 9,000 of some opposition; from prospective sellers living these ‘self-financed’ Green Deal packages in a few in energy-inefficient homes and people wanting months. to buy older homes, which tend to have lower SAP ratings. Both would be hostile to the penalty Such a grant scheme offers simplicity in terms side of the scheme. The more the Treasury tried of administration and fraud prevention, since it to protect revenue neutrality, the larger this requires only one payment. Grants would only penalty element would have to be. be made to households with retrofits based on Green Deal assessments recommending plausible According to modelling commissioned by the energy saving installations task group, it would stimulate 135,000 to 270,000 additional retrofits a year, increase GDP As with the existing Cashback, the grant would by £404m to £807m a year and achieve annual be based on standard payments for each different CO2 savings of 209,000 to 417,000 tonnes a year. type of measure. Within this framework, there is scope to fine tune a Green Deal grant scheme Variable stamp duty would stimulate additional to limit overall costs (by capping total annual retrofits, but it would not of itself close the Green expenditure), to maximise cost effectiveness Deal funding gap. In most cases, a newly moved- (per unit of energy/carbon saved), to encourage in household which wanted a Green Deal loan take up by lower income groups and minimise in order to claim a stamp duty rebate would still deadweight losses (avoiding paying towards find itself having to provide part of the finance installations which householders would have upfront. But at least it could recover some or all funded in any case). of this initial outlay (and even pay off some of the Green Deal loan early) when the rebate was For example, the grant might only apply to paid. ‘orange tick’ recommended measures (see pages 8 and 20) and be paid over only if recommended 2.5 Converting the Cashback ‘green tick’ measures were also installed as part of the package. into a Green Deal grant Such a scheme could be funded directly by A permanent Cashback scheme (or one that government of via ECO, although the latter was guaranteed to last for several years) would seems unlikely given the controversy over fast- convert it into a grant scheme helping to finance rising energy bills. If the grant was applied to energy saving retrofits. For households interested 400,000 homes a year, at an average cost of in using Green Deal finance, these grants would £300 each, total annual expenditure (excluding help close the funding gap created by the Golden administration costs) would be £120m. This is Rule. close to the £125m set aside for the existing Such a grant is equivalent to an energy efficiency Green Deal Cashback scheme, only a tiny portion feed-in tariff discussed above, but paid only of which has so far been spent. 14
It is also small in comparison with government In essence, the proposal is that when a home estimates for the total annual ECO costs of £1.3 undergoes significant building work which, bn. The UK Green Building Council’s task group all things being equal, would raise its energy did not select a Green Deal grant as among the consumption, then the entire property would most promising retrofit incentives. Our view is have to meet minimum energy efficiency that it should be a front runner. standards in order to receive the building regulations approval required for the work. For Recommendation: Government should example, the fabric of a proposed extension assess variable stamp duty and Green would have to comply with building regulations Deal grants as incentives for household and the rest of the house would also have to be retrofits, then deploy one or both of these improved (the consequential improvements) if, for at least three years. say, it lacked adequate loft insulation or cavity Government has the resources and the policy wall insulation. appraisal process required to devise an incentive, This is a way of controlling the rise in energy or combination of incentives, which offers best demand and carbon emissions caused by home value for money while securing hundreds of improvements. But it would tend to increase thousands of retrofits each year. the upfront cost of major home improvement projects – hence hostile press campaigning 2.6 Sticks and carrots – the against a “conservatory tax” which persuaded case for ‘consequential government to drop the proposal. improvements’ The Green Deal offers a way round the problem. A Green Deal loan could cover any extra costs Regulation could also be used to drive household resulting from “consequential improvements” retrofits, at least in theory. The most obvious and leave the household no worse off provided way to do this would be to compel existing the annual energy bill savings resulting from the homes to meet minimum energy efficiency overall retrofit equalled or exceeded the annual standards before going on sale (for example, Green Deal repayment. they would have to be above bands F and G). The Government has said it intends to ensure all But this will not always be the case with the private rented properties achieve such minimum Green Deal in its present form, because of the standards after 2018. funding gap issue outlined in this report. What is needed is an incentive to close that gap. Such regulatory ‘sticks’ are easier to justify if there are also carrots – incentives of the kind Recommendation: A Green Deal incentive discussed above. Even so, the UK GBC’s task along the lines we propose would group decided that introducing minimum legal strengthen the case for ‘consequential energy efficiency standards for existing homes improvements’ measures in the at point of sale was a political impossibility. That Building Regulations. This means that judgement is sound. if approval is sought for any alteration or extension which would increase a There is, however, one regulatory ‘stick’ driving home’s energy demand, then the overall retrofits which the Government had intended energy efficiency of the property has to deploy but then abandoned. This is the so- to be improved in order to offset this called ‘consequential improvements’ measures increase. Home improvement works, which would have been part of the latest revision along with house purchases, are the of Part L of the Building Regulations covering most important opportunity points for energy conservation. For several successive householders to make major energy revisions of the regulations, governments have efficiency improvements. Consequential begun considering such measures then decided improvements should be introduced into not to proceed with them. the Building Regulations once a Green Deal incentive is deployed. 15
3. Further a first step. And an installer acting without a Green Deal provider would be obliged to offer the opportunities and same level of assurance, guarantees and means to address complaints and resolve disputes as a provider. better assessments Recommendation: Accredited Green Deal installers should be able to offer There are several other ways in which the Green unfinanced Green Deal packages to Deal could be improved in order to fulfil its households without a Green Deal provider potential. being involved, provided appropriate safeguards are introduced. 3.1 Increasing opportunities for smaller traders 3.2 The Green Deal street It was always hoped that the Green Deal would by street provide abundant additional work for small If several households in one street took out a firms and sole traders – builders, plumbers, Green Deal at the same time, this could offer glazing installers, electricians and so on. Having them several advantages. obtained the necessary Green Deal accreditation, they would become Green Deal installers and • They could share information with each carry out the bulk of the energy efficiency other about retrofits – the various possible retrofits across the UK. measures and likely costs and benefits, all the more so if they had the same type of However, these Green Deal installers need to house. be linked to Green Deal providers, the larger (generally) organisations which draw up Green • They might be able to bargain as a group Deal finance plans and sign agreements with with Green Deal installers/providers, individual households. Installers cannot offer obtaining a better price for the work. Green Deal packages on their own. • Working on several properties in one But it is now clear that many of the households location, either simultaneously or who might benefit from the Green Deal will sequentially, would provide the installer not want to opt for Green Deal finance. And if with economies of scale and continuity of households choose not to use this finance, then work, in turn allowing better margins and/ they should not be compelled to use a Green Deal or lower prices. provider for their package. Instead, they should be able to deal direct with accredited Green Deal Recommendation: Government should installers. This would encourage small traders to explore the potential for a street-level market unfinanced Green Deals, along with any Green Deal incentive, administered by government-backed incentive, direct to potential local councils, aimed at encouraging local customers. groups of neighbours to club together in organising Green Deal retrofits. Small traders should be able to improve their own margins on Green Deal work as a result of DECC has made a start with its £20m Green Deal this freedom. This change might also encourage Communities scheme launched in July 2013. It many more of them to be interested in the needs to build on the learning from this in 2014. scheme, and to make links with (or become) (12) Green Deal assessors. Green Deal providers would still be free to offer unfinanced as well as 3.3 Free Green Deal financed Green Deal packages. assessments Some safeguards are necessary. Households A Green Deal assessment, carried out by a choosing to deal direct with an installer would certified assessor who visits the property, is the still have to obtain a Green Deal assessment as 16
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