Retrofitting the Green Deal

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Retrofitting the Green Deal
Retrofitting
the Green Deal

                 1
Retrofitting the Green Deal
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

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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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