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Energy Saving Trust's views on the ECO3 consultation

We need urgent infrastructure investment in home energy efficiency in England. But if ECO is all we’ve got, it should be targeted at fuel poor households.

The ECO3 consultation asks if we agree the programme should focus 100% on affordable warmth, targeting people in fuel poverty. 

Energy Saving Trust is deeply concerned about the overall scale of the investment in home energy efficiency in England. Current and planned levels of investment do not align with the government’s ambitious targets to bring all fuel poor households to a minimum EPC “C” standard by 2030, nor for bringing all homes to EPC “C” by 2035. We believe the government should be working on building private sector finance for energy efficiency, but also making a large scale public infrastructure investment in our homes. An energy supplier obligation –like ECO – is one way of funding that investment. But we don’t believe a supplier obligation should be the dominant part of the future funding mix, as we explain in our white paper on fuel poverty funding.

BUT while ECO remains the only publicly mandated funding stream for home energy efficiency in England, we agree that it has to remain focused on the people who most need help with their energy bills.

It’s good that ECO will include an innovation element. But it can’t just support innovation in products and processes – it must also support innovation around engaging people with the energy efficiency opportunity​

We welcome the plans for ECO to provide funding for innovative measures. Millions of homes have now benefited from cost-effective energy efficiency measures using current technologies – like standard cavity wall insulation. If we’re going to continue to make significant progress on home energy efficiency, we need new cost-effective products and services that enable households to save energy in new ways, through the 2020s.

Currently, the proposals seem to be that ECO innovation funding will only provide money to trial new technologies and new processes for installing technologies. But Energy Saving Trust is calling for ECO innovation to also support new ways of engaging people with the opportunity to improve the energy efficiency of their home.

A core “market failure” of energy efficiency is that people don’t identify and value the long term benefits it can bring. Energy efficiency is also often difficult and complicated: low income households in particular may find it difficult to allocate the time, money and energy to access help to improve their home and reduce bills.  Many households, who already have double glazing and a reasonably modern boiler, may simply feel that they have already done their bit on energy efficiency.

New tools and engagement techniques can help households identify the potential for their family to benefit from energy efficiency services. For example, our innovative SMAP service will use smart meter data to help Scottish households to see how much their family can save from different energy efficiency measures. That’s a service we’re developing, and we’re just one of many organisations and companies coming up with new digital ideas in this area.  Innovative engagement techniques could also target groups of households and home owners– for example landlords and tenants in the private rented sector. The private rented sector has the highest fuel poverty but also historically the lowest level of support from ECO.  And, finally, specialist engagement services may be needed to reach the most vulnerable customers, for example people living with mental health problems.

Scoring innovative engagement approaches under the current ECO scoring system which is used to allocate funding will be difficult. But to do so is vital, particularly if we are to find ways to reach homes that most need support.

……And innovation around energy saving advice as measures are installed​

Results from a recent pilot study in Scotland showed that as many as 30% of households find that their properties become too warm following the installation of energy efficiency measures. These households are still using their heating systems as they would have before the measures were installed.  Because they haven’t received advice at the time the improvements were installed, they’re continuing to waste energy.

Different ways of providing advice as measures are installed needs to be supported under ECO innovation support. This will ensure that the predicted fuel bill and CO2 savings are delivered in practice.

Innovative measures supported under ECO needs to be based on real evidence of how people interact with measures in homes.

If we’re going to achieve home energy efficiency targets we need new cost-effective products and services that enable households to save as much energy as possible. But those innovative measures must really work in homes. We’ve heard too many stories of energy efficiency installations that end up causing problems for households: unexpected damp issues, or heating controls that residents don’t know how to use.  The tragedy of Grenfell Tower also shows how we need to be absolutely confident about building renovation technologies and processes from a health and safety perspective.

In the ECO consultation, the government is proposing to monitor performance of innovative measures using the National Energy Efficiency Data framework (NEED) – a large scale database where real energy bills for homes can be analysed against the measures that have been installed in those homes. We know that this can allow a statistically robust analysis of the performance of measures across large samples of homes, but understand that this process could take two or more years.  EST believes that in-situ field trials should be at the centre of monitoring the innovation products and processes supported under ECO from the start of the programme. As well as energy savings, these trials should assess the impact of new technologies and processes on home temperatures, how people use the measures, and unexpected consequences, such as moisture and damp. In-situ trials will also allow evaluation of the householder experience, both in terms of the performance of the measures and the installation process.

Our preliminary response to the consultation can be read here.

If you have comments or questions please direct them to owain.jones@est.org.uk.