eco guidance consultation response final · kingfisher future homes ltd eco guidance consultation...

Kingfisher Future Homes Ltd., registered in England number: 3926841 Registered office: 3 Sheldon Square, Paddington, London W2 6PX VAT registration number: 232555575

B&Q House, Chestnut Avenue, Chandlers Ford Eastleigh, Hampshire SO53 3LE

ECO Team Ofgem 9 Millbank London SW1P 3GE

ECO 2012 – 2015 Guidance for Suppliers Consultation Response

We welcome the opportunity to respond to this consultation and our comments are attached.

We would like to highlight how much we have appreciated the open and consultative approach adopted by both DECC and Ofgem to the development of ECO. There are numerous stakeholders with a direct interest and we have been impressed with the approach taken to engaging with them. In particular, we have welcomed the opportunity for those organisations involved in the delivery of ECO, rather than just those directly subject to the obligation, to contribute both to the high level design and to the development of technical implementation detail. Whilst our comments in response to the questions in the Consultation do not always support the proposed approach, our recommendations and suggestions are generally for relatively minor changes that we believe will help to improve operational delivery, rather than querying the direction or approach.

We look forward to continuing to work with DECC and Ofgem and will continue to offer whatever support we can in order to help ensure the success and cost-‐effectiveness of ECO in delivering its challenging objectives.

Yours sincerely

Brian Scannell Head of Policy & Compliance

25 January, 2013

Kingfisher Future Homes Ltd

eco guidance consultation response final.docx of 15 Version saved on 25 January, 2013 at 3:14 pm

Kingfisher Future Homes Ltd., registered in England no: 3926841. VAT registered no: 232555575

1. Background to ECO

Question 1: Do you agree with our proposed ‘date of effect’ of the final guidance? If not, please suggest a different approach and explain your reasons for this?

No, we do not believe that the proposed date of effect is viable. It will be completely impossible to implement any changes to systems or processes in that time, particularly if they impact on data collection or reporting requirements.

We recommend changing the ‘date of effect’ to “the first day of the first month which occurs SIX weeks or more after the date on which the guidance is published”. This will ensure a minimum period of six weeks and a maximum period of 10 weeks for the Guidance to come into force. We consider this a tight but achievable timetable to implement any changes to training, processes or systems.

Question 2: Whilst ECO brokerage is not currently mandated what, if any, areas of additional detail should be considered to avoid complications for the Brokerage mechanism?

We don’t believe at this stage that the brokerage should be mandated.

The process of open dialogue and working groups that DECC have run in developing ECO and Green Deal has provided a much greater level of transparency than has been achieved in previous obligations which is to be welcomed.

Areas where additional detail should be considered are around the ability for participants to game the outcomes of the brokerage. Overall we have a number of concerns about the brokerage solution DECC have implemented as a solution to ensuring open access to ECO funding for Green Deal Providers. Our specific issues around brokerage are:

• There is some potential for pricing to be managed as buyers could use the system only to take lowest priced opportunities in the brokerage in an attempt to keep wider market prices down. Brokerage prices will be the only ones that are truly visible to the general ECO market and, therefore, there could be wider interest in finding ways to suppress the brokerage price. This could have quite far reaching effects on the ECO market overall, influencing bi-‐lateral and brokered ECO work. There will also be potential opportunities for buyers to tactically play the market thereby creating a high degree of uncertainty and volatility

• A lack of any trading experience for most if not all GDPs puts them at a distinct disadvantage in operating effectively in the brokerage

• Sellers or internal businesses may identify themselves to preferred partners/ parent companies thereby affecting true pricing and openness of brokerage

• Size of lots etc will mean, over time, sellers aren’t totally blind to buyers, this could have a detrimental effect on fair pricing and potentially disadvantage smaller players




• There is a risk of there not being enough buyers, or of the market being constrained by artificially lowered prices in the brokerage and of participants falling out of active involvement in ECO.

• Practically there are a number of methods that can be used to undermine the brokerage system. For example, there is a risk of unfair behaviour where bids may be withdrawn within 30 mins of the relevant deadline so the seller has to take a lower price at the last minute

• There is a risk any auction being flooded with ECO measures by providers with greater capacity -‐ light bulbs in CERT being a good parallel, as fewer participants were able to access CERT funding than would otherwise could have been the case while 128 million light bulbs were given away

• We would welcome strengthened and more rapid recourse mechanisms if the brokerage principles don’t work

We would encourage both DECC and Ofgem to keep a close eye on the operation of the market for ECO measures and funding and would encourage them to retain powers to intervene quickly whilst the ECO market is establishing itself.

Question 3: We have stated that, where a supplier funds all or part of the installation of a measure, we will be satisfied that a supplier has ‘promoted’ a measure. Do you think that this is a sufficient test for promotion, or should we include additional criteria?

For example, where an extension is being built to a property, or an occupied property is being renovated, should we only award a score to measures that are installed and that exceed building regulations? Also, should we only award the portion of the carbon or cost saving that exceeds building regulations?

We support the proposition that the provision of financial support should be taken as de facto ‘promotion’ of the measure in the vast majority of instances. We believe that any requirement for greater direct involvement on the part of the obligated supplier is likely to constrain the development of the market, restrict consumer choice and impose higher costs.

We also support the principle of adopting a broad interpretation of promotion, enabling support for the widest range of activities to improve the energy efficiency of domestic buildings. However, we recommend that the additionality principle should be applied, with ECO attributable savings calculated on the basis of savings over and above compliance with Building Regulations. This will avoid any preferential treatment relative to other improvement options.

For developments that increase total energy consumption, such as property extensions or conversions, we have concerns that the development of appropriate rules for implementing additionality and auditing compliance could divert resources from other activities and may be disproportionate given the incremental savings available on projects of this type. It may therefore be necessary to exclude such projects on pragmatic grounds.




We believe that there is a stronger argument for ECO support to encourage exceeding Building Regulations requirements when undertaking whole-‐house refurbishment. The additional savings attributable to the higher standards adopted will also be more readily evidenced and are likely to be more significant as they affect the entire property rather than just part. We therefore support recognising ECO support for whole house refurbishment as a qualifying measure.

Overall, we believe that ECO support will be most effective if it is focused on encouraging improvement to the energy efficiency of existing dwellings. We expect the market will recognise property developments and refurbishments as potential trigger points for improvements to the property, without any requirement for additional incentives or mechanisms.

Question 4: Do you think that the installation and technical standards required by us under ECO are sufficient? If not, which other standards would be more appropriate and why?

No, we do not agree with the proposed installation standards.

We recommend the full adoption of PAS 2030:2012 for all installations and technologies. Where a measure is not currently covered by PAS, the industry should have a time-‐limited window (say 12 months) during which installations are allowed against Building Regulations, whilst the industry works to ensure that the measure is covered by PAS. If at the end of the agreed period appropriate standards for installation and competence have not been adopted within PAS, then the measure should be withdrawn from ECO.

Question 5: Do you agree that we should only require suppliers to comply with the measure-‐specific annexes in PAS, or should we require suppliers to comply with PAS in its entirety? If the latter, please explain why.

No, we do not agree with the current proposals. We feel that the current proposals risk creating complexity and uncertainty and undermine efforts to improve standards in the energy efficiency industry.

For example it is unclear how a company could demonstrate that installations are being carried out “in accordance with the provisions of the relevant annex of PAS” other than by either being certified to PAS 2030 or creating an equivalently independent and impartial framework. Such uncertainty creates a potential risk that companies will seek to gain a competitive advantage by reducing the standards that they work to. Were this to happen – in reality or purely in perception–there is a risk of a “race to the bottom” in quality terms, to the severe detriment of ECO and the wider energy efficiency industry. Installation quality concerns have directly contributed to the adoption and the level of In Use Factors. We believe that ECO provides an ideal opportunity to tackle these concerns by developing and promoting consistently high standards across the industry.




We recommend the full adoption of PAS certification for all installers wishing to access ECO support.

2. Carbon Emissions Reduction Obligation

Question 6: Please provide your views on our definition of, and evidential requirements for, hard-‐to-‐treat cavities. In particular:

-‐ Cavities which are not suitable to insulate with standard insulation materials or techniques

-‐ Substantial remedial works

-‐ The requirement for a chartered surveyor’s report for the insulation of natural stone cavity walls

With more than 75% of the remaining uninsulated cavities identified as being hard-‐to-‐treat1 it is critically important that no artificial barriers are constructed that would undermine tackling this potential.

We are concerned that the current proposals risk doing so, undermining the development of effective solutions for the hard-‐to-‐treat cavity wall insulation market by adding delays, uncertainty and unnecessary costs into the process.

For example, given the four ‘work hours‘ definition of substantial, it is inevitable that the cost of the chartered surveyor’s report will greatly exceed the cost of the remedial measures. The additional cost and delay will simply serve to reduce the overall cost effectiveness of the programme, thereby reducing the number of properties helped. We believe that a simpler, less bureaucratic approach can be achieved by adopting a similar approach to the boiler repair/replacement worksheet, recognising that the key expertise relating to cavity wall insulation lies with the installer community.

We support the existing proposals in respect of hard-‐to-‐treat cavity walls that do not specifically require a chartered surveyor report; specifically:

• 5.15 (a) – cavity walls in a building with three or more storeys;

• 5.15 (d) – cavity walls with an available cavity of less than 50mm; and

• 5.15 (e) – cavity walls in homes of pre-‐fabricated concrete construction or with metal frame cavity walls or other non-‐traditional construction [NB the reference to paragraph 5.19 in sub-‐paragraph ii is presumably an error and requires clarification]

However, we recommend an alternative approach to replace 5.15 (b) and (c), so that a cavity wall insulation measure is classified as a qualifying hard-‐to-‐treat cavity wall insulation installation if:

• The insulant used is specifically intended for use on non-‐standard cavities; and

1 DECC Statistical Release – Estimates of Home Insulation Levels in Great Britain, July 2012 see: https://www.decc.gov.uk/assets/decc/11/stats/energy/energy-‐efficiency/6472-‐stats-‐release-‐estimates-‐home-‐ins-‐jul2012.pdf




• A PAS 2030 certified installer completes a standard checklist identifying the reason(s) for the wall being characterised as hard-‐to-‐treat e.g. exposure, poor brickwork, the requirement for remedial works, or the wall consisting of an outer leaf that includes more than 50% stone.

• All reports must be supported by photographic and other evidence e.g. a schedule of remedial work undertaken, and subject to Ofgem audit (and potential over-‐ruling) as per the boiler checklist. The independent technical monitoring should also help to minimise the risk of “standard” CWI being presented as hard-‐to-‐treat.

We believe that this approach will help to ensure that ECO is effective in supporting the development of the hard-‐to-‐treat cavity wall insulation market.

3. Carbon Saving Community Obligation

Question 7: Please provide your views on our interpretation of the requirement for walls and lofts to be insulated before district heating connections can be installed.

We recommend that wherever technically possible both lofts and cavity walls (including hard-‐to-‐treat cavity walls) are required to be insulated as a pre-‐condition for the connection to a district heating scheme to be considered as a qualifying measure.

4. Home Heating Cost Reduction Obligation

Question 8: What are your views on our approach to qualifying boilers set out in Appendix 2? In particular: our definition of a boiler, warranty requirements, and methodology to evidence the boiler being repaired or replaced.

We support the key principles of the proposals as providing a pragmatic solution. In particular, we support the definition of all boilers with an efficiency of less than 86% that are broken or not functioning efficiently as being beyond economic repair. This will ensure that supported households are provided with an efficient heating system with a robust warranty, thereby helping to mitigate their risk of fuel poverty.

We also support the boiler checklist approach to evaluating whether a repair is economically justified. However, we are concerned that the definition of “not functioning efficiently” is inherently problematic and we recognise a potential difficulty in achieving an acceptable level of consistency in assessments.

This is a particular concern given the potential for Ofgem to over-‐rule the competent person’s judgement. Were this to happen it would undermine suppliers’ confidence in this measure, potentially resulting in suppliers declining to support repairs and the prospect of eligible households being unable to access support.

We would therefore recommend that the threat of Ofgem determining that the repair was not a qualifying repair be waived, pending the outcome of early stage technical monitoring. This could result in improved guidance and, if appropriate, the




reintroduction of the option to wholly or partially discount the ECO score claimed for a boiler repair or replacement. We also recommend that all boilers identified as having a seasonal efficiency of 75% or less be regarded as “not functioning efficiently”, so that their replacement would be recognised as a qualifying boiler replacement measure. The simple design of many older boilers means that they can continue to operate without incident -‐ the only problem being that much of the fuel they use is wasted. These old and inefficient boilers are unsuited to the task of providing space and water heating in the homes of vulnerable groups and should be recognised as qualifying boilers under ECO.

The two specific elements of the Guidance that we consider unworkable are:

• The requirement that the same operative carry out both the boiler assessment and any repair or replacement (section 3.1); and

• The requirement for a qualifying repair to provide a warranty covering the entire boiler (as defined) rather than just the elements repaired.

We consider it to be impractical and counter-‐productive to require that the same operative undertake the boiler assessment and any resulting repair or replacement. The varying skills of individuals mean that operating in this way would be highly inefficient, increasing costs unnecessarily. In particular, many of the operatives qualified and competent to install a replacement boiler would not be competent to undertake the assessment of repair costs and complete the checklist.

We therefore recommend that the requirement for the same operative to undertake both the boiler assessment and any resulting repair or replacement be dropped.

Our concern in respect of the warranty requirement is the risk that the cost drives up the cost of the boiler repair to the point where it is not cost-‐effective as an ECO measure. If suppliers choose not to offer this measure, it will mean that eligible households are left with a boiler that is potentially efficient but which they cannot afford to repair it nor can they get the repair done under ECO. There is a risk that this could result in pressure being placed on the operative undertaking the assessment to determine the boiler as being beyond economic repair. Worse still would be if householders acted to place the boiler beyond economic repair, potentially endangering themselves as well as undermining the cost effective delivery of the ECO. We therefore recommend that the requirement for the warranty to cover the entire boiler (as defined) be dropped.

Question 9: What do you consider to be the expected cost of providing a one-‐year and two-‐year warranty in respect of a repaired qualifying boiler?

We have had discussions with potential providers about the warranty requirements as currently specified. They have raised a number of concerns:

• Warranties are insurance products that are subject to specific regulation in respect of in-‐home and related sales. These issues have separately been identified in respect of the warranty requirements for Green Deal and they




remain a serious concern. Our advisors continue to recommend the option of an insurance backed guarantee as being a more appropriate product.

• In order to be able to provide cover for the complete boiler, it is likely that a full service will need to be undertaken on the existing system, including system flushing. This will add directly to the initial cost, as well as increasing the likelihood of additional works being necessary as part of the initial repair.

• The cost of providing cover for the complete boiler rather than just the parts replaced will depend on the make and model of the boiler, significantly complicating the assessment process.

Our preliminary assessment is that the direct and consequential costs of providing a warranty as required will run into several hundred pounds per repair, making the repair measure non cost-‐effective in terms of the ECO score.

Question 10: Do you feel that our approach for evidencing AWG eligibility is appropriate? If not, can you suggest an alternative to this approach?

We are concerned that the proposed approach requires the capture, processing and retention for audit of substantial amounts of sensitive personal data, including health-‐related data that is subject to specific levels of additional protection. We are particularly concerned about the proposed requirement to take copies of benefits letters and supporting information.

We are also concerned that the complexity of determining whether an individual is in receipt of one or more of the qualifying benefits. The level of complexity creates a significant risk of errors being made, both of excluding qualified individuals and vice versa.

Whilst rigorous training and robust data management practices can mitigate the risk of errors and data protection problems, such risk cannot be eliminated completely. We also recognise the requirement to minimise the risk of errors and fraud and therefore the necessity of an adequate evidence trail.

We recommend that all assessment of AWG eligibility be done via the service being developed with DWP for use by the Energy Saving Advice Service (ESAS). If it is possible for ESAS to verify a customer’s eligibility when the customer contacts them directly, then it should be equally possible to make the service available to prospective customers contacting other organisations.

One relatively simple option would be to provide a service allowing third-‐party organisations to transfer a telephone call with a customer through to ESAS, who would then go through the validation process with the customer. They would then pass the customer back and provide the organisation with a reference number for the customer for audit purposes.

The organisation would still have to verify and evidence the residency of the AWG person at the property and verify and evidence the householder requirements. However this would completely eliminate the need to hold individuals’ health or benefits-‐related data.




We would anticipate that use of the service would be restricted to specific organisations to ensure that the service is used appropriately. One possibility would be to allow access for Green Deal Providers, who have already signed up to the code of conduct. An alternative might be to limit access to organisations who have signed up for the brokerage scheme.

In summary, we strongly recommend that the requirements for verifying and evidencing AWG eligibility be revised to reduce the necessity to hold and transfer highly sensitive personal data.

Question 11: Do you feel that our approach for evidencing ‘householder’ is appropriate? If not, can you suggest an alternative, or robust proxy, to this approach?

We are concerned by the cost and complexity of the householder requirement and the practicality of verifying and evidencing compliance, particularly given the different requirements in England, Wales and Scotland. As we understand it, the objective of the householder requirement is to ensure that support is directed towards private sector housing, both owner-‐occupied and private rental. We are also concerned that the requirement for the householder to be resident in the property will exclude some AWG eligible individuals from receiving the intended support. For example, if the property is rented by a relative of the AWG eligible individual on their behalf in order to satisfy landlord credit requirements.

We recommend revising the householder requirement, so that suppliers only need to demonstrate that the property is not owned by a public authority or registered social landlord.

We also recommend removing the residency requirement for the householder, requiring only that the AWG eligible individual is resident at the property.

5. Calculating Savings

Question 12: What are your views on our approach to how suppliers must utilise SAP, RdSAP and associated software?

We strongly support the requirement for the property specific calculation of attributable savings based on SAP and RdSAP, the national calculation methodology.

However, we do have a number of recommendations which we believe would improve the overall framework, including:

• Integration of ECO requirements into the SAP/RdSAP specification and software approval framework;

• A requirement to lodge EPC for all HHCRO assessments in order to provide an audit trail for input data;




• Revising the definition of “not functioning efficiently” to include all boilers with a nominal seasonal efficiency of 75% or less;

• Extending the use of product-‐specific data in savings calculations to products other than boilers; and

• Introducing product-‐specific lifetimes and IUF for savings calculations. Each of these recommendations is considered further below.

The existing approval framework for SAP/RdSAP software is designed for the purpose of verifying the correct implementation of SAP and RdSAP for EPC purposes. The RdSAP specification has recently been extended to include the requirements for producing Green Deal occupancy assessment and advice reports. This has necessitated a separate software approval framework.

We note the point in 8.46 relating to bespoke ECO software. The implication is that existing approved software can be used without revision; we do not believe that this is correct. There are specific requirements for ECO calculations, for example:

• The calculation of measure-‐specific carbon emission savings to kg precision;

• The specific calculation of ECO scores using the correct lifetimes and IUF; and

• The need to do specific before and after calculations for individual measures, using the same PCDF file based on the date of assessment or the date of installation.

Which would not be incorporated into existing software and would not be checked as part of the current software approval framework.

There are also specific issues that need to be addressed in the RdSAP specification to cover likely scenarios under ECO. For example, the standard RdSAP inputs assume that if solid wall insulation is applied to a cavity wall, then the cavity will always be filled first. Similarly, solid wall insulation is input to RdSAP on the basis of the equivalent thickness of mineral fibre insulation, creating the possibility of errors and the potential for confusion. We therefore recommend that the SAP / RdSAP specifications be extended to ensure that they incorporate the requirements of ECO and a specific software approval framework be established verifying that software is ECO compliant. This follows the existing approach adopted for Green Deal.

We doubt that the suggestion in 8.55 that suppliers “use accredited SAP and RdSAP assessors for their calculations” is viable in many instances. We consider it to be essential that an accredited assessor does the initial assessment of the property and we strongly recommend that an EPC be lodged for that initial assessment to ensure that the survey is done within a formal quality framework in order to provide confidence in the input data upon which all subsequent calculations are based. However, the subsequent calculation of the savings associated with individual measure installations will in general be automated and driven by data on completed installations. Given the notification requirements, manual recalculation is unlikely to be operationally feasible other than in very small operations. This highlights the importance of having a framework for software approval.




We support the approach proposed for scoring glazing, recognising the additionality principle. We also support the approach proposed for scoring the repair / replacement of qualifying boilers, subject to the recommendation in our response to question 8 above that all boilers with a seasonal efficiency of 75% or less be considered to be “not operating efficiently” and therefore qualifying boilers. Given the age of most of these boilers, it is likely that the actual efficiency being achieved is lower than the nominal seasonal efficiency, making them particularly unsuited to provide heating for fuel poor and vulnerable households.

We recommend extending the product-‐specific approach to calculating savings from boilers (based on their specific seasonal efficiency as disclosed in the PCDF) to cover insulation products and systems at the earliest opportunity. We would also recommend the introduction of product-‐specific lifetimes and IUF at the earliest opportunity. The use of product-‐specific data in calculating the carbon and heating cost savings will encourage the development of more efficient products and installation techniques, thereby helping to drive improved standards throughout the industry and ensuring that ECO is delivered cost-‐effectively.

Question 13: Do you have any comments on our approach to scoring packages of measures? If suggesting alternatives, please provide evidence on how this will meet the requirement for suppliers to notify us of carbon/cost scores each month.

In broad terms we support the proposed approach. However, we recognise that the proposed approach may result in operational practices that are not necessarily in the customer’s interests, particularly under HHCRO.

For example, a property with a broken boiler and which is also suitable for CWI. The customer would typically wish to see the boiler repaired / replaced as quickly as possible and the CWI installed subsequently. However, if the boiler is repaired / replaced in one month and the CWI installed in the next, the ECO score is significantly less than if both measures are installed in the same month (when the scoring will be based on the CWI being installed first). This could affect installers scheduling decisions to the detriment of the customer. We believe that introducing a limited amount of flexibility to avoid such circumstances. We recommend allowing the reporting of measures installed up to two months before the end of the reporting period. So the May report (submitted at the end of June) could include measures installed during both April and May.

This would not alter the requirement for monthly reporting and the vast majority of measures would be reported in the month they are installed. But the proposed approach would remove concern about the scoring mechanism penalising installations straddling a month end. It would therefore remove the risk of scheduling measures – in particular boiler repairs and replacements -‐ close to the month end.




Question 14:

a) What are your views on whether suppliers should be able to infer some RdSAP inputs when scoring measures under the HHCRO?

b) Do you have any suggestions on how this could be done, while ensuring that the savings determined for the measure are accurate and specific to the property in which they are installed?

c) Would this enable the obligation to be delivered more efficiently and effectively? Please provide qualitative and quantitative evidence to support your position.

We do not support the use of inference rules beyond those already used in RdSAP and allowed under the EPC framework.

There are already established rules within the EPC framework that allow data sampling and cloning to be used when it can be justified for a specific population of properties e.g. blocks of flats or estates of social housing where there is a high level of homogeneity between properties. We would recommend that such an approach only be allowed under ECO if EPC are issued for the properties. This will ensure that the inference rules adopted are compliant with the national calculation methodology and subject to independent audit. The development of RdSAP included work to evaluate the sensitivity to the various inputs compared with the time taken to collect the input data. The current input data requirements are the result of this optimisation process. For example, glazed areas are inferred on the basis of the age and built-‐form of the property because the time required to measure the openings was not justified by the improvement in the accuracy of the resulting rating.

There are software tools that can infer RdSAP inputs and which can be used to make recommendations for improvement measures. Whilst they can achieve reasonable accuracy in determining appropriate improvement options and even in predicting the likely impact on the property’s energy rating, they will inevitably be weak when it comes to calculating the likely energy use and potential savings. This is because the absolute energy use and the predicted savings depend on the property volume and surface area, whereas the rating is normalised on the floor area and is therefore self-‐correcting when evaluating improvement options.

The most time consuming portion of an RdSAP assessment is collecting this basic dimension and geometry information for the property. However, any approach that infers these data items will inevitably result in different ECO scores than would be calculated from a proper RdSAP assessment. Crucially, given the variability between properties, it would be extremely difficult to ensure any inference rules were conservative. There will inevitably be instances where the ECO score can be improved by selecting to use the inference rules even if the actual data has been collected.

Overall, we recommend working within the existing EPC rules, including issuing an EPC for each property in order to ensure that the input data – which is crucial to the accurate calculation of the ECO score – is subject to a robust QA framework.




Question 15: We intend to publish all appropriate methodologies immediately after approval on our website. What are your views on this proposal?

We are concerned that immediate publication could potentially reduce the incentive to actually develop appropriate methodologies, which could constrain innovation and research. We suggest that applicants proposing appropriate methodologies backed up by robust field trials or other supporting information should be allowed to nominate whether they are happy for the methodology to be published or whether they wish to maintain exclusive rights to the methodology for a fixed period (we suggest one year).

We would anticipate that where a manufacturer or an industry group has developed the methodology, they would wish to see it published and available as quickly as possible. Where a supplier develops a methodology, they may wish to retain exclusivity for a period. If it is agreed that a methodology does not have to be published immediately, we would suggest that the fact of its existence and scope should be published.

6. Monthly Notification of Completed Measures

Question 16: Do you feel that our approach to determining the date on which the installation of a measure is complete is reasonable? Are there instances where you think an alternative approach should apply? If so what alternative do you propose?

Subject to our recommendation under question 13 of allowing up to two months to report measures (in order to avoid issues with the installation of a package straddling a month end), we support the proposed approach to determining the date of installation and consider that it provides sufficient flexibility

Question 17: Do you feel that our approach to what we consider as ‘administrative oversight’ is reasonable? If not, please explain why.

We are concerned that the notification requirements are complex and the systems involved in collating data and calculating notifiable data items are being developed with limited opportunity for testing. We would suggest that during an initial period a degree of flexibility – including tolerance for human fallibility – is both necessary and justified.

11. Excess Actions

Question 18: Do you feel that this chapter adequately explains what can be considered as an excess action?




No comment.

Question 19: Do you agree that our process for making an application for excess actions is clear?

No comment.

13. Audit and Technical Monitoring

Question 20: What are your views on our approach to auditing?

ECO is complex and successful delivery will depend on the performance of multiple parties within the delivery chain. We therefore welcome a robust audit approach that it risk based, operates within a spirit of continual improvement and the cost is proportionate to the benefits achieved. The consultation contains little detail on the proposed audit approach, so it is difficult to judge whether it will satisfy these criteria.

Question 21: Do you agree with our approach to technical monitoring? If not, do you have any specific comments on how this could be made more efficient?

We are concerned that the proposed approach to technical monitoring takes no account of whether installers are actually working within the PAS 2030 framework (rather than just in accordance with the relevant product specific annex). As such, it risks undermining initiatives to improve standards across the entire industry.

We recommend that where an installer is PAS 2030 accredited for a measure, then the base level monitoring for the first three quarters of operation should be set at 1% rather than the proposed 5%. More generally, we suggest that Ofgem engage with the PAS 2030 accreditation framework. Feedback from the technical monitoring required under ECO should contribute to the on-‐going development of the standards, in order that PAS 2030 accreditation itself is itself sufficient assurance of quality and customer service. This would remove the requirement for specific additional technical monitoring under a future phase of ECO.

Question 22: Are there standards in addition to those contained in the building regulations, that we should require suppliers to technically monitor?

No comment.




Question 23: Do you agree that our approach to fraud prevention is suitably robust (including the submission of prevention/detection proposals at the time of activity proposals)?

We support the objective of preventing fraud and the broad approach outlined. However the proposals provide limited guidance on what is expected and we would welcome more detail before commenting on the practicality and proportionality of the requirements.

eco guidance consultation response final · kingfisher future homes ltd eco guidance consultation...

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