More information including the full consultation documentation is available at:
http://www.decc.gov.uk/en/content/cms/c ... _deal.aspx.
56. Do you agree that targets of 0.52 million tonnes of CO2 per year saved, and £3.4 billion reduction in notional lifetime costs of heating by March 2015 represents the correct balance between ensuring high levels of delivery and minimising costs that could potentially be passed through to consumers?
57. Do you agree with the estimated costing of this scale of ECO at £1.3bn p.a. as set out in the Impact Assessment? Do you have additional evidence on the costs and benefits of the proposed targets for consideration in further analysis?
58. The division of the overall ECO between energy companies could be based on share of customer accounts, or sales volume. Do you have a preference as to which metric should be preferred, taking into account possible impacts on distributional equity? Please provide evidence for your views.
59. We propose that savings calculated through the SAP-based Green Deal Assessment methodology be used as the basis for ECO targets and scoring. Can you envisage any undesirable or inadvertent effects, that this approach might result in? If so, please provide details and evidence.
60. Should targets and scores for the Carbon obligation and/or the Affordable Warmth obligation be expressed on the basis of the annualised savings of measures or the lifetime savings?
56. No comment
57. Whilst the amount £1.3billion is substantial the split on the affordable warmth of 25% means the whole budget for the vulnerable is very low and below existing allocations. This is likely to mean fuel poverty targets will remain unattained. My concern is not with the amoount but with how the money could be aloocated. The removal of subsidies for basic insulation could destroy the cavity and loft insulation industry overnight and lead to many missed opportunities. If estimates for for unfilled cavities are accurate and remain quite high I would like to see a tapered support introduced as part of the Carbon saving element for eample a 50% subsidy in year one and 10% removed in each following year. This would give the industry time to adapt to solid wall insulation and keep basic and high carbon saving activity vibrant while many cavities are yet to be filled. A mass transition in a short space of time will lead to many technical errors that could set Soild wall insulation back many years, so allowing more familiar activity to continue and form part of the obligation will allow some elements of the targets to be dealt with in confidence allow more attention to the qulaity of solid wall insulation.
58. no preference
59. No real problems other than this will replace Warmfront and hance there is no Energy saving in repairing a boiler and little in replacing a 5 or 6 year old one so unless allowance is offered for affordable warmth SAP may be not be best.
60. Lifetime savings take account of the persistence of the measure so this is preferrable but expressing both not be a problem with the way data is collected.
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