Green around the gills

You can spot them a mile away.

The pallid deathly paleness, dark rings under their bloodshot eyes, yellow sweat stains on two day-old shirts, stubble, and twitching from too many nights knocking back Red Bull and necking coffee.

These are the sustainability bods; specifically the ones tasked with responding to the government’s green deal consultation before the deadline yesterday.

Yep – for the first time in a long while these folk are probably sick of discussing the green deal. You would be too if you’d had to wade through nearly 2,000 pages of consultation document and accompanying impact assessment before drawing together a considered, succinct reply.

It would appear to be a thankless task – so as I read through them all over the next few weeks, hopefully I will be able to give credit where it’s due.

It’s worth mentioning that no response I have come across so far has deviated from the basic sentiment of: ‘we want this to work but with out a series of changes we are concerned that it will not meet its fundamental goal of cutting carbon to 2020 and 2050 targets’.

You can read that as ‘green deal set to fail’ – it is after all an easy headline – but ultimately this is a consultation inviting criticism so we can only be so surprised when, shock horror, the green deal gets criticised. Yes, some folk will tear chunks out of it and call for a plan B, but it’s all part and parcel of the process, and if you didn’t voice your concerns in the consultation, then you effectively hand in your ‘I told you so’ card at the DECC front desk.

If every organisation warns of potential failure without considerable change then I would suggest, for the sake of your sanity, to focus on what the suggested changes are rather the consequences of ignoring them.

Despite all that, there is some doom ‘n gloom to vent. The British Property Federation’s response which said it is unlikely carbon emission targets would be met without further action and called on the government to provide additional cash incentives to help make the scheme more attractive.

The NHF has been doing a huge amount of work on the green deal – often working with the Local Government Association - and their response reflects this.

As you might expect, they flag up the issues around excluding social landlords from accessing ECO funding that I have written about exhaustively (and will return to in more depth later). Interestingly, though, is the way it does so.

The NHF response paints the government a picture of the woes facing housing providers right now: the end of grant funding, more highly leveraged as a result of the affordable rents programme, their income streams facing an uncertain future as a result of the government’s welfare reforms, and all in all, in no position to invest large sums of cash in energy efficiency works in lieu of ECO.

It also warns that the FITs saga has had ‘a very negative effect on the reputation of DECC in the sector and sentiment about government supported energy efficiency schemes’.

With this in mind, the NHF makes a helpful pitch for some of the government’s £200 million green deal funding announced by Treasury, arguing that making that available to landlords would go some way to improving ‘engagement’ with the sector (a stance backed by the LGA).

There is even a veiled warning: ‘we have also made clear that if social landlords did not have access to any of this funding there would be very serious further consequences for the sector’s sentiment about the green deal and DECC initiatives more generally,’ it reads.

In terms of its wider concerns about the red tape surrounding consumer protection and accreditation for green deal providers, it says that in some instances the mechanisms proposed on the basis of the owner-occupier scenario are ‘cumbersome, unnecessarily costly or unworkable in the social housing sector’. It suggests that the assessment cost of £75 is probably an underestimation.

And on ECO, well – we all knew what the NHF was going to say, and it has said it well. It points out that by only focussing on solid wall insulation for hard to treat ECO funding, 85 per cent of the social housing stock stands to miss out on ECO altogether.

Finally, and most starkly, is its conclusion centring on access to affordable warmth. It argues a higher proportion of social housing tenants are fuel poor than occupiers in other tenures, and at least a million social homes need subsidy to enable improvements which would take their low income tenants out of fuel poverty.

‘The Federation and its membership support the objectives and key principles of the proposed approach, but believe significant changes to the detailed policy proposals are needed to make the Green Deal workable in the social rented sector, with ECO subsidy where necessary.

Without this, as the government is aware, social housing’s potential to be both early and significant deliverers of the green deal will be wasted, with the associated huge risks to the supply chains and policy aims of the green deal in general.’

That is certainly a blunt warning.

Even the Chartered Institute of Housing, which to date has been relatively silent on the subject of green deal and ECO, has responded candidly. CIH does say it is ‘very concerned’ that the green deal will have an ‘insufficient impact’.

Interestingly, the CIH calls for a completely separate consultation on the green deal and ECO for social landlords on the basis that the one we have just had was ‘inadequate’ for social landlords and overly aimed at the private sector.

Part of this is the lack of provision over the problem of including green deal works alongside major repair programmes and extending it to whole neighbourhoods, and the problem of getting tenant consent.

It pushes a number of point on ECO – the way it could be regressive by increasing fuel poverty for low income households, and that exclusion of social landlords from ‘affordable warmth’ subsidy is unfair.

It states: ‘Measures such as [difficult cavity walls, sloping ceilings, flat roofs and suspended timber floors] which discriminate against social tenants are inequitable in two senses: first poor households are concentrated in the social sector (47per cent of households in the lowest income decile are in social housing), second, all households pay fuel bills, from which ECO is funded, and therefore all sectors should have an equal right to ECO funds, subject to meeting the criteria.

As an aside, Inside Housing put this point to Energy Secretary Chris Huhne yesterday during an online question and answer session organised by Which?

He responded: ‘I just don’t agree that social landlords have little to gain from the hard to treat allocation, as our figures show that there are similar amounts (proportionally) of solid wall homes in the social housing sector as elsewhere. Because most social homes are now up to decent homes standard, it makes sense to concentrate affordable warmth where the biggest problems are.’

That could change soon, though. Issues around ECO being flagged up elsewhere in the nation media over the last few weeks. The Times’ Tim Web has been covering it – and more recently, The Guardian’s George Monbiot (who originally flagged up the inequitable way the FIT works) has been blogging on green deal and ECO.

When I first revealed about landlords exclusion from affordable warmth (denied by the government at the time) and the findings in the interim results of the Hills review it didn’t strike me as a topic that would ever be sexy enough to capture the imagination of rest of the national press. Hopefully now that it has, Inside Housing’s Green Light campaign can step up a gear to make sure that ECO is not regressive, that the mistakes from CERT and CESP are not repeated, and that the most vulnerable people are protected.

Unsurprisingly, the Association for the Conservation of Energy has beef about the transition from CERT to ECO which could cause a slump in the insulation. It has also published its timely Dead CERT report into the transition to ECO. This flags up the long discussed problem the introduction of ECO (focussed mostly on hard to treat solid wall insulation) will pull the carpet out from under the feet of the loft and cavity insulation market as the expected uptake of the green deal which takes over from the CERT measures is low.

The report does not recommend a ‘son of CERT’ approach to smoothing the transition; instead it suggests aligning the green deal to ECO by allowing lofts and cavity walls delivered through green deal to contribute to ECO. It also calls for ‘fiscal incentives’ such as a VAT cut for green deal measures, use of the £200 million from Treasury to incentivise the take up of green deal packages, and linking stamp duty and council tax to home energy ratings.

It recommends increasing the ECO for low income and vulnerable households and widening the eligibility group (although it’s not clear whether this means making it tenure blind), the introduction of more regulatory standards, and the inclusion of more costly cavity wall insulation as eligible for ‘hard to treat’ ECO. The executive summary has some very interesting pie charts.

They outline some scenarios based on ACE alternative proposals in the first four years of ECO up to 2016. These include 500,000 homes insulated with loft and cavity wall insulation a year, an additional 75,000 harder to treat cavity walls to be insulated, and more than 140,000 solid wall insulations a year.

ACE claims under their proposed scenario, more than twice the proportion of ECO will be spent in the homes than need it most, saving 55 per cent more carbon and seeing 80 per cent of solid wall insulation numbers delivered under the DECC scenario installed at a rate of 140,000 a year. And all at a lower cost to bill payers than DECC are proposing.

Now, I am no sustainability bod, so am unable to properly asses the merits of these proposals.

But I am hoping that better qualified (albeit more sleep deprived) people than myself will be able to respond to this and let me know – once they have recovered from the trauma of the green deal consultation, that is.