1 Department of Energy and Climate Change The Green Deal and ...

Q14. We propose that any measures should be allowed under the Affordable Warmth obligation,
provided it allows eligible households to heat homes more affordably. If you disagree, or feel
there are risks to this approach, please explain and set out any restrictions you believe
should be put in place.
39. We broadly agree, although not fully, with the principles set out in paragraph 53. The
portability of measures should not be a criterion, but the criterion should be whether a
measure makes heating more affordable (more economic or to reduce need). However small
the measure, it still helps alleviate fuel poverty. If it turns out that the Affordable Warmth
obligation can be delivered in the first ECO period at lower cost by helping the majority of fuel
poor customers a little, rather than to provide greater help to a few, then that is as effective in
alleviating fuel poverty (in fact more so, as the adverse effect of the costs of the scheme would
be reduced). Moreover in practice there is very little prospect of the policy intent being
diluted. The challenge of identifying and engaging eligible customers dictates that major
insulation and heating measures will predominate.
40. Guidance is required over the implications of Clause 11(4) of the draft ECO SI. We would agree
with an interpretation which excludes measures which reduce bills without making warmth
more affordable, but not the exclusion of community based loft insulation programmes.
Q15. Do you have any suggestions for whether and how we should score, boiler repairs under the
AW obligation, such that where repairs are most cost-effective than replacement systems,
without significant impact on efficiency, these can be promoted?
41. The difficulties of scoring boiler improvements are demonstrated by the draft proposal for a
deemed score for boiler replacement which greatly exceeds the true benefit, as would be
calculated by a Green Deal assessment (SAP). This needs to be addressed to ensure due
weight is given to insulation measures and to avoid a barrier to Green Deal assessments and
whole house solutions for Affordable Warmth eligible customers. These difficulties would be
compounded by including boiler repairs, which can only be given a deemed score.
42. Scoring would be more difficult still as there can be no established norm for the life a boiler
repair. Indeed some might only be effective for a few months, or less, leading also to an issue
of verification to avoid each successive boiler repair being scored. There would also seem to
be a clash with the ‘additionality’ principle (Clause 11(4)(a) of the draft ECO SI), as boiler
repairs will generally be an emergency which households would fund themselves. Additional
complications would be the need to verify private ownership, as landlords would be
responsible for private tenancies, and to ensure that there was no disincentive to taking out a
central heating care policy.
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