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

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E. Too complex to<br />

simultaneously<br />

arrange <strong>Green</strong> <strong>Deal</strong><br />

finance <strong>and</strong> ECO<br />

contract<br />

F. Tenders for largescale<br />

retr<strong>of</strong>it<br />

inhibited by need for<br />

prior ECO contract<br />

Potentially valid, <strong>and</strong> providers may also be concerned at revealing<br />

information to potential competitors (if a supplier has in-house<br />

delivery). A brokerage would need to guarantee volume could<br />

be placed (<strong>and</strong> providers to accept some market price risk, or<br />

cost inefficiencies would rebound on consumers). However,<br />

there may also be the same objections as D. – st<strong>and</strong>ard<br />

contracts can be placed through six phone calls; bespoke<br />

contracts may not be suitable for a brokerage<br />

<strong>The</strong> real barrier here is the short timescale <strong>and</strong> firm targets <strong>of</strong> ECO,<br />

which make it difficult for housing providers to negotiate with<br />

suppliers <strong>and</strong> then place a tender. Some flexibility between ECO<br />

periods would reduce this barrier. <strong>The</strong>re would be a benefit <strong>of</strong> a<br />

brokerage if the costs <strong>of</strong> transactions are lower than direct<br />

negotiation with suppliers, although this would only seem likely<br />

if st<strong>and</strong>ard contracts were practicable.<br />

143. Our conclusion is that a brokerage model is not required. Clearly, we would welcome <strong>and</strong><br />

would use any route to market that provides a secure <strong>and</strong> cost effective solution to delivery <strong>of</strong><br />

the obligation. We believe this can be achieved through energy suppliers working with local<br />

suppliers <strong>and</strong> providers to deliver the lowest cost <strong>and</strong> most effective delivery <strong>of</strong> the obligation,<br />

rather than establishing a formal brokerage system <strong>and</strong> associated infrastructure at further<br />

significant cost to the industry <strong>and</strong> in turn the energy bill payers. As it is in the interest <strong>of</strong><br />

energy suppliers to work with GDPs where they <strong>of</strong>fer cost effective delivery, we feel that<br />

market forces will ensure competitive access to ECO, <strong>and</strong> that a brokerage is an unnecessary<br />

burden on a new market.<br />

144. If DECC are minded to pursue a brokerage model we would be prepared to support its<br />

development, but no assumption can sensibly be made as to how much <strong>of</strong> the market it might<br />

capture.<br />

Q52. Do you agree that it is desirable that energy suppliers should have to fulfil some or all <strong>of</strong> the<br />

(carbon) obligation by spending money promoting measures through those organisation<br />

who are able to provide the most cost effective delivery options?<br />

145. No. Forcing suppliers to purchase from particular providers will create inefficiencies in the<br />

market, which increase costs to energy consumers. If they are genuinely cost effective then in<br />

46

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