This is the first of a number of blogs about the recently published Green Deal consultation: At 267 pages it is a mammoth document, and there are not many days before the response is due. 18th January 2012 is the response date. I will be submitting a response on behalf of HTA and a number of our clients with whom we have been discussing the Green Deal for some months now.
I am attending the UK Green Building Council consultation on Wed 30th (tomorrow) and I am chairing the final session on the Green Deal at the London Housing Forum event on Thursday. Suffice to say that I will be reasonably clued-up about the Green Deal by then.
– I am glad to see that there is a strong statement to the effect that the Green Deal can be a huge opportunity for people to improve the quality and value of their homes. I think that this is key to its success and this has not been emphasised enough to date.
– It is a new market, and a great opportunity for companies old and new to compete in it, there is room for everybody!
– There is recognition that the Green Deal will often be delivered alongside other works, but there is too little discussion of the complexity that this brings. If a householder engages a company to fit a kitchen and then decides to go down a Green Deal route, the kitchen installer may not be able to offer to do the extra works and a new company may be required. This will put some people off.
– I am still concerned that there is no energy efficiency target for dwellings carrying out the GD. Without a target there is the strong likelihood that the sam dwelling will need to be treated many times between now and 2050 instead of doing it once properly. I think that this is too short term thinking.
– I have seen little, so far, to encourage a street-by-street approach where a Green Deal Provider takes on a neighbourhood en masse and delivers the works on a rolling programme over a period of say five years per ward. That would encourage GD Providers to doorknock and to really sell their wares. The document talks about homeowners getting a Green Deal Assessment and then shopping around. This is frankly unrealistic. We are not talking about a few groceries here, and very few householders are comfortable ashopping around for External Wall Insulation.
– There are strong statements about the importance of the independent Green Deal Assessor who carries out the assessment and identifies the measures that are relevant and which will pay for themselves under the ‘Golden Rule’. Why then is is allowable for Green Deal providers to employ an assessor and choose how much to charge for the assessment? I see plenty of opportunity for assessors working for a provider who likes External Wall Insulation and the assessor only specifying EWI because it suits his/her employer.
– If homeowners are encouraged to shop around, then a Green Deal provider could subsidise the cost of the assessment, only for the homeowner to take the assessment to a competitor and seek a better price for the work.
– There is a statement that a new version of rDSAP will be used to carry out the asssessment, but full SAP will also be valid when used by a SAP assessor. This is sensible, but there is no information that I am aware of about when these tools will be available for evaluation and testing. The recent history of timely releases of the software to assessors is not good.
-There is mention of the possibility of multiple Green Deals being possible on the same property, which is puzzling and offers the potential for very confusing electricity bills for future owners of the property. I accept the possibility that works can happen at different times, but these works should be folded into the same Green Deal so that there is only one fund for the property.
-There is a proposal to appoint a Green Deal Administrator, who will monitor that the targeted savings are generally being achieved by the scheme and that the Green Deal is functioning as planned. One wonders what the outcome will be if it is discovered that this is not the case.
I will cover more of the document in a few days time.