Heat and Energy Saving Strategy(HESS) http://hes.decc.gov.uk/ ,
Community Energy Saving Programme (CESP)
http://www.decc.gov.uk/en/content/cms/consultations/open/cesp/cesp.aspx and
CERT
http://www.decc.gov.uk/en/content/cms/consultations/open/cert/cert.aspx.
I will of course have to respond to the consultation formally, but I thought I
would post a couple of comments that apply to
the policy in general.
1. All three documents are founded on the principle that the market can
deliver energy saving given the right incentives. This must be flawed.
It is an assumption that has been made for the last thirty years and
even when real possibilities of saving have been shown to commercial
users (who are meant to be driven by costs and savings) there has been
little energy saving activity. It also assumes that the value of carbon
and the environment can somehow be reflected in prices, which it clearly
is not.
2. The documents refer to the importance of resident behaviour, mostly
in relation to the deployment of 'smart meters', but they take little
regard to the issue of engagement and motivation. Our experience in
Cambridge Carbon Footprint over the last three years is that once
provided with the support, people will willingly engage in both more
sustainable behaviour (turning down thermostats etc) and 'invest'
considerable time and money in improving their houses. These
investments, such as solar water heaters or solid wall insulation, may
have marginal or negative returns on investment but are made because
climate change and carbon reduction are important issues.
While the consultation does not discuss in issues of personal values, it
should be said that if the government plans projects such as the third
Heathrow runway or an new coal powered electricity station at
Kingsnorth, appealing to people concerns about climate change may be met
with cynicism.
3. By ignoring personal values, motivation and behaviour, the proposals
are inevitably concerned with technical issues, such as heat pumps and
smart meters. They have failed to recognise one of the fundamental
issues in home energy, ventilation. There is no mention of improvement
to doors or windows, either by replacement or renovation and so nothing
about improving air quality, mechanical ventilation or heat recovery
systems in buildings.
4. CESP is unduly concerned with providing upgrades to the disadvantaged
and fuel poor. While improving the housing for these groups is
essential, it should not be confused with carbon reduction. The evidence
is that upgrading badly insulated houses occupied by less well off
residents results in warmer, safer homes and little reduction in heating
costs or carbon emissions. The problem with the building stock is that
the bulk of the CO2 emissions are form larger pre 1919 houses occupied
by the comfortably off, such as the Defreville Estate. In the present
proposals, CESP funding will not be available in Cambridge, as there are
in sufficient households in the lowest income decile. It will therefore
not be able to provide any support for future programmes to address the
Cambridge housing energy problems.
Note that the Cambridge City "Home Energy Strategy" reports that the
average SAP rating for the Cambridge housing stock is over 5 and a half
points below the national average.
5. The HESS talks about 7 million homes and upgrades that will cost in
the order of £10,000 per dwelling by 2020, but fails to recognise that
this represents an expenditure by individuals, government and energy
suppliers of seventy billion pounds in ten years. I would be surprised
if the mechanisms discussed could deliver this level of activity.
I hope you will take the time to look at the documents and make a formal response too. You can comment here, but I am not Ed Milliand.
