Written evidence submitted by JJ Crump & Son
Are the Government’s targets on residential energy efficiency still appropriate to achieve its ambition to reach net zero emissions by 2050?
What are the potential risks and opportunities of bringing forward the Government’s energy efficiency target?
Should Government targets for energy efficiency be legislated for, and if so, what difference would this make?
Residential energy efficiency targets are going to be impossible to achieve using schemes such as ECO.
We are in a situation where Government is using a Fuel Poverty project to achieve carbon reduction targets. This is never going to work.
ECO3, in particular, is based totally on the Affordable Warmth group (i.e. those on benefits) or Local Authority Eco Flex (low income + high cost.) The reality is that there are millions of homes that do not fit into these categories but need energy efficiency measures to improve the energy efficiency of the properties, reduce carbon emissions and reduce household fuel bills.
For many years there have been calls to make household energy efficiency a National Infrastructure Project so that each and every home that needs energy efficiency improvements can access grant funding to install them.
A national energy efficiency programme for homes and businesses would deliver quick returns by slashing fuel bill by hundreds of pounds for customers as well as reducing emissions to help meet the net zero target.
An ambitious infrastructure plan that would also help kickstart our economic recovery by creating thousands of skilled jobs and new opportunities for businesses.
How effective is the EPC rating at measuring energy efficiency? Are there any alternative methodologies that could be used? What are the challenges for rural areas?
It is widely known, and reported, that around 2.5million household EPCs are incorrect (whether it be insulation assumed or measurements incorrect) and this can affect whether a property can access ECO funding and have energy efficiency measures installed or not.
There needs to be a proper process incorporated within ECO to allow householders and/or installers that know a property was not insulated when it was built, or where a DEA has incorrectly reported ‘insulation assumed’ to have that EPC corrected and then to be able to access ECO funding.
How can the Government frame a Covid-19 stimulus strategy around improved energy efficiency of homes?
The Government’s manifesto committed £9.2billion for home energy efficiency.
By creating a national infrastructure project thousands of new jobs would be created very quickly, it would also secure the future of businesses that have only just weathered the storm of Covid-19, furloughed employees and work completely stopped for three-four months.
At the same time, it will also help thousands of householders that are facing increased energy bills (estimated to be increased by as much as 20% as a result of lockdown) and help kick start the drive towards net zero emission plans.
However, ECO needs to be simplified. The legislation is too rigid and is preventing new technology/energy efficiency measures being introduced as innovation measures to the scheme which could significantly reduce overall energy bills and carbon emissions.
The current scheme prevents/limits innovation technology types that are not directly related to reducing space heating costs despite the fact that hot water is a significant cost to households and contributes to around 30% of a household energy bill.
J & J Crump has a new product that it would like to introduce to ECO as an innovation product that would save households around £380/year on their electricity bill – electricity is the bill associated with their space heating.
The product can provide significant lifetime bill savings, which could benefit thousands of fuel poor customers who live in electrically heated homes and rely on electric storage heaters, electric panel heaters or electric warm air units (particularly flats with no gas supply) and an electric immersion heater as their only source of hot water which is very expensive to run.
Households that use electric heating tend to be of lower income. In England, around a third have incomes of less than about £14,500 per annum. This combined with higher costs of heating, means these households are more likely to be fuel poor.
This new technology measure would significantly reduce the high costs faced by properties which rely on electric immersion heaters as the main source of hot water - around 1.8m homes in England - At present there is no alternative for these properties.
Crump Innovation Heat Pads ® is a ground-breaking product, completely different to any measure previously delivered under supplier energy efficiency obligations.
It has been developed using a material and application system that can demonstrate improved energy efficiency performance and significant lifetime bill savings (LBS.)
The heat pads are unique carbon polymer pads ® which are retrofitted to the exterior of an existing water cylinder by removing sections of the tank insulation. The pads are then connected to an electronic ladder system which in turn is connected to a 24v power transformer. The carbon polymer is non-combustible, and the pad made from flame retardant material.
One heat pad is sufficient to heat 50L of water, so the average tank of 120L would be retrofitted with three pads.
Once connected to the 24v transformer the pads heat immediately and begin to heat the water in the tank to 62°C.
When the tank reaches 62°C all three pads will switch off and remain off until hot water is drawn from the tank.
When hot water is drawn from the tank – say 35L for a shower - cold water will flow into the bottom of the cylinder. The remaining hot water will rise to the top of the tank and at this point the bottom pad will immediately switch on to start bringing the cold water back up to 62°C. The remaining pads will remain off as the top section and middle section temperature will still be at the required temperature. If 50L was drawn off the tank the bottom and middle pads would switch on and so on.
The unique properties of the pads and the electronic ladder system provide impressive sayings in comparison to a common 3kW immersion heater based on the UK average electricity rate of 17.36p/kWh.
With average annual bill savings of around £380/year (up to £510/year on a one-bed flat.) Based on a lifetime of 30 years the LBS could be as much as £4560. The product needs no maintenance unlike electric immersion heaters which degrade over time.
The application of the measure is simple and would be installed under the relevant PAS annex – other insulation and conform to BS7671.
Is the £5million Green Home Finance Innovation Fund enough to stimulate the market for a and drive action from the banks to encourage homeowners to improve the energy efficiency of their homes?
What policy and/or regulation could supplement it?
Which models in other countries have been successful at stimulating demand for energy efficiency within this market?
What additional policy interventions are needed for social housing, leaseholders, landlords and tenants?
England, unlike Scotland and Wales, currently provides no central government investment to improve domestic energy efficiency.
More than 2 million fuel poor homes in England have no or inadequate levels of loft insulation, over half a million have uninsulated cavity walls and 1 million have solid walls with no insulation and are the most expensive to treat and heat.
While the Green Home Finance Innovation Fund is welcome it is costly to find and treat just fuel poor homes.
Making domestic energy efficiency a national infrastructure project would ensure ALL homes are treated, not just those living in fuel poverty, and that no one is living in a cold damp home that is expensive to heat.
How should the proposed Home Upgrade Grant Scheme be delivered to help the fuel poor? Should the new grant scheme supplement ECO in its current form, or should ECO be redesigned?
Under ECO3 LA Flex element, Local Authorities have become more involved in targeting and tackling homes that need energy efficiency measures.
Some Local Authorities have pots of funding available to help fund measures where the ECO funding does not cover the full cost of the measure and a contribution is required.
Allocating all Local Authorities funding from the Home Upgrade Grant Scheme would ensure that installers, that have an established relationship with a Local Authority, would be able to access funding to combine with ECO funding to effectively target and deliver whole house solutions on an area-based approach
Are there examples of where energy efficiency policy has fallen between Government Departments? How could cross-departmental co-ordination be improved?
J & J Crump & Son Response 10.06.2020