Talking of the Carbon Plan, (subtitled ‘delivering our low carbon future’) it is difficult to see how you can set out a plan and a proposal to deliver it without some targets along the way. And that is what the Carbon Plan effectively does, including targets for the insulation of cavity wall and solid wall housing. But really eagled eyed students of Hansard will have detected ministers fervently debunking the notion that there are or should be targets as far as Green Deal and ECO are concerned. Here’s Greg Barker on the subject of targets during the committee stage of the recent Energy Bill:
‘Labour members, in their heart of hearts, yearn for a plan – a centrally organised government Plan like Warm Front. …That is not the Green Deal: that is not how it will work. Nor are targets the way it will work, because we have been down that road before and it ended in failure.’
And here’s Lord Marland, batting bravely for the Green Deal in response to a question asking him to estimate take up of Green deal over the next five years.
‘The Green Deal is a market based mechanism and take up will depend on the level of consumer demand.’
So no targets, then. But the authors of the Carbon Plan have, clearly, not taken these emphatic protestations into account: yes, they set out what looks suspiciously like… targets. Here’s what the Carbon Plan (p33) has to say on Green Deal and ECO:
‘The Government’s current policy package will depend on the final design of the Green Deal and Energy company obligation in the light of public consultation. It is likely to result in all practicable cavity walls and lofts having been insulated by 2020, together with up to 1.5 million solid walls also being insulated’.
Looks a bit like targets, doesn’t it? But then we have to contend with the tricky business of the cold light of impact assessments, which must be published on policy proposals by law, and have to, more-or-less add up. You might remember that DECC had some trouble with the Feed in Tariff change impact assessment recently. Nasty, messy, but necessary. The impact assessment for Green Deal and ECO, unfortunately doesn’t really bear the Carbon Plan targets out: it does, on the one hand, predict a quite staggering amount of solid wall insulation (SWI) considering the funds available, and the limited amount of social housing SWI to practice on before we get onto the much less tractable private sector SWI. But on the other hand it envisages a gap, and then a collapse in cavity wall insulation as CERT and CESP (and that centrally planned Warm Front) come to an end, and Green Deal takes up the slack. Essentially, there will be, according to the impact assessment, a declining level of cavity walls insulated dipping from just over 100,000 in 2013 to well below that figure in 2021: and certainly well below the 170,000 ‘treatments’ per year that are pencilled in to make the Green Deal finance company figures stack up.
That, it could be argued, is because ‘all practicable cavity walls and lofts’ have been treated by 2020: but that is not so, if the English Housing Survey estimates of all types of cavity wall (conventional, narrow and non-traditional) are taken into account. Indeed as a new report from the Association for Conservation of Energy makes clear, (‘Dead CERT’ January 2012) the demise of work on cavity wall insulation once CERT goes and Green Deal comes in will mean that ‘at such a rate, even the low cost cavities would not be insulated until almost 2040, with the more expensive cavities not filled until 2050.’
Those companies specialising in cavity wall and loft insulation, furthermore will probably have to adapt rapidly to solid wall insulation, or die. The ACE report suggests the creation within Green Deal/ECO of a ‘son of CERT’, which could continue work on cavities, particularly narrow and unconventional types, by bringing them into an obligation, and hence into ECO’s funding envelope.
I guess it is, on reflection, little wonder that ministers have been so adamant about not having targets. They are indeed difficult to achieve, especially if the mechanism you introduce leaves a great big hole in the middle of them. Put money on ‘son of CERT’ is my advice.