Remove Red Tape

Energy Efficiency

Improving the energy efficiency of our homes, businesses and industry is a cost-effective way of reducing our use of energy, and in turn, the amount of energy we need to produce. This is the best way of reducing carbon emissions, whilst alleviating fuel poverty, and lowering bills. Not only that, but if we require less energy overall then this also helps maintain our energy supplies as well as improving the competitiveness of UK businesses.

But despite these social and economic benefits, barriers exist that tend to dampen demand for energy efficiency measures. These include the up-front cost of measures; the hassle-factor of arranging installation; and lack of consumer awareness. It is these types of barriers that existing and future regulations are designed to overcome, including where appropriate designing non-regulatory mechanisms to achieve our aims.

You can find the regulations that relate to Energy Efficiency below to the left.

Please tell us what you think should happen to these regulations and why, being specific where possible:

• Should we scrap them altogether?
• Could their purpose be achieved in a non-regulatory way (eg through a voluntary code?) How?
• Could they be reformed, simplified or merged? How?
• Can we reduce their bureaucracy through better implementation? How?
• Can we make their enforcement less burdensome? How?
• Should they be left as they are?

20 comments on “Energy Efficiency”

1. Peter on January 4, 2012 at 8:09 pm said:

   1) All Commercial Buildings to have DEC’s by April 2013. 2) Link Business rates to the DEC rating; 3) This negates the need for a (widely speculated) nationwide complex rates revaluation where the priority shifts from assessing business turnover to the prioritised CRC. 4) Ensure that trading standards departments actually get off their backsides and enforce the regulations instead of coming up with excuses. 5) Continue tax incentives for capital expenditure allowances, carbon trust interest free loans etc. 6) Result? ) Businesses save cash from reduced energy costs at the same time as making improvements to their properties b) Boost to industry through the said improvements. c) Government acheives CRC’s and related targets.
   Another comment: EPCs are required upon the marketing and transfer of all property; however there are loopholes which DECC will not close, so why do they bring out legislation but not enforce it? Comparitives and benchmarks are only useful if they apply across the board 100%. So now the green deal comes out this year, and call me cynical, but I imagine I’m not the only who is thinking what the hell is going to happen this time…..Comment Tags: business rates, DECs, EPCs, tax incentives
2. Robert Flint on January 4, 2012 at 11:50 am said:

   The microgeneration industry has the potential to make a major contribution to energy efficiency improvements in the residential building sector (which represents approx. 25% of UK carbon emissions). To help stimulate such technologies and enable them to address the mass market, various policies are being enacted (e.g. the Feed In Tariff and the Green Deal).

   Entirely reasonably, a system of regulations is being developed to assess technologies and ensure they are capable of delivering carbon and cost savings in practice. It is necessary for a specific product to meet these regulations before it can qualify for the applicable policy support. However, there is a ‘red tape’ challenge around some of these regulations. Specifically:-

   1. Much of the residential energy industry relies upon the SAP (Standard Assessment Procedure) which is used to assess building energy use. SAP has evolved over many years, and has become extremely complex and almost impenetrable in practice. This is acting as a constaint on innovation (since designers find it hard to predict the score a building design will get) and a constraint on competition (since it is hard for Government to compete the supply of new SAP versions to get best practice / value).
   2. A procedure called PAS67 is being proposed to calculate the effectiveness of small scale combined heat and power (‘micro CHP’) systems, which are intended to replace gas boilers and provide electricity as well as heat for the home. This procedure is extremely cumbersome, expensive to implement and not fit for purpose (a simple threshold test would suffice).

   In general, the governance surrounding the implementation of SAP, MCS and PAS67 does not appear to allow rapid and transparent improvement of these key regulations. Our experience in participating over several years indicates vested interest is strong and change is very slow to implement.Comment Tags: MCS, microgeneration, PAS67, SAP
3. Hugh Conway on December 29, 2011 at 1:38 pm said:

   One of the most frequent red tape comment by businesses has been linked to the CRC Energy Efficiency Scheme.
   The comments usually include the complexity of the scheme and the number of man-hours spent on its administration with numbers of 130 to 150 man-days frequently being quoted.
   An examination of the Environment Agency web site would tend to bear this out where we find the following:
   there are 40 Guidance Documents containing 867 pages of guidance. There are 14 “useful links” to other organisations providing information on the scheme. There is a section on “frequently asked questions” with 15 topics and 98 questions. All of this for a single tax scheme.
   Some of the above may have been necessary for the scheme in its original form when recycling of revenue was proposed, however in its new format it is totally unnecessary. Energy suppliers, if requested, now have a licence obligation to provide consumption data for the period being monitored. A consumer should only need to examine this data, confirm its accuracy, and then send it with their payment to HM Revenue and Customs by the end of July each year.
   The other area that has been raised as a concern is the extension to the Climate Change Levy and Climate Change Agreements, where DECC is proposing to involve the Environment Agency in providing the administration for the new period. Concern has been expressed that this is going to lead to increased red tape by the EA with experience of the CRC scheme being used as an example.Comment Tags: climate change, crc, energy efficiency, taxation
4. Nick Turner on December 14, 2011 at 3:53 pm said:

   We have found the CRC scheme to be particularly complicated, management intensive and difficult to administer. There is little guidance for landlords of commercial property as regards recovering the cost of allowances from tenants and the scheme is effectively a tax. We have little control over our occupiers’ energy consumption and for multi-let buildings, we simply recover the cost of energy consumed – hence there is little incentive for the consumer to reduce consumption etc. Equally, the more successful we are in letting business space and improving employment etc, the higher our deemed “consumption” and therefore tax. Why doesn’t the Government simply add a levy to all energy bills (regardless of annual usage) so every consumer is incentivised to reduce consumption? That would seem to be a fairer approach, an easier one to administer and not discriminate against large users, who are invariably adding more to the local economy etc?Comment Tags: crc
5. John Alker on December 13, 2011 at 4:35 pm said:

   Government is asking the wrong question in the Red Tape Challenge. Effectiveness is critical, but overall ‘volume’ can be a red herring. The “One in, One out” policy on regulation risks assuming that one regulation is the same as another. We should be asking whether we have got smart regulation, delivering the desired effects, at a reasonable cost to business. There is undoubtedly scope for streamlining policies in relation to energy efficiency in non-domestic buildings, but is Government willing to look at fundamentally altering the CRC given it derives income from it? Far more useful would be a roll-out of Display Energy Certificates to all commercial buildings.Comment Tags: buildings, carbon reduction commitment, crc, DECs, display energy certificates
   • Red Tape Challenger on December 15, 2011 at 9:50 am said:

     Thank you for your comments. This is valuable feedback. On the general point of Red Tape Challenge compared to “One-in, One-out” there is a key difference as Red Tape Challenge is about reviewing the stock of regulation on the UK’s books whereas “One-in, One-out” is designed to stem the flow of new regulation. “One in, One-out” is measured on a “net cost to business” basis. For example if the government is bringing in a regulation classified as an “IN” which costs business £10m, it is required to find an offsetting “OUT” deregulation which saves business £10m. Therefore the burden of the regulation is considered.
6. Clare King on December 8, 2011 at 2:07 pm said:

   I believe that energy efficiency legislation at both local and central government level should be strengthened, and certainly not weakened. Creating the right regulatory environment to make energy efficiency improvements more cost effective than the status quo is imperative for the UK to meet it’s carbon emission targets.

   What the industry desperately needs is certainty. The recent short notice u-turn on solar subsidies and changes to the CRC Energy Efficiency scheme – to give just two examples – create uncertainty around investment that is seriously hampering efforts to scale up energy efficiency and renewable energy measures.

   New measures such as the Green Deal have the potential to promote increased uptake of energy efficiency measures however the key will be accessibility and good implementation. Let’s hope that is what we see, because so far the coalition is getting a pretty poor report card for progressive environmental policy.Comment Tags: crc, energy efficiency
7. HJP in Beds on December 4, 2011 at 4:45 pm said:

   Energy conservation is vital for our future health & wealth. Therefore the government should be encouraging efficient use of all forms of energy, and their production. Home-grown energy could protect us from the uncertainty of supplies from Russia and the Middle East, so keep the incentives going. The regulations should encourage this process, while protecting our health from the excesses of the past. If that means keeping them, albeit with updating adjustments, then so be it!Comment Tags: energy conservation, energy-independence
8. lonw1 on December 4, 2011 at 10:01 am said:

   It relates to domestic gas efficiency. There are currently a number of regulations relating to gas boilers in homes. One in particular restricts the positioning of flues in areas like open stairwells and small courtyards. They do not however stop existing ones being used. As a result there are literally tens of thousands of people who currently have a gas boiler which is old and cannot be replaced by a new one. These are less safe and far less efficient than the new ones. If the installation were genuinely unsafe then surely they should be banned out-right butas that is not the case there seems no reason why existing ones, if they are going to remain anyway, could not be able to be replaced by more efficient ones. There regulations just do not make sense and encourage people to get their old boilers replaced by illegal contractors.
   If this is the wrong pages to post this comment please post it on the appropriate one.Comment Tags: gas domestic energy efficiency
9. Bryan on December 3, 2011 at 3:09 pm said:

   Energy rating system.
   Follow Japans lead and contiually increase standards for eletrical equipment and remove street lighting on all roads ,cars have had lights for over 100 years! ,illuminated motorways is madness.
10. Matthew Hill on December 2, 2011 at 2:33 pm said:

    One important item of energy legislation – the Building Regulations – is not included here, although it affect all construction work. “Part L” of the regulations has become vastly more complicated over last two decades and has expanded from one document to four plus copious guidance documents. The result has been a widespread lack of understanding of much of the detail by designers and enforcers.Comment Tags: Building Regulations
    • Andrew P on December 7, 2011 at 1:20 pm said:

      Simply can’t agree-sorry
11. Vincent falco on December 2, 2011 at 2:06 pm said:

    By taking away Communities and Local Government involvement with EPBD. Their own Ministers are contradicting one another over Holiday let ‘exemption’ – What chance is there that they can dovetail with DECC targets?
    Grant Shapps has excluded the one building sector that would benefit most from Green Deal.
    Ask approx 12, 000 DEAs what they think of DCLG ability to lead & regulate- you will hear the laugh in China.
    The industry will get behind an initiative only if they believe in it (they do) and have confidence of it being administered competently without vested interest ( they don’t) – Will this constructive and honest criticism be published?Comment Tags: Ingredients necessary for success
12. Vincent falco on December 2, 2011 at 1:55 pm said:

    Confidence and credibility in DCLG
    EPBD recast – the deadline for an EPC was 28 days so DCLG changed in to 7 days -Oh and added 21 days to that if it could be done – sounds good, means nothing- its still 28 days, giving the layperson a semblance of activityComment Tags: Does DCLG leftt hand know what its Left hand is doing?- credible
13. Bryan Norris on December 2, 2011 at 12:38 am said:

    Out of nearly 300 regulations, we found four that match the Government’s criteria for the scheme – burdensome regulations that are a barrier to green growth*:

    Dark Smoke (Permitted Periods) Regulations 1958 Allows derogation from the Clean Air Act 1993 (CAA) s1 prohibition on dark smoke emissions from industrial plant, allowing specified short-term emissions

    Dark Smoke (Permitted Periods) (Vessels) Regulations 1958 Allows derogation from the CAA s44 prohibition on dark smoke emissions from vessels, allowing specified short-term emissions

    Clean Air (Emission of Dark Smoke) (Exemption) Regulations 1969 Disapply the CAA s2 prohibition on smoke emissions from industrial or trade premises in relation to burning

    Clean Air (height of chimneys) (exemption) regulations 1969 Sets out exemptions (eg for temporary plant) from the requirements of CAA s14 to have a chimney height approved.

    As exemptions from regulation in the Clean Air and Dark Smoke Acts, these four ‘regulations’ are a barrier to stopping air pollution. The regulations are pretty old, with modern biomass boilers not suffering from dark smoke, so we see no reason not to scrap these them. In fact, scrapping the exemptions might lead to economic stimulus if businesses replace older, polluting equipment and processes with more efficient new equipment and processes.

    What’s more, as the government is operating a ‘one in one out’ approach to regulation, this leaves room for some rather helpful new ones…

    - A strong Emissions Performance Standard (EPS) for power stations with grandfathering provisions (how long future plants can pollute for) linked to our carbon budgets. This would need to be designed to guide new and existing fossil fuel power plants to use Carbon Capture and Storage and Combined Heat and Power for baseload operation or to only run for short periods of time to help balance the power grid. This new regulation would give a clear pathyway for decarbonisation over the next two decades, and would help power companies and manufacturers to plan the most efficient way of decarbonising.

    - Make ecodesign regulations (eg. for ‘A’ rated freezers) progressive. This means de-linking energy use from size so that larger sized products would have to use the same amount of energy as smaller sized products. This would align UK product standards with forthcoming US product standards and help to counteract the trend of ever larger appliances undermining emissions reductions from product standards. We could also take an example from Switzerland, which will, in 2012, require all driers sold in Switzerland to carry the A rating, effectively banning conventional driers from the market.

    - Extend the ban, from 2018, on renting out properties in Energy Performance Certificate (EPC) bands F and G to sales of homes in these bands. Combined with the Green Deal, this would give owner-occupied households (around 67% of all homes) both a carrot and stick to improve energy efficiency.

    With a net reduction in regulations, these would meet Government’s desire to cut red tape while driving innovation in environmentally efficient technology and cutting energy use. What’s not to like?
14. Matt Wood on November 28, 2011 at 2:09 pm said:

    Do not to increase the speed limit on motorways from 70 to 80mph. This for me represents a bit of hippocricy. It goes against everything the government are telling us to do in every other aspect of our lives. We can no longer buy incandescent lightbulbs as they are not efficient enough, yet they are considering encouraging us to drive in a manner which is much less environmentally friendly. (Not to mention the safety implications of driving 10mph faster).Comment Tags: speed limit
    • Peter Chisnall on December 27, 2011 at 5:35 pm said:

      Totally agree, have any Ministers actually done the maths? Even if you could travel at 80mph saving 4 minutes on a 35 mile journey, 7.5 minutes on a 70 mile journey, 15 minutes on a 140 mile journey, 30 minutes on a 280 mile journey, travelling at 80 rather than 70 isn’t going to save the economy and will lead to more emissions and more fuel being used, Greenest Govt ever, pathetic.Reduce the speed limit to 60mph, may even make the roads flow more smoothly, get rid of the Dartford Toll the greatest congestion causer ever and a real barrier to improving the economy.
15. Peter Brown on November 28, 2011 at 9:29 am said:

    Planning Approval ought to be brought into the 21stC so that owners of Grade II listed buildings can bring their properties up to energy saving standards of other buildings. Currently individual planners obstruct improvements to these buildings. The issue can be dealt with in an aesthetic way.Comment Tags: Energy Saving, Grade II listing
16. Phil Jones on November 26, 2011 at 12:31 pm said:

    Merge the data collection/reporting processes for Display Energy Certificates (DEC) and Carbon Redction Comitment (CRC) – introduce DECs in all buildings to hightight poor performnce and use these as the basis for CRC – savings in bureacuracy, energy and carbon emmisions plus more jobs – see UKGBC report on DECsComment Tags: Phil Jones – Chair CIBSE Energy Performance Group
    • Sean McCarthy on November 28, 2011 at 10:16 pm said:

      I agree with Phil Jones of CIBSE. Not including DECs in the Energy Bill was a missed opportunity to support energy efficiency in buildings. Regulations can be beneficial to industry if they are applied in an even handed manner and have to general support of the sector to which they apply. The challenge for energy efficiency is to align the various standards, regulations, and indices etc . so that information such as energy or carbon data may be collected once in a standard format and used many times. It would also appear that nearly every department and many agencies “take the lead” on energy efficiency – DECC, Treasury, BIS, CLG, DEFRA, EA, OFGEM, HMRC etc.Comment Tags: energy efficiency