We welcome the opportunity to respond to your consultation on the Green Deal Framework. We have responded to a number of your specific questions in the attached Annex and have outlined below the key points we wish to make.
Gemserv has been involved in the Green Deal since its inception, operating three central roles. Being at the heart of the administration of the Green Deal gives us a unique perspective of what has worked well and what lessons must be learnt going forward to evolve the sector. Moreover, our wider experience of developing and operating a large number of industry funded schemes across the energy efficiency, microgeneration and energy industries, offers a further practical insight, both in terms of what is required to optimise scheme administration and what principles must apply to support businesses and consumers alike.
The following summaries our key points:
- There is a clear role for a PAYS mechanism, and the infrastructure that supports it, to enable householders and businesses to become more energy efficient;
- We welcome simplification, provided that at least the same level of consumer protection is retained. For example, the application process for Providers can be simplified in line with the FCA requirements, allowing greater attention to be placed on ongoing participant auditing and technical monitoring by the GD ORB;
- There is a need to ensure assessments are undertaken independently, to ensure only those measures that are suitable for a property are recommended;
- A number of activities could be undertaken at the Each Home Counts level, provided the Quality Mark and how it operates develops in such a way as to at least maintain the same level of consumer protection as is currently present in the Green Deal scheme; and
- The GDAA should be moved to sit under the MRA, thereby removing duplication and reducing costs to participants and consumers.
To read our full consultation response please click on the link below: