Multi-Organisation Reponse to DECC Consultation on The role of appliances and consumer electronics in the CERT (2011)

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This multi-organisation response was coordinated by Waterwise. Signatories to this response agree that CERT has been a useful mechanism to help the UK deliver its carbon emission reduction targets and stay within carbon budgets. It is recommended that the Coalition Government should review the existing function and scope of CERT within the extension period and in particular look at the role of non-insulation measures. We are of the opinion that the current scope of CERT should be maintained during the extension period, but with greater enforcement of existing regulation and amendments which maximise the potential for promoting joint water and energy programmes to ensure cost-effective CERT delivery.

Overview

Signatories to this response agree that CERT has been a useful mechanism to help the UK deliver its carbon emission reduction targets and stay within carbon budgets. We think it is right that the Coalition Government should review the existing function and scope of CERT within the extension period and in particular look at the role of non-insulation measures. We are of the opinion that the current scope of CERT should be maintained during the extension period, but with greater enforcement of existing regulation and amendments which maximise the potential for promoting joint water and energy programmes to ensure cost-effective CERT delivery. This would help deliver other Coalition Government objectives such as increasing water efficiency and setting in place the most effective framework to nudge consumers into sustainable behaviour, which will be particularly important to ensure widespread take-up of the Green Deal, once CERT ends.

The potential for addressing carbon emissions from homes through hot water efficiency measures is not being fully realised. CERT is beginning to be used to fund joint water and energy retrofitting projects – to help reduce the 5% of total UK greenhouse gas emissions which is accounted for by heating water in homes, and to help water companies address water scarcity issues. But there is a danger of the current CERT model developing at a strategic level without taking the potential carbon savings from water efficiency fully into account. There is a particular problem around additionality which prevents both CERT and Water Efficiency Targets being met by the same measure: this is not a deadweight issue as water companies would not (indeed did not) promote the current hot-water-saving devices in the absence of CERT. Indeed, the three CERT-accredited devices have been specifically designed to meet the requirements of the CERT programme rather than to meet the Water Efficiency Targets.

Below, we respond to the specific questions set out in the consultation document, as well as making wider points relating to CERT, ECO (the proposed successor to CERT) and the Green Deal.

In this context, it is important briefly to set out that water efficiency measures across the board– hot and cold – have an important role in their own right in the UK’s programme to adapt toclimate change: some areas of England are already classified by the Environment Agency as seriously water-stressed, and it is known that in coming years there will be more people and less water, so the available water will need to go further, through water-efficient homes, buildings, and people. In addition, the Coalition Government is committed to publishing a White Paper on reform of the water sector to ensure a more efficient use of water (and protect poorer households), by June 2011, and to introducing legislation by May 2012.

More widely, the Coalition Government’s National Infrastructure Plan, published in October 2010, identifies current barriers to strategic working between regulated economic sectors, and sets out measures to address these, to be taken in the next six months. Removing the one potential regulatory mechanism which currently enables joint working between the water and energy sectors – namely, the inclusion of hot-water-using devices in CERT – would be a step away from this overall goal, and would send a confusing message to consumers whom the Coalition Government will wish shortly to sign up to the Green Deal (which, as the National Infrastructure Plan also stated, will include water efficiency as well as energy efficiency). Since both industries have demand management targets – for energy and water respectively – there is also a significant financial incentive to carrying out joint retrofits (not least because the biggest cost of a retrofit is the visit to the home itself).