Elmhurst Energy responds to the Department for Energy Security and Net Zero’s consultation on proposed amendments to the Energy Company Obligation (ECO) schemes, specifically the Standard Assessment Procedure (SAP) and Reduced Data SAP (RdSAP).

In responding comprehensively to all 11 questions posed by the consultation, Elmhurst aims to contribute to the advancement of ECO4 and the Great British Insulation Scheme (GBIS) in a progressive manner.

Consultation Overview

In short, the Government proposes that both ECO4 and the GBIS use the latest SAP and RdSAP methodology versions. This covers both schemes for the period of Spring 2024 to March 2026.

Three options for this are provided within the consultation:

Option 1: Flexible Evidencing

The first option allows either RdSAP 2012 or RdSAP 10.2 to be used for 3 months following the RdSAP 10.2 launch. Scheme providers and regulators must support both versions during this period.

Option 2: Pre-determined Eligibility

The second option requires RdSAP 10.2 for retrofits after its launch. It allows RdSAP 2012 pre-assessments for proof of eligibility if conducted before the version change.

Option 3: Fixed Evidencing

The third option mandates RdSAP 2012 before the change and RdSAP 10.2 after. Retrofits risk ineligibility if starting efficiency rating improves. There is no need for industry or regulators to manage multiple software versions.

Elmhurst’s Response Summary:

• Elmhurst strongly advocates against running two methodologies concurrently (Option 1), citing the potential for unintended consequences. We recommend that Option 1 be removed from the process. Instead, we have a preference for Option 2, emphasising its immediate feasibility and lower risk to the industry.
• Regarding transition periods, Elmhurst supports a six-month window for using either SAP2012 or SAP10.2 for ECO4 retrofits, aligning with established industry guidelines for pre and post-project assessments.
• In response to potential risks associated with converting pre-retrofit SAP ratings from RdSAP2012 to RdSAP10, Elmhurst highlights the need for industry understanding and suggests that funding be based on the pre-assessment at the time.
• While Elmhurst does not see significant concerns in proposals related to District Heating Connections (DHC) and Ofgem’s scoring methodology updates, we emphasise the importance of regular methodology updates to reflect technological advancements and changes in energy generation.
• The proposed changes in RdSAP 10 are acknowledged to necessitate more time on-site for data collection. Elmhurst Energy suggests a review of pricing structures to account for the increased value of future domestic energy assessments.

Stuart Fairlie, Managing Director, comments:

“We cannot stress this enough. Option 1 within the consultation is not viable. We strongly feel that running two methodologies concurrently is entirely problematic. It has never been done before for RdSAP, and the potential disruption to the industry is something that would be difficult to justify for the relatively short period of time where this would apply. The sensible and pragmatic approach is clearly option 2, and we hope that this is the outcome chosen for the good of all stakeholders.”