Consultation Outcomes: ECO4 & GBIS Consultation and TrustMark License Plus for GBIS
Today, both Government and Trustmark have released their outcomes for the following consultations:
- ECO4 and GBIS: Proposed Mid-Scheme Changes and Pay-For-Performance Mechanism
- TrustMark Licence Plus (TMLP) for the Great British Insulation Scheme (GBIS)
Both closed for public comment on 12th December 2024 and we are taking a look at the key outcomes from these responses.
What was the ECO 4 and GBIS consultation about?
The consultation was published by government to capture views on various proposed mid-scheme changes to Energy Company Obligation 4 (ECO4) and the Great British Insulation Scheme (GBIS), as well as the introduction of a voluntary Pay-For-Performance (PFP) mechanism.
For more information on what the consultation covered, please read our recent news article: Government Consultation on ECO4 and GBIS: Proposed Mid-Scheme Changes and Pay-For-Performance Mechanism
Elmhurst reviewed the consultation and submitted a response on behalf of its members. The consultation had a total of 122 responses from a broad range of stakeholders including obligated energy suppliers, local authorities, energy efficiency installers, trade bodies, consumer advice organisations, and academic institutions. We take a look at what the government decided on these key points below:
Key Response Points
Broader Adoption of Insulation Measures
Elmhurst’s Response: Elmhurst supported the proposal for households to receive both loft and cavity wall insulation under GBIS.
Government Response: Government will introduce the above change as a result of the feedback. Elmhurst believe this is a positive step to improve delivery and adoption of the scheme across the country.
Integration of Pay-for-Performance (PFP)
Elmhurst’s Response: Elmhurst strongly advocated for incorporating PFP models, particularly through SMETER technology, to enhance scheme accuracy and efficiency.
Government Response: The government are no longer proposing to pilot PFP in ECO4 and GBIS. This is mainly due to the limited time before the schemes end in March 2026 and there would not have been enough time to prepare. The Government also felt that due to recent quality issues with solid wall insulation in GBIS and ECO4 retrofits, piloting a new mechanism now would divert resources from addressing these problems, despite the potential benefits of PFP in improving retrofit quality.
Quality Assurance in SMETER Implementation:
Elmhurst’s Response: Elmhurst stresses the importance of robust quality assurance, advocating for a competency scheme (like their Measured Energy Performance scheme) to ensure the integrity of data and processes, including audits, lodgements, and adherence to methodologies.
Government Response: It was positive to see that government noted the significant benefits that SMETER technology could have and that they will continue to explore approaches to quality assurance prior to any widescale, national introduction.
Acknowledgment of In-Situ Measurements:
Elmhurst Response: While emphasising SMETER, Elmhurst also highlighted the value of in-situ U-value measurements and airtightness tests for evaluating insulation and airtightness interventions, proposing their formal integration into both Retrofit and EPCs.
Government Response: No official mention of these within their consultation response but Elmhurst will continue to emphasise this point moving forward.
ECO4 and GBIS: Proposed Mid-Scheme Changes and Pay-For-Performance Mechanism
View the full consultation response here.
Read the full response >
New TrustMark Licence Plus (TMLP) for the Great British Insulation Scheme (GBIS)
In addition to the government consultation, TrustMark have also published a response on their consultation covering the TrustMark Licence Plus (TMLP) for the Great British Insulation Scheme (GBIS).
The consultation sought views on TMLP as an alternative standard for loft insulation when installed as a standalone measure or paired with heating controls (HCs) under GBIS, as well as the strengthening of financial protection within the scheme. Although this consultation was delivered by Trustmark, the overall decision on TMLP for GBIS was to be made by DESNZ.
For more information on what this consultation covered, read our recent news article: TrustMark Consultation: New TrustMark Licence Plus (TMLP) for the Great British Insulation Scheme (GBIS)
Response Summary
Elmhurst Response: Elmhurst agreed with a lot of points raised within this consultation regarding TMLP for GBIS. As stated in our response to the ECO4 and GBIS Consultation (Questions 13 & 14), we believed this approach offered a pragmatic solution for delivering loft insulation as a single measure and key concerns had been identified as part of the consultation process.
Government Response: However, contrary to the positive responses Government decided to not proceed with the use of TMLP for GBIS at this time. The reasons, outlined in the Government’s response to the ECO4 and GBIS consultation (Questions 13 & 14), primarily stem from concerns that introducing an alternative standard could cause confusion among Installers, TrustMark, Scheme Providers, and the wider industry. The Government acknowledged the overall supportive responses and the aims of TMLP for GBIS and will continue to consider alternative standards in future scheme designs.
Trustmark Response: Trustmark noted that they respected the decision made by DESNZ but were clear that TMLP for GBIS received a high level of support and they received valuable feedback which will be used moving forward.
TrustMark Licence Plus (TMLP) for the Great British Insulation Scheme (GBIS)
View the full consultation response here.
Read the full response >
Elmhurst’s Thoughts
Steven Marriott, Elmhurst’s Retrofit Scheme Manager, comments on these responses and what this means for industry:
“We are pleased to see the addition of ECO 4 measure been adopted under GBIS in relation to cavity wall insulation and loft insulation. This will hopefully lead to better installs an improve the cost-effectiveness of the projects allowing better insulation to be undertaken where practical. This is a positive step forward under the funding strand and should bring about more work for our members.
While we understand that delays did prevent PFP being adopted/considered, Elmhurst hope to see further investigation of this and other such metrics like SMETER in the running and look forward to it including in future funding opportunities.”