GDPF 150327 - Decisions and Actions
Transcription
GDPF 150327 - Decisions and Actions
Provider Forum Decisions and Actions Meeting title: Green Deal Provider Forum 150327 Date of Meeting: 27h March 2015 Attendees: Number Organisation Name Type In attendance 1. British Gas Graham Weller Provider (Chair) 2. Network Green Deal Jane Knight Provider Neil Pittam Electrical Installations Ltd Neil Pittam Provider Trevor Thompson Provider 3. 4. T/A U need Energy Neil Pittam Electrical Installations Ltd T/A U need Energy 5. Solarwise Renewables Roy Tomkinson Provider 6. Westdale Services Ltd Malcolm Kitching Provider 7. DECC Matt Webb Government (part) 8. DECC Tim Charters Government (part) 9. REAL Mark Cutler GD ORB (part) 10. Gemserv Inga Jirgensone GD ORB 11. Gemserv Louise Evans GD ORB 1North Lee Rowlinson Provider GoSolar Energy Solutions Ltd (t/a Elinor Jenkins Provider Green Deal Express Jo Scaiffe Provider 1. EDF Energy Customers PLC David Nutt Provider 2. Osborne Energy Nicole Barrett Provider 3. InstaGroup Ltd Lucy Shadbolt Provider 4. MEB Total Limited Billie Alcock Provider 5. Willmott Dixon Energy Services Ltd David Adams Provider 6. Your Green Deal Provider Ltd John Johnson Provider 7. DECC Ben Golding Government Dial-in 12. 13. 14. Enhance Energy) Apologies 1 Decisions and Actions – Final V1.0 23rd April 2015 8. DECC John McKenna Government 9. UKSS Renewable Energy Services Sue Beardmore Provider 1. WELCOME AND INTRODUCTIONS The Chair welcomed everyone to the meeting and invited introductions from the participants. 2. ACTIONS FROM THE PREVIOUS MEETING There were four outstanding actions. Updates on these actions and agreed new actions are recorded in Annex A of these minutes. Under Action: GDPF 09-04, GD ORB provided some clarification to members on the Consumer Contracts Regulations (CCR) where definitions of ‘home selling’ and ‘distance selling’ differ to those in Doorstep and Distance Selling Regulations, an issue which was brought to the attention of the group at the previous Provider Forum meeting. The group heard from GD ORB that: The new cancellation rights set out in the CCR apply to ‘off-premises’ and ‘distance’ contracts – defined as: o Off-premises: if a consumer is asked to sign a contract during a sales visit to their home, elsewhere or away from the company’s trade premises in the presence of a company representative. Or, the customer is not given adequate “time to reflect” and is pressured to sign. o Distance: contract that has been negotiated and agreed exclusively by distance means (by post or email). However, an agreement can still be a ‘distance contract’ even if a company representative visits the customer’s home. For example, if a company representative visits a customer for the sole purpose of completing a technical survey and then the quote/order form is sent to the customer and the contract is subsequently completed by post or email. If a Green Deal Provider visited a customer’s house and left the contract with the customer to sign in their own time then this would be on premises, and if a Provider were to also state to the customer that the offer would shortly expire, then that would be classified as ‘distance’ as this action could be considered to be putting pressure on the customer. Some concern was expressed about these regulations with regards to Green Deal finance as if a customer has committed to finance and then changes their mind after the goods have been installed, then the finance agreement will be void. 2 Decisions and Actions – Final V1.0 23rd April 2015 It was argued that the stipulated 14 day calling off period required is not always possible in the renewable sector as when goods are delivered, particularly in the case of Solar Photovoltaic (SPV), they are also installed at the same time. It was agreed that while the purpose of the regulations is to harmonise EU law, the regulations are not entirely practicable in the renewable industry sector. The group were informed that companies can start installation work before the end of the cancellation period, but only if the customer gives ‘express permission’ for this. Express permission cannot simply take the form of a tick box. The Chair requested an example of ‘express permission’ be provided to the forum members. Action GDPF 150327-01: GD ORB to circulate a communication to Providers clarifying the Consumer Contracts Regulations (CCR) requirement of 14 day calling off period and provide a best practice example of expressed consent form. 3. GREEN DEAL POLICY SOLUTIONS FOR THE NEXT GOVERNMENT DECC invited considerations from the group with regards to Green Deal policy solutions for the next Government and thanked the group for their suggestions that were agreed to be thoughtful and valuable. The key suggestions of the group were: Consistency in delivery from point of investment in businesses to the end result. For example, the changes to ECO in December last year had an adverse impact on many businesses. The Green Deal Home Improvement Fund (GDHIF) was also provided as an example as the supply chain inform customers that cashback is available through GDHIF only for the various phases of the fund to close shortly afterwards. It was, however, noted that this issue has been considerably improved with the staggered releases of GDHIF funding due to increased visibility of the releases and back office systems becoming increasingly robust. Funding must be made available for Solid Wall Insulation due to the cost of installation and the need for large-scale installation. Green Deal and other energy efficiency scheme participants should have access to the whole market of customers. Currently, the options for achieving this are limited in that either: o A business can offer a discount for the installation of measures so that the fuel poor can afford to improve the energy efficiency of their home which is not a feasible business model for most Providers; or o Participants can move into the realm of finance, as is the case with the Green Deal where some customers do not meet the funding criteria and, again, would be excluded. These two options prove to be either detrimental to energy efficiency businesses or fuel poor customers who would benefit most from energy efficiency improvements to their homes. A suggestion to improve this was to lower the figure for GDHIF and blend the funding with ECO, by blending funding together between schemes, more customers would be eligible for having 3 Decisions and Actions – Final V1.0 23rd April 2015 measures installed and scheme participants would therefore have more of an incentive to be involved in the Green Deal and the energy efficiency market more generally. Participants could adopt a ‘whole house’ approach and encourage the installation of multiple measures. With regards to the branding of the Green Deal, Forum members suggested that changing the name of the Green Deal may not be feasible at this stage due to the associated administrative issues and agreed that the Green Deal has come to be a strong brand. One participant reminded the group that the initial purpose of the Green Deal is to reduce carbon emissions which should remain the focus of the scheme. From a regulatory perspective there should be stricter monitoring of participation in the Green Deal particularly with regards to the quality of installations. GD ORB informed attendees that improving the quality of Green Deal installations is a priority for GD ORB and is being progressed via the technical working groups and also in relation to consumer protection. 4. FCA AUTHORISATION APPLICATION ISSUES One Provider suggested that, despite FCA’s approach to assess each individual business model separately from each other, standardisation of what Providers are required to submit should be in place due to the fact that Providers must remit Green Deal charges and do not have a choice in this matter as a party to the GDAA. GD ORB informed Provider Forum members that the FCA webinar FAQs can now be found on the GD ORB website here. At the last meeting of the GDAA Panel the issue of FCA authorisation was also discussed and an action was taken to have a direct joined up session to the discuss FCA requirements in relation to the GDAA with the intention of making sure the GDAA remains fit for purpose. Another Provider suggested that Providers submit to the FCA a thorough but simple business process and that they key is to ensure that the process and procedures followed exactly and are tested against the organisation’s day to day activities and fit within FCA’s guidelines. This approach is likely to be more successful than designing a flawless process that is not necessarily practicable. GD ORB informed the group that there are currently nine Providers with full FCA permissions and will continue to monitor the progress of Providers in attaining the required permissions. 5. ASSESSMENT OF BOILERS – HHCRO AND GREEN DEAL DECC informed the group that a query had been received about a line in the communication concerning electrical heating and that DECC have been following up over the interpretation of this line. 4 Decisions and Actions – Final V1.0 23rd April 2015 Action GDPF 150327-02: DECC to revise the DECC news bulletin Assessment of Boilers – HHCRO and Green Deal and GD ORB to re-circulate the communication clarifying the change. One Provider queried whether European Regional Development cannot be blended with ECO or the Green Deal which, if the case, would be problematic as many authorities rely on a certain amount of blending for certain projects. GD ORB informed the forum that a similar issue has been formally raised with GDAG and DECC agreed to investigate the issue and report back to the forum. Action GDPF 150327-03: GD ORB to clarify with DECC whether European Regional Development Funding can be blended with ECO and/ or the Green Deal and report back to the forum. 6. DECC CONSUMER FIRST PROJECT DECC informed the group that the Consumer First Project is working to ensure that customers are brought into heart of DECC policy making. This has been developed as part of DECC’s actions in response to the Government Digital Strategy (https://www.gov.uk/government/publications/department-for-energy-andclimate-change-government-digital-strategy-actions/deccs-actions-in-response-to-the-government-digitalstrategy) One Provider commended the project and suggested this is a positive way of thinking by having a core team of people working closely from the beginning of a process and using this to build a digital interface and use existing data sources more cleverly. 7. GDAA UPDATE In the Panel Chair’s absence, GD ORB provided a summary of the key GDAA updates, including: The GDAA 2015 budget is to be confirmed soon and that the GDAA self-funding will start from 1st July. From this date, all GDAA parties will be required to contribute the £1000 fixed fee element. Agreement of the budget has not yet been confirmed in writing but DECC are looking to cover the remainder of the cost (variable cost) for the remainder of 2015. Next year the variable cost (per plan) will be paid for by parties to the GDAA. The GDAA Special Purpose Vehicle (SPV) is scheduled to be in place by 1st July 2015. The next GDAA Performance Reporting Workshop is scheduled to take place in May 2015. The group heard from GD ORB that the group has made a lot of progress based on input from parties on their day to day experiences in respect of reporting. With regards to the GDAA 2016 budget, one Provider queried whether existing plans up to this point will be sacrosanct. GD ORB confirmed that the variable cost will be spread across all plans that are currently live and the idea is that the more plans there are, the smaller the cost will be per plan. Providers expressed some concern at the additional costs involved that will be applied to each existing plan as this cost was not factored in at the point of agreeing finance with the customer. 5 Decisions and Actions – Final V1.0 23rd April 2015 8. ISSUES LOG The Provider Forum members reviewed the issues captured on the current issues log in order to decide upon the priority issues and identify issues that have been resolved and can be removed from the log. The following key issues were discussed: Golden Rule methodology. The IRR-002-GDPF issue cannot be progressed any further until after the election but Providers reiterated the importance that the issue be addressed. One Provider requested an update on a reported case of Provider non-compliance and GD ORB confirmed that the GD ORB compliance team is investigating this case. With regards to issue IRR-012-GDPF and FCA permissions, one Provider suggested that some Providers have lost a proportion of the supply chain who are deterred from involvement in the Green Deal due to the requirement to have FCA permissions. The group agreed to follow up on issues after the election in May. 9. AOB There was no further business and the Chair closed the meeting. 6 Decisions and Actions – Final V1.0 23rd April 2015 Annex A ACTIONS OUTSTANDING Action Ref Description By Who Date of completion Update Post-meeting note: DECC have published carbon savings from GDHIF as part of our quarterly Green Deal and ECO stats release. The latest quarterly release can be found here (see Table 1.15): https://www.gov.uk/government/statistics/green-dealenergy-company-obligation-eco-and-insulation-levelsin-great-britainquarterly-report-to-december-2014 Action GDPF 09-02 DECC to raise Provider concerns regarding the need to undertake technical monitoring of GDHIF installations in order to verify carbon reduction savings, and report back the Forum on what steps are being taken. DECC 23/04/2015 The methodology behind how the carbon savings are calculated can be found in the following methodology note (page 29 covers GDHIF): https://www.gov.uk/government/statistics/domesticgreen-deal-and-eco-statistics-methodology-note The Scheme Administrator currently conducts on-site audits of a proportion of properties under GDHIF to ensure that energy efficiency measures have been installed (and therefore assumed carbon-saving realised), and there are further provisions for additional technical monitoring. 7 Decisions and Actions – Draft V1.0 10th February 2015 This action is closed. Action GDPF 09-05 Action GDPF 150327-01 Action GDPF 150327-02 Action GDPF 150327-03 DECC to clarify and provide written confirmation of the Ombudsman arrangements for Green Deal Providers. GD ORB to circulate a communication to Providers clarifying the Consumer Contracts Regulations (CCR) requirement of 14 day calling off period and provide a best practice example of expressed consent form. DECC to revise the DECC news bulletin Assessment of Boilers – HHCRO and Green Deal and GD ORB to re-circulate the communication clarifying the change. GD ORB to clarify with DECC whether European Regional Development Funding can be blended with ECO and/ or the Green Deal and report back to the forum. DECC 22/05/2015 The Green Deal Ombudsman Service has provided a written statement clarifying the investigation fees protocol between the Green Deal and Financial Ombudsman. The FOS Policy Director is to be installed in the near future, following which further clarification on subscription fees will be provided to Providers. GD ORB 22/05/2015 The communication is under development and is expected to be circulated shortly. DECC / GD ORB 22/05/2015 Final wording of bulletin is being agreed. It is intended that the communication will be reissued with an additional statement to clarify imminently. 22/05/2015 A guidance document on blending various energy efficiency schemes and funding streams is under development. GD ORB / DECC ACTIONS CLOSED AT THE MEETING Action Ref Description By Who Date of completion Update 8 Decisions and Actions – Final V1.0 23rd April 2015 Action GDPF 09-03 DECC to raise issue of product warranties undermining IBGs internally with the appropriate team, and report back the Provider Forum. Action GDPF 09-04 GD ORB and DECC to clarify the implications of the Consumer Contract Regulations for the DECC/GD Green Deal and report back to the Provider ORB Forum on how these regulations can be met in practice. DECC 27/03/2015 27/03/2015 Initial feedback on the issue has been collected and reported to DECC. Provider Forum members were invited to confirm whether additional evidence on the issue needs to be collected and submitted to DECC and it was agreed that this is not necessary. The action was closed at the 27th March meeting. GD ORB provided an update to Provider Forum members at the 27th March GDPF meeting. GD ORB agreed to circulate a communication to Providers clarifying the requirements. The action was closed at the 27th March meeting. ACTIONS CLOSED SINCE THE PREVIOUS MEETING Action Ref Description By Who Date of completion Action GDPF09-01 Provider Forum members to draft a letter to the GDFC to request confirmation that the GDFC Green Deal Plan documentation has been approved by the FCA. Provider Forum 13/03/2015 Action GDPF09-06 The GD ORB to arrange a teleconference for Provider Forum members to have an initial discussion on the Provider/GDFC service level agreements. GD ORB 19/02/2015 Update A letter has been drafted by a number of Provider Forum members, which has been circulated to the Provider Forum for comment and to request confirmation of support (supporting Providers will are signatories to the letter). The letter will be sent to the Green Deal Finance Company (GDFC) and be accompanied by GDFC Service Level Agreement (SLA) Strawman. Please see Action GDPF 09-06. A teleconference was organised on the 19th February. Feedback on the 'Strawman' document was taken to be incorporated. Further feedback was sought and incorporated from the Provider Forum Co-chairs. The 9 Decisions and Actions – Final V1.0 23rd April 2015 'Strawman' has been circulated to the Provider Forum members for comment, alongside a supporting letter (Please see Action 09-01). 10 Decisions and Actions – Final V1.0 23rd April 2015