Given the stated aim to target low income, fuel poor and vulnerable households; NEA believes it is paramount that beneficiaries of the scheme receive adequate consumer protections. Government have assumed that there will be no household contributions made during the course of the policy, however this practice is still allowed. Although outside of this consultation, this is still a major consumer protection concern of NEA. We therefore believe that household contributions must be capped and monitored rigorously by Ofgem. This can be captured on standard forms and would be useful to determine how successful the scheme is at targeting households in the deepest fuel poverty. This was a key observation of the National Audit Office (NAO)’s 2016 investigation into the Green Deal and ECO, as well as the BEIS select committee report on energy efficiency.
NEA supports the Government’s attempts to drive up consumer outcomes within ECO. It should also resource the enforcement of quality against this accreditation. As noted above, this should be supported by ECO obligated suppliers communicating the support that is available through ECO in more consistent and assessable formats, installers providing adequate advice to maximise the benefits of the energy saving measuring being installed and ensuring suppliers and contractors highlight how other forms of supplier-led assistance can be accessed if the most vulnerable fail to benefit from energy saving measures under the scheme. NEA also seeks for the Government (and Ofgem) to stipulate the need for obligated suppliers to uphold their obligations to treat their customers fairly and respond to the enhanced needs of those in vulnerable situations. This can be achieved by communicating the support that is available through ECO in more consistent and assessable formats, provide adequate advice to maximise the benefits of the energy saving measures being installed and ensure any contractors highlight how other forms of supplier-led assistance can be accessed if the most vulnerable fail to benefit from energy saving measures under the scheme. These obligations need to be adequately reflected in the contracts that suppliers have with their partners that deliver the scheme on their behalf them.
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