The National Insulation Association (NIA), which represents UK insulation installers, system certificate holders and manufacturers, submitted its response to Ofgem's administration consultation on the Great British Insulation Scheme and the ECO4 amendment by the closing date of 16 June 20231. The consultation covered how suppliers would be monitored against targets, how carry-over and carry-under would work, how eligibility would be verified, and how the scheme would treat private rented homes and rural off-gas properties1.
The NIA agreed with Ofgem's proposed annual phase targets, which require suppliers to deliver a minimum number of measures in the first two years and reach at least 90% of the target within the relevant phase year, and with treating measures delivered on or after 30th March 2023 but before the ECO4A Order commenced as early delivery measures1. It supported unlimited carry-over between annual targets for the first two years, but said the carry-under mechanism should be used in exceptional circumstances whereby suppliers must have a valid reason for failing to meet their annual targets1. It also asked for more permitted carry-under between Years 1 and 2 because of the delayed start to the scheme1.
On eligibility, the NIA questioned reliance on Council Tax bands, which it said are largely out of date having been first valued in 1991 and again in 2003, and warned that collecting council tax bills from residents could delay compliance1. It opposed limiting households to single insulation measures and opposed a cap on innovation measures, and said draught proofing is missing from the list of eligible insulation measures1. It also asked for bulk submission of tenures and completed instalments, so that suppliers fitting instalments into a high rise block of flats can submit compliance in bulk1.
For private rented households, the NIA said low-cost measures such as loft and cavity wall insulation should be offered alongside higher-cost measures such as solid wall insulation1. It cited the English Housing Survey 2021-2022 showing cavity wall insulation rates of 61% in the private rented sector, 71% of owner-occupied homes and 77% of social rented homes, and DESNZ data showing 29% of cavity walls and 33% of lofts in the UK were still uninsulated1. It said 24.1% of private rented households were estimated to be in fuel poverty on the latest available data, which predates the steep rise in the energy price cap1.
The NIA opposed the proposal that the 20% uplift for rural off-gas properties apply to Scotland and Wales only, not England1. It said the stated reason, overlap in rural areas with the Home Upgrade Grant 2, was limited in practice because up to 80% of households targeted by the scheme are set to come from the general eligibility group rather than the low-income group1. It said only one-third of off-gas properties are EPC band A-C and 20.1% are fuel poor1.
"The scheme includes a 20% uplift for rural off-gas properties. However, under the current proposals, this uplift will apply to Scotland and Wales only, not England."
The NIA also said the number of households spending over 10% of their income on energy costs is projected to double in 2023 to 8.83 million, and that insulation could have saved £18 billion spent on subsidising energy bills over the course of the Energy Price Guarantee1.
Why it matters for households
The consultation set the administrative rules for how insulation is delivered under the Great British Insulation Scheme and the ECO4 amendment, so the points the NIA raised bear on which homes can be treated and how quickly. A single-measure limit would mean a home could receive one insulation type rather than a package, and a cap on innovation measures would restrict the use of less established products. Excluding loft and cavity wall insulation for private rented households would remove the cheapest measures from that group, which the NIA says has the lowest insulation rates and the highest fuel poverty rate of the tenures it cites. The rural uplift question matters for off-gas homes, which the NIA says are less energy efficient and more often fuel poor than on-gas properties, and which are often harder and costlier to treat. Eligibility verification through Council Tax bands bears on whether a household can demonstrate it qualifies, and on how long that takes. The Ofgem consultation is part of the wider regulation and energy independence framework that determines what a household can have installed and on what terms.
What happens next
Ofgem's consultation closed on 16 June 20231. The sources do not report when Ofgem will publish its response or the final scheme rules, or whether the NIA's positions will be adopted.