Flexible Eligibility Statement of Intent - Version 5

This statement sets out our flexible eligibility criteria for the Energy Company Obligation (ECO4) scheme from April 2022 to March 2026.

The ECO4 scheme will focus on supporting low-income and vulnerable households. The scheme will improve the least energy-efficient homes helping to meet the Government’s fuel poverty and net zero commitments.

The flexible approach for Local Authorities (LAs) to identifying fuel-poor and vulnerable households who may benefit from heating and energy-saving measures is referred to as “ECO4 Flex”.

We welcome the introduction of the ECO4 Flex eligibility routes as it helps us achieve our plans to improve the homes of those in fuel poverty or vulnerable to the cold.

We are publishing this Statement of Intent (SoI), on 1 August 2022 to confirm that each of the households declared will adhere to at least one of the four available routes outlined below:

• Route 1: SAP bands D-G owner-occupied households and private rented sector E-G households with an income less than £31,000. This cap applies irrespective of the property size, composition, or region.
• Route 2: SAP bands E-G for owner-occupied households and private rented sector households that meet a combination of two of the following proxies:
  • Proxy 1) Homes in England in Lower-layer Super Output Area 1-3 (LSOA)*, or homes in Welsh provision LSOA 1-3 on the Welsh Index of Multiple Deprivation 2019**, or the Index of Multiple Deprivation for 2020, published by the Scottish Government***
  • Proxy 2) Householders receiving a Council Tax reduction (based on low income only).
  • Proxy 3) Householders vulnerable to living in a cold home as identified in the National Institute for Health and Care Excellence (NICE) Guidance. Only one from the list can be used, excludes the proxy ‘low income’.
  • Proxy 4) A householder receiving free school meals due to low-income.
  • Proxy 5) A householder supported by a LA-run scheme, that has been named and described by the LA as supporting low-income and vulnerable households for the purposes of NICE Guideline.
  • Proxy 6) A household referred to the LA for support by their energy supplier or Citizen's Advice or Citizen’s Advice Scotland, because they have been identified as struggling to pay their electricity and gas bills.

Note proxies 1 and 3 cannot be used together.

• Route 3: SAP bands D-G owner-occupied households and private rented sector E-G households that have been identified by their doctor or GP as low-income and vulnerable, with an occupant whose health conditions may be impacted further by living in a cold home. These health conditions may be cardiovascular, respiratory, immunosuppressed, or limited mobility related.

This is because we have identified a positive correlation between households who suffer from long-term health conditions and living off a low-income, with living in poorly insulated homes.

* The English Indices of Deprivation 2019 (publishing.service.gov.uk)

** Welsh Index of Multiple Deprivation (full Index update with ranks): 2019 | GOV.WALES

*** Scottish Index of Multiple Deprivation 2020 - gov.scot (www.gov.scot)

Declaration and evidence check confirmation

This statement sets out our flexible eligibility criteria for the ECO: Help to Heat programme April 2018 until the scheme finishes. It aims to support households living in Torbay who are most likely to experience fuel poverty and those vulnerable to the effects of a cold home.

We welcome the introduction of Flexible Eligibility and intend to utilise it for the purpose of reducing fuel poverty within the bay. We have worked for many years to improve homes across Torbay with the aim of increasing energy efficiency and reducing fuel poverty.

It should be noted that the final decision on whether any individual household will benefit from energy-saving improvements or heating rests with obligated energy suppliers or their contractors. Inclusion in a Declaration of Eligibility issued by us to a supplier will not guarantee the installation of measures. The final decision will depend on;

1. identification of measures eligible under Help to Heat
2. the supplier's assessment of the cost-effectiveness of installing measures in relation to achieving its obligation
3. whether the supplier has achieved their targets or requires further measures to meet their Energy Company Obligation targets.

We expect that energy suppliers or agents of energy suppliers involved in flexible eligibility surveys and works identified will comply with the Data Protection Act in accordance with Ofgem requirements, will act in accordance with industry best practices in relation to consumer care and quality standards and will comply fully with the requirements set out in The Electricity and Gas (Energy Company Obligation) Order 2018.

Practices associated with cold calling must be undertaken appropriately and sensitively. Companies and individuals must not falsely represent their association with us and must not use the Torbay Council logo on paperwork unless formally agreed. Homes displaying ‘No Cold Call’ signage must not be engaged with.

At initial engagement with prospective clients, representatives must confirm who they are, which company they are working for, and whether that company has been subcontracted by another company or will be selling on householder details.

A list of completed works must be submitted to us monthly confirming the client's name and property address, what works have been completed, the impact of improvement on energy rating and any financial details including any costs met by the client.

The administration charge levied by us in providing the declaration necessary for clients to access the ECO Flexible Eligibility Scheme is £200. This charge must be paid by the energy supplier or their agent and may NOT under any circumstances, be passed on to the client receiving assistance via the scheme. Billing will be monthly.

Failure to pay a monthly bill may lead to declarations associated with the Energy Company being refused.

We reserve the right to waive administration costs where we are working in partnership with an Energy Company or its representatives.

All potentially eligible households should apply through an energy agent or one of their approved ECO installers to ensure that they can either benefit from the scheme or be assessed for eligibility under any other relevant programme.

The officer below will be responsible for checking and verifying declarations and associated evidence submitted on behalf of the local authority:

Name: Samantha Hart
Job Title: Interim Housing Standards and EP Manager
Telephone: 01803 201201
Email: housing.private.sec@torbay.gov.uk

CEO or dedicated responsible person mandatory signature

We will administer the scheme according to BEIS’ ECO4 Order and will identify eligible households via Ofgem’s application process. The Director of Community and Customer Services of the Council will oversee the process of identifying eligible households under ECO4 Flex.

The eligibility information will be stored securely in line with the Council’s data protection policy, Information Commissioner’s Office Data Sharing Code, and BEIS guidance.

Name: Tara Harris
Job Title: Divisional Director of Community and Customer Services
Date of signature: 1 August 2022

For any general enquires relating to this SoI, please contact housing.private.sec@torbay.gov.uk