Flexible Eligibility Statement of Intent - Version 7

This statement sets out Torbay Council’s flexible eligibility criteria for the Energy Company Obligation (ECO4) scheme and Great British Insulation schemes which run until 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 Great British Insulation Scheme will support the ECO4 scheme in the delivery of predominantly single measures targeted at a wider range of households.

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” and “Great British Insulation Scheme Flex”.

The Council is publishing this Statement of Intent (SoI), on the 20 November 2023 to confirm that each of the households declared will adhere to at least one of the four available routes outlined below:

• Route 1: Owner-occupied and private rented sector households with a gross annual income less than £31,000. This cap applies irrespective of the property size, composition, or region
• Route 2: Owner-occupied 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)[1], or homes in Welsh provision LSOA 1-3 on the Welsh Index of Multiple Deprivation 2019[2], or the Index of Multiple Deprivation for 2020, published by the Scottish Government[3]*
  • 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’.[4]*
  • Proxy 4) A householder receiving free school meals due to low-income.[5]
  • 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: Owner-occupied and private rented sector households that have been identified by either a person registered in the General Practitioner Register, a Scottish Health Board, a Welsh Health Board, an NHS Foundation Trust, or an NHS Trust as vulnerable, with an occupant whose health conditions may be adversely affected by living in a cold home. These health conditions must be cardiovascular, respiratory, immunosuppressed, or limited mobility related. This is because the Council has 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.
• Route 4: Not used.

Scheme eligibility

All potentially eligible households should apply through Torbay Council or one of their approved ECO / Great British Insulation Scheme installers, if a list of approved installers is available, to see if they can either benefit from the scheme or be assessed for eligibility under any other relevant programme.

Torbay Council welcomes the introduction of Flexible Eligibility and intends to utilise it for the purposes of reducing fuel poverty within the bay. The Council has 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 the Council to a supplier will not guarantee 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 require further measures to meet their Energy Company Obligation targets.

Torbay Council expects 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 practice 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 2022 (ECO4 Order).

Practices associated with cold calling must be undertaken appropriately and sensitively. Companies and individuals must not falsely represent their association with Torbay Council 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 Torbay Council monthly confirming the client's name and property address, what works have been completed, impact of improvement on energy rating and any financial details including any costs met by client.

The administration charge levied by Torbay Council 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.

Torbay Council reserves the right to waiver administration costs where it is 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 LA officer below will be responsible for checking, and verifying evidence, and issuing declarations submitted on behalf of the local authority. For any general enquiries relating to this SoI please contact:

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

Torbay Council will administer the ECO4 Flex scheme according to the Electricity and Gas (Energy Company Obligation) Order 2022 (ECO4 Order).

The Council will administer Great British Insulation Scheme Flex according to the Electricity and Gas (Energy Company Obligation) Order 2023 (ECO4A Order).

The CEO/ dedicated responsible person of the Council will oversee the process of identifying eligible households under ECO Flex and Great British Insulation Scheme Flex. The Council will notify Ofgem of households that declarations have been issued for via the declaration notification template.

All personal data collected or processed by Torbay Council for the purposes of ECO4 Flex or Great British Insulation Scheme Flex will be processed and stored in accordance with: the Council’s obligations under UK GDPR and the Data Protection Act 2018, the Council’s data protection policy, the Information Commissioner’s Office Data Sharing Code and other guidance, and Department for Energy Security and Net Zero guidance.

Name: Tara Harris
Job Title: Divisional Director of Community & Customer Services
Date of signature: 20 November 2023

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