Chapter 5: Protecting Customers
Assuring Quality And Protecting Customers
Establishing trust in Energy Efficiency Scotland will be key to its success and it is therefore important that products and services provided by the Programme are of the highest quality. We intend to achieve this by putting in place robust quality assurance requirements at every stage of the delivery process from the marketing and communications to the assessment and installation. This will ensure that consumers are protected, confidence in the programme is boosted and investment is attracted. This Route Map sets out our commitment to developing a robust quality assurance framework covering all aspects of the Programme.
In recent years, shortcomings in consumer protection and in the expected quality standards of installations in the renewable energy, energy efficiency and district heating sectors have emerged. Citizens Advice Scotland and other organisations with consumers’ interests at heart have highlighted this as an area of growing concern. Specific concerns have been raised about cold calling and mis-selling in the energy efficiency sector.
In October 2015 the UK Government commissioned Dr Peter Bonfield to chair an Independent Review of Consumer Advice, Protection, Standards and Enforcement for UK home energy efficiency and renewable energy measures. The Each Home Counts  review identified many examples of exemplary performance of installing energy efficiency measures. However, it also found that too often interventions were not appropriately targeted and, in a minority of cases, there is poor practice and substandard work being carried out  .
Responsibility for consumer protection in energy efficiency, renewable energy and district heating is provided by a number of bodies - Trading Standards Scotland, Ofgem, ombudsman organisations and independent guarantee schemes. Quality standards, inspection, and levels of redress vary significantly between different organisations and compliance schemes. Redress processes, where they exist, can be unclear, slow and difficult for consumers to navigate. Ultimately, they may not satisfactorily resolve the consumer’s complaint. It is also important to note that consumer protection enforcement powers are reserved to the UK Government, although the Scottish Government has new powers to provide consumer advocacy and advice and is able to set quality requirements for installers on work carried out through the Programme incentives and other Scottish Government schemes.
The wide-ranging and still evolving nature of the Programme, which includes a number of installation scenarios from individual properties to district heating networks covering householders, non-domestic premises and businesses, creates new challenges in developing protections that will be applicable in all circumstances. However, the Programme also provides an opportunity to build on existing provisions and create an integrated, accessible and effective quality assurance framework.
The 2016 SNP manifesto committed to creating a consumer body to protect consumers. This represents another opportunity to ensure consumers are able to engage confidently with providers and suppliers and to make energy efficiency choices that suit their particular circumstances.
In developing the framework we will be embedding the set of principles set out below.
The Energy Efficient Scotland Quality Assurance ( QA) Principles
- Across the board there will be robust consumer protection that focuses on high standards of quality, customer care, competence, skills, training and health and safety.
- Individuals and businesses carrying out work under the the Programme umbrella should be competent, appropriately trained and should agree to adhere to the the Programme Code of Conduct.
- Individuals or businesses who fail to adhere to the standards or Code of Conduct will be removed from the scheme.
- There will be sufficient capacity in the supply chain to meet the demand for the Programme and be able to deliver the Programme offer.
- The Programme finance will only be made available where the Programme approved individuals or businesses are used.
- The Programme consumer protection should build on existing standards and frameworks and should represent good value for money.
- The Programme standards will be robustly enforced.
- Consumers will have access to simple and effective redress if things go wrong.
The development and implementation of the Programme quality assurance framework has already begun and will be continuing throughout the transition phase to ensure it is operational by 2020. During this period, customers will benefit from the legal protections that are already in place. As the quality of installation work is integral to the overall delivery of the Programme, the framework will also encompass the skills and competence requirements of the Programme operatives as well as the capacity of the supply chain in Scotland.
We are developing the quality assurance framework with partners and we have established a Short Life Working Group on Quality Assurance, Consumer Protection, Skills and Supply Chain.
The development of the Programme Quality Assurance framework began in early 2018 and will
continue throughout the transition phase in order to be operational in 2020.
SLWG will meet during 2018.
A set of actions will be taken forward that will ensure the framework meets the principles set out.