1: The document says it is based on “Assumptions from
Special Advisors”, rather than an impartial Civil
Service assessment.
2: Amazingly, special advisers have instructed officials to
“Cost the policy without reference to what Labour have
said”. This allows them to ignore that our plan ramps up
to a maximum of £6bn.
3: One assumption is to “Assume that all installations
are exchequer funded". This means they assume 100% of
the costs of upgrading homes are borne by the government. But
that has never been our plan. Any sensible plan involves a
mixture of grants for low-income households and low interest
loans for others, both from the treasury and commercial
banks.
4: Another assumption is that “In terms of existing
policy commitments, assume ECO and the Great British Insulation
Scheme do not continue beyond their current end date of March
2026”. But the ECO scheme is currently in its fourth
iteration and is always renewed when it ends.
5: The document says our funding model is an “uncapped,
fully exchequer funded, undifferentiated model: As instructed we
have not applied any spending limits to this costing”
but our plan is capped at £6bn and this is referenced elsewhere
in the document.
6: The document concedes that “Previous policy design has
differentiated funding levels by household income and has
balanced the cost of policies between Exchequer funded
schemes/grants and supplier obligations like ECO and GBIS, all of
which could potentially considerably reduce the burden on the
Exchequer from delivering this policy.” What this means
is that, as we have been clear about all along, our policy would
offer a mixture of grants for low-income households and low
interest loans for others. It would therefore be differentiated
and as the Treasury says this would considerably reduce the
burden on the exchequer.
7: Later, the document admits that “We would note that
the Opposition has stated publicly that “public investment in
home energy ramping up to £6 billion annual investment in the
second half of the parliament at the latest”. But
elsewhere they ignore the fact that we have said this by assuming
that spending is uncapped.
8: The document admits it has made “no allowances” for
lowering costs via more efficient delivery models. It
acknowledges “a large-scale, area-based delivery
model” - similar to those already used by Labour leaders
across the country - “would potentially deliver economies
of scale.” i.e. reduced costs.
9: The document admits it has ignored potential cost savings from
different ways of upgrading homes to EPC C and notes
alternative methods “may be more cost-effective.” This
means “the average costs used may be higher than strictly
necessary.”
10: The document admits it has made no assessment of savings or
extra revenues generated by the program, such as lower costs due
to fewer cold related illnesses and lower costs from reduced grid
demand.
11: This costing assumes that all homes not already at
EPC C will be upgraded, but this is a voluntary scheme.
Labour has never claimed we would force households to
upgrade.
A Labour spokesperson, responding to the
publication of the costings, said:
“This costing is ludicrous and uses bogus assumptions. They have
costed someone else’s policy, not Labour’s.”
