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10. DirApp - ECO 4 - Post ELT - FINAL - 11-01-23

North Ayrshire Council · 24 January 2023
Back to Cabinet — 24 January 2023 and its agenda

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NORTH AYRSHIRE COUNCIL 
24 January 2023 
Cabinet 
Title:  Providing Affordable Warmth - ECO4 Flex 
Purpose: To seek Cabinet approval for proposals to enable access to
ECO4 Flex funding for eligible households within North
Ayrshire.  
Recommendation:
That Cabinet (i) approves the introduction of ECO4 Flex in
North Ayrshire on the terms outlined in paragraph 2.8, and (ii)
delegates authority to the Executive Director (Place) to publish
an updated Statement of Intent following completion of the
Prior Information Notice and subsequent assessment of
eligible contractors.     
1. Executive Summary 
1.1 The Energy Company Obligation 4 (ECO4) programme is a national four year
programme worth £4 billion to support those on low incomes, and who are fuel
poor and vulnerable to the cold, to assist these households to increase the energy
efficiency of their properties. 
1.2 To support the Council’s ongoing commitment to the cost-of-living crisis, a specific
component of ECO4 - referred to as ‘Flex’- has been identified as an opportunity to
further support affordable warmth in owner occupied and privately rented homes,
as well as complementing our ‘Energy Smart’ programme. 
1.3 A proposed delivery mechanism for access to ECO4 Flex is provided within this
report to maximise this external funding opportunity to further support affordable
warmth measures across North Ayrshire. The delivery model is a proposed new
scheme for the Council, involving a partnership approach with external contractors
to enable access to ECO4 Flex funding for eligible households. 
1.4 Details of how the scheme would be introduced and administered are provided at
paragraph 2.8.

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2. Background 
2.1  The Energy Company Obligation (ECO), first introduced in 2013, is a national
energy efficiency scheme that places legal obligations on energy suppliers to
deliver energy efficiency and heating improvement measures to domestic
premises. This aims to reduce heating costs for low-income, fuel poor and
vulnerable people, and usually incorporates the replacement or upgrade of
inefficient heating systems, installation of insulation, and/or installation of
renewable technologies. ECO funding has been delivered in successive rounds
over the years, with the most recent iteration being ECO4. 
2.2 The latest four-year ECO4 scheme is worth £4 billion nationally and will run to
March 2026. The main objective of the scheme is to reduce household heating
costs by improving the least energy efficient housing stock occupied by low
income and vulnerable households. The delivery funds for ECO4 are generated
from energy suppliers with more than 150,000 domestic customer accounts, and
minimum supply volumes of 300 GWh/year electricity and 700 GWh/year gas. 
2.3 ECO4 has two main routes to support eligible households: ECO4 ‘Help to Heat
Group’ and ECO4 ‘Flex’. Help to Heat Group funding allows independent installers
to access funding for private owners or tenants in receipt of income derived
benefits and has no local authority involvement. 
2.4 While a variation of ECO Flex has been available in previous rounds of ECO
funding, the new ECO4 Flex scheme encourages the delivery of multiple
measures for a ‘whole house’ approach to the least efficient homes. The criteria for
accessing ECO4 funding is more stringent however more funding is available
under the new scheme for those that are eligible. 
2.5 Under ECO4 Flex, a participating local authority can enable access to funding for
private tenure households that are living in fuel poverty or on a low income and
vulnerable to the effects of living in a cold home. 
2.6 Owner occupied homes with an Energy Performance Certificate (EPC) band of D-
G may be eligible for the ECO4 Flex scheme. Separately, private rented homes
with Energy Performance Certificate band of E-G may also be eligible for the
ECO4 Flex scheme. There is a minimum delivery requirement of improving band F
or G homes to at least band D, and band D or E homes to at least a band C. This
requirement is to encourage the delivery of multiple measures in a home to a more
complete upgrade of the least energy efficient homes. 
2.7 The maximum number of potentially eligible properties in North Ayrshire is
approximately 21,700 owner occupied properties with an energy efficiency rating
of D, and a further 12,900 owner occupied or private rented properties with an
energy efficiency rating of band E, F or G. 
2.8  A summary of how ECO4 Flex would work in North Ayrshire is as follows: 
• A Statement of Intent (SOI) is a document published by a local authority to set
out criteria for access to ECO funding in the authority area. We currently have
a published SOI which is used to enable access to ECO funding for our annual

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‘Energy Efficiency Scotland: Area Based Scheme’. The SOI would be updated
with details of selected contractors identified as suitable to install measures
under ECO4 Flex. Only contractors named on the SOI will be able to access
ECO4 Flex funding for eligible households. A copy of the proposed SOI is
provided at Appendix 1. In accordance with OFGEM’s guidance, households
must meet at least one of the following four available funding access routes: 
1. EPC bands D-G households with an income less than £31,000. This cap
applies irrespective of the property size, composition, or region.
2. EPC bands E-G households that meet a combination of two additional
criteria available in the OFGEM guidance.
3. EPC bands D-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.
4. EPC band D-G households that are referred under ‘Bespoke Targeting’.
Suppliers and local authorities can apply to BEIS where they have
identified a low income and vulnerable household that is not already
eligible under the existing routes. Bespoke targeting is provided as a
safety net and would be an exceptional case identified that is not eligible
under the existing routes. 
• The process of identifying contractors would be informed from responses to a
Prior Information Notice (PIN) undertaken to test market interest and identify
potential contractors. Once the PIN responses have been returned, the Council
would engage with suppliers to apply a number of quality tests (see further
information below) before the contractor is added to the SOI. The contractor
will also be expected to sign a Minute of Agreement setting out terms and
conditions that the contractor will require to meet to participate in the scheme.
As part of our Community Wealth Building approach, it is proposed that
contractor participation is restricted to Ayrshire based contractor(s), unless
such geographically based contractors do not express interest, or do not meet
our quality criteria or do not sign the Minute of Agreement. 
• Once the new SOI is published, the contractors will engage directly with
households deemed to be eligible.  The Council is not required to generate
leads for the contractors; however, the scheme would be widely publicised both
internally and with external agencies who interact with households that may be
eligible in order to generate additional referrals and maximise reach. 
• Once the contractor has engaged with the household and sought the relevant
evidence to meet the criteria within the SOI, a declaration will be provided to
the Council for approval. Officers would then assess the declaration and
submitted evidence to make sure the funding criteria have been met, and then
sign the declaration and return it to the contractor. The contractor then notifies
OFGEM and the ECO4 supplier for final approval. Measures are then installed
in the property by the contractor. 
2.9 The key next steps and timeline, subject to Cabinet approval of the proposal,
would be:

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• Assessment of PIN exercise including quality checks: February 2023
• Signature of Minute of Agreement with contractor(s): March 2023
• Publication of updated SOI: end March 2023
• Promotion of the ECO4 Flex scheme by contractor(s) and across Council
channels: April 2023 onwards 
2.10 Ensuring quality as part of the ECO4 Flex programme is an important
consideration for a number of reasons, including: 
• To provide a positive customer experience
• To ensure measures installed are appropriate, of the required quality standard,
and are installed correctly to maximise effectiveness
• To ensure adequate protection, as referrals can involve working with
vulnerable families 
For these reasons, contractors added to our SOI would be required to be
Trustmark and PAS 2030/35 accredited, to ensure high quality workmanship. The
scheme would include key performance indicators to ensure roles and
responsibilities are clear and commitments are adhered to. Officers will also
consider other assessment checks to ensure the customer journey is of a high
quality. 
2.11 In order to provide the required declarations as part of the scheme, contractors
must submit various documents including personal and special category data of a
sensitive and personal nature. A data sharing platform will be established with the
Council’s ICT Service, to safely share and store documentation. Appropriate data
sharing protocols and agreements will be required, and Information Governance
will be consulted throughout the development of the programme. 
2.12 Separately, the Council is investing £2.176m through the Energy Smart scheme to
support residents impacted by the cost-of-living crisis.  The programme includes
the installation of physical energy efficiency measures for homes. This programme
offers an additional route for access to ECO4 Flex funding, for eligible properties,
and officers would refer such properties to SOI contractors where relevant in order
to maximise the reach of the original £2.176m funding package. 
2.13 In addition, the Council receives annual funding to support energy efficiency
measures in hard-to-treat private sector domestic premises.  These are properties
where traditional energy efficiency measures are more difficult to implement,
typically, properties of certain construction types, for example 'no-fines'
construction. As noted above, the Energy Efficient Scotland: Area Based Scheme
(EES: ABS) has in the past utilised ECO Flex funding through the appointed
EES:ABS contractor to support additional measures.  However, the new iteration
of ECO4 no longer allows this cross funded approach. ECO4 Flex funding can
however be used either as a replacement funding source for properties otherwise
eligible for EES:ABS or to provide additional measures that government funded
programmes such as EES:ABS cannot support.  For example, if the limit of grant
funding for EES:ABS has been reached, then we could complete the additional
measures such as windows replacement. Only the EES:ABS contractor named on
the SOI would be able to access ECO4 Flex funding. This helps to both maximise

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available funding and reflect a ‘whole house approach’ to energy efficiency
upgrades. 
2.14 A final consideration which will be kept under review is the potential for a Managing
Agent agreement to be put in place to administer ECO4 Flex declarations on
behalf of the Council. A specialist company could be appointed to manage the
scheme via a Minute of Agreement, with ongoing costs to be meet through
contractor referral fees.  It is anticipated that at present the administration of the
scheme can be undertaken with the resource available inhouse; and resource
requirements will be kept under review as the scheme develops. 
3. Proposals 
3.1 That Cabinet (i) approves the introduction of ECO4 Flex in North Ayrshire on the
terms outlined in paragraph 2.8, and (ii) delegates authority to the Executive
Director (Place) to publish an updated Statement of Intent following completion of
the Prior Information Notice and subsequent assessment of eligible contractors. 
4. Implications/Socio-economic Duty 
Financial 
4.1 The Council is already investing £2.176m in energy support for those impacted by
the cost-of-living crisis. This proposal provides an opportunity to lever-in significant
external funding for eligible properties to support affordable warmth in owner
occupied and private rented homes across North Ayrshire. 
Human Resources 
4.2 It is anticipated that the administration of the scheme can be delivered from existing
resources, however, this will be monitored in response to demand once the scheme
is operational. 
Legal 
4.3 As part of the ECO4 Flex scheme there is an obligation to ensure the quality and
integrity of the partnerships to ensure customer satisfaction and minimise
reputational risk. 
Equality/Socio-economic 
4.4 The proposal utilises external investment to support those living in fuel poverty or
on a low income and vulnerable to the effects of living in a cold home, in our most
energy inefficient properties. It further supports our climate change ambitions,
provision of fair green jobs and a green economic recovery. 
Climate Change and Carbon 
4.5 The proposal aims to: 
• make a positive contribution to national carbon reduction targets by
improving affordable warmth and making homes more energy efficient.

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• contribute to the North Ayrshire Council Climate Emergency declaration
commitment to be carbon neutral by 2030. 
The proposals would also contribute to the delivery of the North Ayrshire
Environmental Sustainability & Climate Change Strategy (ESCCS) Affordable
Warmth workstream. 
Key Priorities 
4.6 The proposals contained within the report support the North Ayrshire Council Plan
priorities: 
• Active and strong communities
• Inclusive, growing and enterprising local economy
• A sustainable environment; and
• People enjoy good life-long health and wellbeing 
Community Wealth Building 
4.7 As noted at paragraph 2.8, the ECO4 programme would be delivered in
accordance with Community Wealth Building aims of creating a fairer local
economy central to our aims of tackling climate change, poverty and inequality. 
5. Consultation 
5.1 Consultation was undertaken with ICT and Democratic Services in the preparation
of this report. 
RUSSELL McCUTCHEON
Executive Director (Place) 
For further information please contact David Hammond, Head of Sustainability,
Corporate Property & Transport, on 01294 324514. 
Background Papers

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DRAFT 
North Ayrshire Council ECO4 Flexible Eligibility
Statement of Intent Local Authority name: North Ayrshire Council
Publication Date: XX/XX/2023 Version
number: V.1
Publication on web site: www.north-ayrshire.gov.uk 
This statement sets out North Ayrshire Council’s flexible eligibility criteria for the Energy
Company Obligation (ECO4) scheme 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”. 
The Council welcomes the introduction of the ECO4 Flex eligibility routes as it helps the Council
achieve its plans to improve the homes of those in fuel poverty or vulnerable to the cold. 
The Council is publishing this Statement of Intent (SoI), on the XX/XX/2023 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 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 households that meet a combination of two of the following proxies: 
Proxy 1) Homes in Scotland in Area 1-3 of Index of Multiple Deprivation for
2020, published by the Scottish Government1 
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.

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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. 
Route 3: SAP bands D-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 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: SAP band D-G households that are referred under Route 4: Bespoke Targeting.
Suppliers and LAs can submit an application to BEIS where they have identified a low income and
vulnerable household, who are not already eligible under the exiting routes. 
Guidance Notes 
Route 1 - P60 and P45 documentation must be provided for all members earning income in
household.  3 wage slips only will not be permitted as they do not reflect annual salaries. Such
documents are available at UK Gov website link P45, P60 and P11D forms: workers' guide: P60 -
GOV.UK (www.gov.uk) for all household members. 
Route 2 - Proxies 1 & 3 cannot be used in combination with each other. 
Route 3 - evidence must be submitted using OFGEM template. Any corresponding email must be
sent from NHS registered email. No other format will be accepted 
Route 4 – currently not available. North Ayrshire Council reserve the right to implement this route
and update its SoI accordingly.
1 Scottish Index of Multiple Deprivation 2020 - gov.scot (www.gov.scot)
Household contact
Households interested in ECO4 flex should contact Home Energy Scotland on 0808 808 2282 to
check their eligibility for this scheme as well as other Government programmes. Households can
also contact ECO4 Flex installers assessed to work within North Ayrshire, the approved contractor
list is published on the council website www.north-ayrshire.gov.uk.
Declaration
To access ECO4 Flex funding, North Ayrshire Council is required to complete a Local Authority
Declaration for eligible households. The final decision on whether a household receives ECO
support is made by the energy suppliers and therefore inclusion within a declaration will not
guarantee installation of measures.
The final decision will depend on:
• The survey carried out on the property and the installation costs calculated.
• The energy savings that can be achieved for a property.
• There is adequate funding to support ECO funding for the installation of the energy
efficiency measures.

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• Whether ECO obligated parties have achieved their targets or require further measures to
meet their ECO targets.
Compliance
ECO installers will be responsible for collecting eligibility data on behalf of North Ayrshire Council
to determine if the householder meets ECO4 Flex eligibility criteria as detailed within this SoI. This
data will be collected through the completion of a Household Energy Efficiency Survey. 
An individual file for each household requesting assistance will be securely transferred to the
Council for evaluation. All applications and supporting documentation must be on the appropriate
OFGEM application templates. Any applications/evidence/amendments not on the correct forms
will be rejected. On agreement, declarations will be provided to the contractor to allow funding to
be sought via obligated suppliers.
All evidence, as set by OFGEM, will be accepted on face value as being accurate and all risks and
liabilities reside with the contractor to ensure those submitted are true and accurate.
ECO installers will liaise with North Ayrshire Council and energy suppliers with regards to eligibility
and the measures that are proposed to be installed. 
ECO installers will cooperate with North Ayrshire Council fully with any audits or investigations
and provide access to all relevant paperwork at any time during ECO4 to ensure regulatory
compliance. Failure to do so would result in a temporary ban and review to determine continued
eligibility to deliver this scheme in North Ayrshire.
Privacy Notice
All information supplied to North Ayrshire Council will be transferred and held securely in line with
Council policies and procedures.
Each household will be provided with the contractor’s OFGEM approved, fair privacy notice,
detailing how the contractor will process information.
Please refer to the Council’s ECO4 privacy notice v1.
Further information about how the Council manages personal information can be found within our
privacy policy, Privacy Policy (north-ayrshire.gov.uk). 
The officer below will be responsible for checking and verifying declarations and associated
evidence submitted on behalf of the local authority: 
Name: David W Hammond 
Job Title: Head of Sustainability, Corporate Property & Transport 
Telephone: 01294 320000 
Email: energyandsustainability@north-ayrshire.gov.uk 
CEO or dedicated responsible person mandatory signature 
North Ayrshire Council will administer the scheme according to BEIS’ ECO4 Order and will
identify eligible households via Ofgem’s application process. The CEO 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,

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Information Commissioner’s Office Data Sharing Code, and BEIS guidance. 
Signature: XXXXXX 
Name: Craig Hatton 
Job Title: Chief Executive 
Date of signature: XX/XX/2023 
For any general enquires relating to this SoI, please contact energyandsustainability@north-
ayrshire.gov.uk.