The UK Government has come a long way in preparing the ground for massive carbon emission cuts in the future, but still lacks a coherent plan that will actually deliver energy efficiency in practice.
The Energy Bill, which is supposed to lay the foundations for the Green Deal, carbon price floor, market reform, carbon capture and storage, and a mass roll out of energy efficiency and renewable energy, is currently approaching the Report Stage in Parliament.
However, although many of its aims are laudable, there is no chance of them being realised unless there is more joined-up connection across Government departments and across the country as a whole that lays out exactly how they will be achieved.
Although the Bill makes reference to fuel poverty, limiting or eliminating it is not one of its stated aims. It should be, otherwise there is no guarantee that it can happen.
Furthermore, although the Bill currently contains a long-term aim to meet the 2050 carbon reduction target, by not tying actions to interim carbon budgets there is no way of ascertaining whether measures taken in practice actually are commensurate with the requirements of these budgets, and whether the country is on the right path.
In fact, there is no mention of the interim carbon budgets in the Bill at all.
Carbon budgets are set by the Committee on Climate Change to act as milestones along the way to the overall target of reducing emissions by 80% by 2050. Its latest report says that already the UK may not meet the current period's budget by 2012.
Businesses and investors are unlikely to see the Green Deal as an opportunity without the certainty that interim targets will provide.
In order to arrive eventually at the 2050 destination, each sector within the economy needs to have a staged plan to work to, with interim goals along the way, and be effectively monitored.
In the building sector for example, the mechanism by which the Green Deal is implemented will be crucial to its success. It will require the cooperation of local planning departments, Building Control, the Treasury, trade associations, and the Department for Communities and Local Government.
Deciding on whether carbon emission reduction targets from this sector are being met will be estimated based on nominal values for the carbon saved as a result of specific measures carried out, such as the number of solid walls or lofts insulated.
But in practice, work may be poorly executed, some of it may be DIY of dubious quality, and Building Control is not currently mandated or equipped to judge whether or not this work is to the appropriate standard. Monitoring of results is going to be crucial to telling whether the predicted emissions are really saved or not.
Nowhere in Government will you find a plan that pulls all these threads together.
WWF, along with the National Insulation Association, the Mineral Wool Insulation Manufacturers Association, and the Gypsum Products Development Association and many more, tabled an amendment to this effect in the committee stage of the Energy Bill called the Warm Homes Amendment.
Unfortunately, MPs voted the amendment out, instead inserting their own - now in as clauses 107 to 108. But there is still time to get it in, and MPs continue to be lobbied by the campaign.
Another objection to the Green Deal has been raised by Andrew Warren, director of the Association for the Conservation of Energy and himself picked by the Energy Minister Greg Barker to chair an industry-based advisory forum on the scheme.
The scheme is expected to contribute to a 29% reduction in carbon emissions from homes and 13% reduction from non-domestic properties by 2020.
Warren makes the valid point that the way the financing of the Green Deal currently set up could well cause it to backfire and shift public opinion against it. This is because it is financed by an increase on electricity bills, which will not be reduced by most of the actions taken under the Green Deal.
Instead, the reductions in energy use made from the measures taken will appear on heating bills which, for 78% of our homes and other buildings, is provided by natural gas.
Where participants get gas and electricity bills from the same company and when they receive joint bills, then allocating the Green Deal to the gas part should be achievable.
But most people still buy from two different providers, and when they discover that their electricity bill has risen and carries the Green Deal loan costs on it as well, then this, Warren says, is when they will be asking “why on earth they ever got involved with this Government flagship policy at all".
As WWF's campaigner on the issue, Darren Shirley, says, a high level framework is missing from the Energy Bill. Without a plan for saving energy, it will not happen. It needs many similar issues defining and joining up to make it deliverable.
In short, the strategy around the Green Deal and Energy Company Obligation needs more incentives and checks to improve energy efficiency in the large proportion of the housing stock that currently lacks adequate insulation.
Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs) should be introduced into all non-residential buildings to incentivise emissions reduction.
At the moment, the Bill is still hot air. But isn't that what it's supposed to be eliminating?