From: duncan@nature-society.org <duncan@nature-society.org>
Sent: 03 September 2025 15:22
To: ‘DESNZ Correspondence’ <correspondence@energysecurity.gov.uk>
Cc: fuel poverty action
Subject: Parliamentary Ombudsman – Systemic Absence of Duty of Care – ECO4

Dear DESNZ,

I am writing further to my MP, Matt Bishop, having referred details of my installer complaint. The matter was passed to MCS, but no proper investigation took place: I was never interviewed or invited to submit evidence, while the installer was afforded direct phone contact. Multiple, objective breaches of PAS standards and ECO4 guidance are evidenced in my materials below and reflect a wider, systemic problem affecting many households – many of whom I am in direct contact with.

• Article: “I was promised a warmer, greener home. Two and a half years later, I am still living without heat”

• Overview: “The reality of ECO4 complaints.” The reality of ECO4 complaints
• ECO5 demands: ECO5 Demands
• Attachment: Draft Letter Before Action re: Consumer Energy Solutions (CES) — illustrating alleged breaches (GDPR, mis-selling, digitally duplicated signatures/potential fraud). Litigation is not realistically accessible to ECO4 claimants; the document demonstrates gravity, not a threat.  And is shared without prejudice.

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1) A systemic failure of safeguarding

Nature Society (the foundation of a new charity) is responding to the absence of advocacy for homeowners experiencing ECO4 harms.

In many cases:

• No vulnerability assessments are carried out.
• No contracts / scope of works are issued; works proceed without informed consent.
• PAS designs and heat-loss figures are neither scrutinised nor shaped with homeowner input – a root cause of fuel poverty, rather than its alleviation.

We are in contact with families (including elderly people and a baby requiring specialist care) left without functional heat for over two years as a direct result of failed ECO4 works. Air source heat pumps (ASHPs) are “always-on” systems; many households are not told this. Even when installs are “to plan,” real-world heating costs frequently rise and control is reduced, deepening fuel poverty. EPC uplift within ECO4 is hypothetical at point of award and not validated in use.

2) The complaints system is not fit for purpose

Distressed, often vulnerable, homeowners are forced through a maze of fragmented bodies; none take ownership of whole-home PAS compliance or investigate credible allegations of breach, negligence, mis-selling, or fraud.

In my case:

• No PAS Coordinator visit ever occurred
• Ofgem claim to take fraud very seriously, but later admitted they have no powers to oversee installer fraud or hold them to account
• TrustMark: lost records of my site visit; no response to correspondence. Referred me to PAS.
• PAS (as an accrediting body): disclaim accountability for whole-home systems or mis-selling investigation and refer to FCS
• FCS / Energy Ombudsman / Citizens Advice / Trading Standards: each signposts away; none can assist in practice.
• NICEIC refused to investigate, as HIES offered partial arbitration
• HIES confirmed that as at 2024, they audited just 1 in 1000 installs.  Whilst well-intended, their heat pump only focus excluded meaningful investigation into PAS / whole home breach.
• Etc.

Please do not suggest existing measures are sufficient; our evidence demonstrates they are not.

3) Further limits of recourse

• Dispute Resolution Ombudsman: £10,000 cap; non-specialist in retrofit. With installs up to £35,000, this is inadequate.  Neither do the DRO possess sufficient specialist knowledge of ECO4.
• Courts: multi-track claims typically require ~£80,000 representation and up to three years to conclude — not realistic access to justice.
• Installer churn: firms go bust and re-emerge; struck-off entities re-register with schemes. This must be prevented.

4) Reasonable demands and available solutions

Our ECO5 campaign demands are ECO5 Demands

Core principle 1: No homeowner should be worse off as a consequence of ECO4. No property should remain cold, damp, or damaged for months or years in the absence of meaningful guarantees and independent arbitration.

Core principle 2: Every grant funded install should deliver claimed benefits by guarantee.

The present absence of in-use performance data harms both households and the state:

• Homeowners lack empirical proof of whether measures work.
• Government cannot evidence value for money against net-zero objectives.
• The only certain beneficiaries are installers and the accrediting bodies they fund.

There are practical solutions, requiring data, governance, enforcement, emergency safeguarding, which can be delivered cost-effectively. I would welcome a discussion.

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Requests to DESNZ

1. Initiate formal arbitration under DESNZ’s complaints route — not solely for my case, but to address the systemic absence of duty of care and homeowner advocacy across ECO4. I am willing to participate constructively as a solutions-focused representative for affected households.
2. If DESNZ will not convene arbitration, please refer this matter to the Parliamentary and Health Service Ombudsman.
3. Immediate winter safeguarding: establish an emergency mechanism ensuring that households left without heat or facing unaffordable costs due to ECO4 installs receive access to interim support within 30 days (heat provision, temporary systems, or remedial action), with investigations following thereafter.

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Why action is urgent

Without intervention, this winter will again see households unable to afford adequate warmth because of ECO4 outcomes. Failing to protect homeowners is a false economy: externalities escalate costs elsewhere in the system (health, housing, productivity, false CO2 savings). ECO5 is the opportunity to correct course and deliver measurable, real-world benefits alongside industry growth.

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I would appreciate a response within 14 days and am happy to meet in person or via video to walk through evidence and practical next steps.

Yours sincerely,

Duncan Hayes
Tel: 07x
Caseworker: xx
MP: Matt Bishop

Enclosures / Links:

• Article: “I was promised a warmer, greener home. Two and a half years later, I am still living without heat”
• Overview: The reality of ECO4 complaints
• Scope for Improvement: ECO5 Demands
• Draft Letter Before Action (CES) — illustrative, without prejudice – see attached