Warm Homes Fund Call for Evidence

Summary of Asks

WMCA requests the following from DESNZ:

1. Establish the national NETF: Establish the Neighbourhood Energy Transition Fund as
a national investment fund with regional allocations and delivery, providing a single investment architecture through which any qualifying region can access CDEL FT capital for area-based neighbourhood retrofit and clean energy delivery, without each region
needing to independently negotiate fund terms or replicate the legal and governance architecture.

2. National Demonstrator Allocations: Create a ring-fenced National Demonstrator Allocation of approximately £340m for WMCA as the anchor National Demonstrator, and equivalent allocations for other regions with the delivery capability, programme
pipeline, and institutional readiness to work through the five key proof points on behalf of the wider programme. The Coalition of Place collectively represents the demand for this tier; aggregate National Demonstrator Allocation could approach £1–2bn across committed regions.

3. Open Allocation mechanism: Design and resource an Open Allocation mechanism through which regions not initially participating as National Demonstrators can access NETF capital as their delivery capability and programme pipeline develops, drawing on the legal frameworks, investor relationships, and standardised consumer contracts established through the demonstrator phase.

4. Joint fund design process: Engagement between WMCA, DESNZ, NWF and GBE to agree capital stack structure, governance design, FT compliance framework, consumer offer architecture, and co-investment terms.

5. ONS pre-engagement: DESNZ facilitation of early and informal ONS pre-classification engagement before the fund is formally structured. This engagement should address two specific questions: first, whether a fund vehicle with the design features described in this submission – genuine independent governance, commercial pricing of services, and
third-party co-investment – could be compatible with Public Sector Corporation classification under Eurostat guidance; and second, whether Central Government
classification of the fund vehicle would mean that the deployment of CDEL FT capital into it does not qualify as a Financial Transaction in National Accounts terms. WMCA understands these questions are not yet resolved even among officials and requests that DESNZ seek clarification from HM Treasury and ONS as a priority.

6. Payment mechanism legislative pathway: Early engagement between DESNZ and MHCLG on the Ministerial order pathway under the Local Land Charges Act 1975 s.1(1)(e), to enable the property-linked payment obligation mechanism to be tested in
the demonstrator phase without primary legislation.

7. Collective enrolment mechanisms: Development of mechanisms enabling SPV-level
bulk Boiler Upgrade Scheme (BUS) applications and consumer loan origination through neighbourhood delivery vehicles, treating both as a priority alongside the NETF fund design process.