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News 11 September 2019 Updated 26 January 2021

Response to the Fuel Poverty Strategy consultation 2019

The government has published a consultation on an Update to the Fuel Poverty Strategy for England. Energy Saving Trust has always strongly supported the Fuel Poverty Strategy, with its headline 2030 target of an energy efficiency standard of “C” for all homes occupied by fuel poor households, where practicable.

This proposed update to the original 2015 document also has many sensible ideas. In particular, we welcome a planned reform to the definition of Fuel Poverty. The revised definition will be more closely aligned with the central energy efficiency target of “C”.

But the government’s consultation on the Strategy update has a huge gap. It doesn’t discuss the fact that – because of a lack of funding in England – we’re just not going anywhere near fast enough to meet the “C” target by 2030. This is a point that has been repeatedly made by the government’s own official advisory body, the Committee on Fuel Poverty. Investment in home energy efficiency will bring widespread benefits to the UK economy, but the consultation provides no discussion of where the resources will come from or the economic benefits that infrastructure investment in tackling fuel poverty will bring.

As the organisation providing energy efficiency advice to householders on behalf of national governments in Wales and Scotland, Energy Saving Trust are very aware that this consultation fails to address the role of expert advice services in tackling fuel poverty.

In Scotland, households in fuel poverty benefit from a single point of telephone/online help. They can speak to a locally based, trained advisor who will give them all the available information and help them access financial support to make their home warmer and energy bills lower. In addition, some Scottish households that are vulnerable or with more complex needs can access in-home help.  In England, there is nothing like this.

We urgently need a nationally co-ordinated, impartial advice service for England, delivered by local organisations to help reach vulnerable households, and to ensure that the worst, coldest homes get improvements. As well as enabling direct, self-referrals from people struggling in cold homes, an advice service also makes it much easier for health care providers to refer their patients to fuel poverty support.

The worst homes – leaving no household behind

The consultation proposes a principle of tackling the worst homes first. That’s good but it’s also a principle that is in tension with the other concept dominating this Strategy: cost effectiveness.

Instead, Energy Saving Trust argues that the consultation needs to start with the principle that no low income household will be shut out of fuel poverty support because the home is too difficult or complicated to improve.

For Scottish Government, Energy Saving Trust has been delivering Energy Carers, a programme of deep in-home support for vulnerable households in fuel poverty, often involving repeat advice/support visits. Our experience from Energy Carers is that often the most vulnerable people are living in the worst homes. And, in these homes, structural and damp problems often need to be sorted before energy efficiency improvements can begin.

We suggest this strategy should promote support for vulnerable customers (in-home advice and assistance perhaps involving repeat visits from a local support body) coupled with a flexible top up fund for fuel-poor owner-occupiers to help pay for improvements beyond what is available and cost-effective under mainstream fuel poverty support (this may include money for basic, structural repairs etc).

Meanwhile, it is essential that cost effectiveness should be calculated on the full social benefit not on narrow energy bill savings. Installing energy efficiency measures doesn’t just help individual homeowners save on bills: it delivers national-scale cost savings, for example to the NHS because fuel-poor householders don’t end up in hospital because of cold-related illnesses. In calculating the pay-back from energy efficiency programmes we need to include those national-scale benefits.

Finally, many people in fuel poverty are in private rented homes. We need real targeted programmes, working with landlords to make these homes better – as well as low cost finance and advice that private landlords can access to make improvements.

Again, Scottish Government programmes provide an example here – Home Energy Scotland provides advice and loans to private landlords. For landlords who won’t act to improve homes, we need robust regulatory trajectories for minimum standards for private rented homes. Currently, landlords have to make improvements where homes are F or G banded and the improvements cost less than £2,500. We need that minimum standard to be made stronger, over time.

We encourage anyone interested in the problems of fuel poverty in England to respond to the consultation. The consultation closes on Monday 16 September.

Last updated: 26 January 2021