Our response to consultation on a new fuel poverty strategy for Northern Ireland

There is an urgent need for a strategic, cross-departmental, and cross-sectoral approach to address fuel poverty in Northern Ireland through the development of a long overdue and updated fuel poverty strategy. The cost-of-living and energy crisis have further emphasised that fuel poverty must form an integral aspect of all government domestic energy schemes.

In this regard we welcome the concerted efforts of the Department for Communities (DfC) in engaging with community representatives and households throughout the development of this consultation and the proposed Strategic Framework contained therein. Some Key Points in the response include:

• We welcome the draft strategy’s key objectives, proposed outcomes and actions.
• We are highly supportive of the proposed Annual Ministerial Statement on fuel poverty.
• There is a recognised need for a coordinated, expert, tailored and impartial energy advice service in Northern Ireland. We agree with the consultation, that a one stop shop that provides free, trusted and impartial advice, can empower households to access the energy, financial, technical and behavioural advice to confidently upgrade their homes and reduce energy costs. This can also help with effective delivery of government retrofit schemes. However, confirmation of key details on the commitment under the Northern Ireland Energy Strategy to develop a one stop shop needs to be prioitised and finalised.
• Public awareness of the changes that need to be made to decarbonise homes is low and a national awareness raising campaign should be implemented.
• It is important that the strategy sets clearly defined and measurable targets which are regularly reviewed to help accelerate decarbonisation and reduce fuel poverty.
• We support the Department’s intention to introduce minimum energy efficiency standards for the private rented sector, particularly given the high levels of fuel poverty present.
• We support the whole-house retrofit approach, based on the existing fabric of the property and the best pathway to achieve a desired level of energy performance.
• Long term policy certainty is necessary to ensure effective delivery of government retrofit.

We look forward to continuing to engage with DfC and the wider Executive to deliver a new Fuel Poverty Strategy for NI and realise the vision of ‘a warm, healthy home for everyone.’

Yes.

Vision

We welcome the concise and ambitious nature of the vision of “a warm, healthy home for everyone”. The clear definition and unlimited scope of its application in applying to everyone, encourages cross-departmental and cross-community collaboration that will be necessary to alleviate and eradicate fuel poverty. However, we believe that the vision and guiding principles should be supported by clear, measurable targets for reducing fuel poverty. A similar expansive approach to addressing fuel poverty has been recommended in a report by the ‘Committee on Fuel Poverty’ in England, in which it urges a future fuel poverty strategy to include ‘a guarantee of affordable energy for all’, which accounts for low-income households who may not be in receipt of state benefits.

Whilst we agree with the proposed vision, we think that because a warm home is not automatically synonymous with a healthy home, that the comma should be replaced with an ‘and’ so that the vision is “A warm and healthy home for everyone”. For example, improper ventilation in a warm (or indeed a cold) home can lead to poor air quality, which is linked to a range of health problems including respiratory conditions and allergic symptoms. We also note that overheating can pose health risks including dehydration, heat exhaustion and heat stroke. This has been recognised under the Northern Ireland Programme for Government (2024-2027) launched in March 2025, which highlighted that “we have begun to see the very real impact of climate change locally, through extreme heat…”

Guiding principles

Long-term sustainable solutions

We welcome the inclusion of long-term sustainable solutions as a guiding principle. A focus on short- term or least-cost solutions risks detrimentally impacting longer-term benefits, such as: reduced long-term running costs and savings, energy independence or prioritising incentivised support for large-scale generation that may for instance not contribute to lower energy bills to the extent that community or local small-medium scale energy generation may.

Needs based

We agree that the approach to tackle fuel poverty must be flexible and adapt to the changing needs of people in or at risk of fuel poverty. This approach will help ensure support is provided to those most in need by adapting to any external events, such as energy price fluctuations and decarbonisation policies impacting households.

The inclusion of holistic support is particularly important. Addressing fuel poverty requires a multi-faceted approach that includes home energy efficiency improvements but also financial support, communication, education, behavioural change, and advice. Household renewable energy and storage technologies may also have a role to play in reducing bills.

It is important to ensure that particular groups of households are not overlooked due to overly stringent definitions of ‘needs based’ or unwavering income thresholds being set. In response to fuel poverty flatlining in England, a report by the ‘Committee on Fuel Poverty’ has recommended replacing the ‘Low Income, Low Energy Efficiency’ (‘LILEE’) metric, which is based on household income as “it no longer captures the full range of households facing unaffordable bills.”

To ensure specific groups are not unfairly disadvantaged, an approach similar to the consumer duty principle introduced by the Financial Conduct Authority for regulated entities and activities could be considered. This requires end-to-end customer journey mapping for all defined groups and customer outcomes testing to evaluate if any groups are receiving differential outcomes.

Collaborative

We strongly support the inclusion of this guiding principle. Effective and meaningful cross-departmental and cross-sectoral collaboration will be essential to the strategy’s success.

At present, a disjointed and incomplete customer journey makes it challenging for people to navigate existing advice services and identify and apply for relevant funding. We agree with the position put forward in the consultation that a one stop shop (OSS) that provides free, trusted and impartial advice, can support households to access the energy, financial, technical and behavioural advice they need to make their homes more energy efficient and reduce their energy costs.

A OSS can also facilitate collaboration as it can partner with trusted intermediaries, such as charities and health care organisations and build referral pathways to help reach the most vulnerable or hard to reach, through existing customer support networks to ensure they receive the right support.

Additionally, any strategy to tackle fuel poverty must engage with all stakeholders and be aligned to wider policies with similar end goals, such as those to eliminate child poverty.

We agree with the ten-year timeframe proposed for the strategy (2025 – 2035) which demonstrates the government’s long-term commitment to tackling fuel poverty.

We also welcome the proposal for a mid-term review in 2030, alongside annual indicators (including for extreme and severe fuel poverty), annual reporting (reviewed by an independent advisory group) and an annual Ministerial Statement to ensure accountability and adaptability.

However, we would welcome further clarity that the strategy will be revised to take account of recommendations made by the review. These mechanisms will be critical for assessing progress and making timely adjustments in response to emerging challenges and opportunities, such as shifts in energy markets, evolving decarbonisation policies and advances in technology.

We welcome the Department’s intention to introduce an updated Decent Homes Standard for the social housing sector by 2026.

We understand the complexity and subjectivity associated with defining thermal comfort. The Building Services Research and Information Association (BSRIA), in its Thermal Comfort topic guide, categorises influencing factors into personal (such as health or preferences that there is limited control over) and environmental (such as internal temperature, which there is a degree of control over).

BSRIA outlines specific measures of thermal comfort, such as dry bulb temperature, mean radiant temperature, operative temperature, relative humidity, air speed, air turbulence, draught risk and barometric pressure. We would ask that the Department considers this, as well as other international guidelines and those provided by the World Health Organization, which recommend that occupied rooms be maintained at 18– 21°C, when defining a measurable definition of thermal comfort.

It is also crucial that the updated Housing Fitness Standard sets clear minimum requirements for thermal comfort and is implemented as soon as practicable.

We support the Department’s intention to introduce minimum energy efficiency standards (‘MEES’) for the private rented sector (‘PRS’) by 2027 given the particularly high levels of fuel poverty in this sector and the lack of success of previous efforts to decarbonise these homes. It is important that the strategy sets clearly defined and measurable targets which are regularly reviewed to help accelerate decarbonisation and reduce fuel poverty within the sector. We note that this intention is in line with the Housing Supply Strategy’s (2024-2039) existing commitment to “put in place minimum standards for the PRS as part of a wider Executive policy to set MEES for all domestic tenure types.

Our response to this question is split into two parts:

1. the information and data that will be useful to DfC, and
2. the information and data that will be useful to landlords and tenants.

Useful Information

Information and data that will be useful to DfC

In order for DfC to design MEES, they will need data that can act as a proxy for the energy performance of each property.

• In England and Wales, the data that is used as a proxy for a property’s energy performance under the UK Government’s MEES for the private rented sector is a property’s EPC rating. Landlords are required to improve their properties to an EPC E unless the cost of doing so is more than £3,500 in which case they are expected to make all the improvements that can be made up to that amount.
• The Scottish Government is still considering the proxy that will be used when MEES are introduced for the private rented sector in Scotland but has proposed using either a straightforward list of measures or a reformed EPC fabric efficiency metric.

DfC will also need data to show whether a landlord has met the required level of energy performance.

Information and data that will be useful to landlords and tenants

Landlords will want to know:

• which measures they need to install in order to meet the standard,
• the costs of installing the measures and the bill savings that are likely to result from installing the measures (information about both of which would be able to be found on an EPC),
• the implications for the tenant (whether the work will involve any disruption in the property), and
• whether there is any support available to help fund and/or finance the measures that need to be installed.

We know from our experience in Scotland that even without regulation in place, landlords value being able to access advice about improving the energy performance of the properties they let. In 2023-24, the Scottish Government’s Home Energy Scotland specialist advice service for private landlords provided advice to 697 landlords covering 917 privately rented properties. Landlords supported by the specialist advice service in 2023-24 will deliver total attributed lifetime savings of 4,890tCO₂ and lifetime financial benefits to the bill payers of £2.7 million.

Once improvements have been made, it will also be important for tenants to understand that they might need to change their behaviour as a result of their home being more energy efficient in order for them to benefit from reduced energy bills – a tenant may for example be able to reduce the number of hours their heating is set for, once the energy efficiency of the property they rent has been improved.

Barriers to overcome

For MEES to effectively alleviate fuel poverty, the following barriers will need to be overcome:

• Split-Incentive – the landlord pays to improve the energy efficiency of the property but the resultant savings will benefit their There is therefore a need to ensure that support is available to enable landlords to finance energy efficiency improvements.
• A low interest loan scheme, similar to the Scottish Government’s Home Energy Scotland PRS Landlord Loan scheme, could support compliance.
• Additionally, a cost cap will be necessary, if minimum energy efficiency standards are implemented, as has been adopted in England and Wales. Under the recently launched consultation on ‘Improving the energy performance of privately rented homes in England and Wales’, the Department for Energy Security and Net-Zero (‘DESNZ’), acknowledges that there is a need to ensure a balance between MEES’ being affordable, fair and proportionate and the need to meet necessary energy efficiency standards. In this they propose setting a rigid cost cap (not indexed to inflation) and also applying an affordability exemption (several methods proposed, including a simple data-based approach).
• Costs of improvements may be passed to tenants, detrimentally impacting affordability and fuel poverty. Under previous NISEP schemes, there were requirements for tenants to have a minimum of 6 – 12 months remaining on tenancy agreements to avail of Similar protections for tenants should be in place to protect against this where support is provided to landlords.
• Enforcement: For the fuel poverty strategy to be successful, enforcement of standards needs to be adequately resourced. We welcome attempts to improve enforcement of the Landlord Registration Scheme and expressly link this to MEES, so they can be more effective in supporting a reduction of fuel poverty within the PRS. Efforts should also be made to ensure awareness of this obligation among landlords.

Rent Smart Wales provides valuable insight into how the government may aid and manage enforcement.

Consumer advice

Many private landlords operate on a small scale with limited investment funds and are often not aware of any financial and other support available to them to help with improving their properties. Whilst landlords may have EPCs for their properties, they may not properly understand the range of improvement options suitable for the dwelling or how to access the relevant supply chain. This is particularly the case for landlords who have solid wall or other hard to treat properties where solutions can be wide-ranging, complex, disruptive and costly. To meet this need, the provision of specific advice, information and support is required for the PRS and this should be part of any OSS offering.

Tenant behaviour

Tenants may be reluctant to raise concerns with landlords (for example, because they fear reprisal if they suggest work is required) or be disengaged due to a sense of having little influence over energy saving measures in their home. They may also lack awareness of available options.

Limited supply chain and skilled workforce

There are significant challenges posed by the shortage of skilled installers and the limited supply chain. A concerted effort will be required across government to improve the supply chain and upskill the workforce at the pace and scale necessary to meet decarbonisation targets (see our response to 33). Additional support should be provided for rural and hard- to-treat properties, which may require additional energy efficiency measures installed (see our response to question 12).

Yes. MEES should be applied to other tenures. Our view is that MEES should be applied to all housing tenures (PRS, owner occupied, socially rented).

Whilst the PRS may be a key concern, given the particularly high proportion of inefficient homes and those experiencing fuel poverty in the sector, improving the fabric efficiency of all of Northern Ireland’s building stock will be essential if climate change targets are to be met. As well as delivering emissions reductions, improving the fabric efficiency of the building stock has the potential to deliver a host of other benefits. These are well documented and include lower fuel bills, improved comfort for occupants, lower risk of condensation, improved heat pump performance, reduced risk of overheating and reduced need for electricity capacity increases.

Existing support programmes in Northern Ireland, such as the Affordable Warmth Scheme and the Northern Ireland Sustainable Energy Programme (‘NISEP’), have had some success in encouraging building owners to voluntarily improve the energy performance of their buildings.

For this reason, we agree that if sufficient numbers of building owners are to improve the energy efficiency of their properties, regulation requiring them to do so will be required. This will necessitate the development of an appropriate support framework to ensure that compliance is easy for everyone and the costs of meeting any new minimum energy efficiency standards are met fully for households living in fuel poverty.

The fitness standards in their current form are unfit for purpose, overly subjective and lag behind other jurisdictions, as acknowledged in the Housing Supply Strategy. Additionally, they do not provide adequate provision for affordable heating or risks to health and safety in properties (including overcrowding). This includes, for example, the fact that ‘adequate provision for heating’, is satisfied by the availability of an electrical socket to facilitate an electric heater.

Tenants relying on electric heaters face higher energy costs, difficulties in maintaining thermal comfort and are at greater risk of falling into fuel poverty. In a recent survey by Renters’ Voice, 68% of respondents said the efficiency of their heating system made it more difficult to afford to heat their privately rented homes.

Updated fitness standards for dwellings in line with England’s ‘Housing Health and Safety Rating System (HHSRS)’, which is a scoring system used by councils to assess the effect of certain hazards on the health, safety and wellbeing of the occupants (including the presence of damp or mold), could contribute to improved living conditions. These hazards are rated as ‘category 1’ or ‘category 2’, with councils obligated to take action on more serious category 1 hazards.

It is essential that updated heating standards are implemented to help ensure all homes have affordable, efficient heating systems.

We also recommend that if the fitness standards are updated to cover energy efficiency and heating, it is essential that the NI Government considers how these standards will align with proposed MEES (and potentially clean heat standards in the future). The government should provide clear visibility of all relevant standards well in advance of their introduction so that people can make informed decisions about undertaking the necessary work and avoid having to do so more than once, potentially resulting in unnecessary financial expenditure and disruption.

Yes. For the fuel poverty strategy to be effective in reducing fuel poverty, it is imperative that all government domestic energy schemes are required to take account of its principles. This will help to ensure a cross-departmental commitment to effectively alleviating fuel poverty throughout Northern Ireland. This should include proposed new schemes, including DfC’s ‘Warm Healthy Homes’ scheme and DfE’s low carbon heat schemes.

Yes. Eligibility criteria based on gross household income risks excluding some groups, such as the working poor and certain pensioners, who have become particularly vulnerable due to the housing and cost- of-living crisis. We welcome recognition in the consultation of the range of factors that can contribute to and affect energy use and affordability, including the makeup of a household or their income.

Disposable income and makeup of a home

The Affordable Warmth Scheme’s gross household income threshold of £23,000 is now unsuitably low (as recognised by the recent increases to NISEP thresholds). This threshold also does not account for disposable income or the makeup of a home. This can disproportionately impact certain vulnerable groups, such as the working poor, who may not be in receipt of means-tested benefits, due to exceeding the threshold or a lack of awareness of eligibility. These households must also be considered in any revised eligibility criteria.

We agree that new schemes should ideally build in flexibility in both eligibility and approach to adapt to households’ needs and ensure schemes continue to be effective at alleviating fuel poverty. We therefore welcome stakeholder acknowledgement that DfC should adopt a more flexible, data- driven approach, prioritising disposable income over gross income to better assess financial capacity and ensure schemes remain relevant for alleviating fuel poverty.

Avoid complexity and deliver a smooth transition

When designing a grant scheme, a balance must be struck between the simplicity of the scheme and effective targeting of households. Schemes which are overly complex and confusing for households to navigate can lead to poor uptake. The administration costs of more complicated schemes are also more likely to be higher. In this regard, it will be important that the Department learns from existing schemes and duties, such as:

• In making recent updates to the Utility Regulator’s NISEP scheme specific consideration was given to avoiding overcomplicating the scheme, and certain changes that were made, were carefully considered to ensure that they wouldn’t create longer waiting lists that make it harder to prioritise those most in need. We would be happy to discuss this work in more detail with DfC if that would be useful.
• In Wales, under the Warm Homes Nest Scheme, there are a series of income thresholds based on the number of children in the household.
• FCA Consumer Duty for schemes providing regulated activities (eg consumer loans) there is an obligation to categorise various vulnerable groups, document all their touchpoints, define consistent good and poor outcomes and assess and remediate any differential outcomes experienced by specific groups (for certain regulated activities such as consumer loans). In instances where the duty is implemented for a scheme, this can help deliver consistent consumer outcomes for everyone.
• When considering integrating flexibility into eligibility criteria, the Department can look to GB’s ECO4 Flex, which is a referral mechanism within the wider ECO4 scheme. This allows local authorities to expand the eligibility criteria for the scheme to suit the unique needs of their respective areas and target low-income households who are unlikely to qualify under the scheme’s standard approach to fulfilling eligibility.

Yes. Recent fluctuations in inflation have put additional affordability pressures on households which has significantly impacted fuel poverty in Northern Ireland. A static income threshold risks excluding households who are struggling financially but narrowly exceed the threshold. As stated in our response to question 8, assessing income after housing costs is also important; as high rents, mortgages and other expenses significantly reduce disposable income, making energy costs harder to manage. Income thresholds should be adjusted regularly to reflect inflation, minimum wage levels, or the Retail Price Index (RPI), so that the eligibility criteria keeps pace with the cost of living.

Given the vision is to ensure everyone lives in a warm and healthy home, it’s also important to ensure that inflationary increases do not stall or delay energy efficiency upgrades due to for instance installation costs increasing at a higher rate than a tenants disposable income.

Yes. We think that, on balance, the Energy Performance Certificate (EPC) rating of a house should be considered as part of eligibility criteria (but not as the sole factor). This would help to ensure that public funding for home energy performance improvements is targeted at the homes that need them most.

This aligns with the approach in Scotland, where one of the eligibility criteria for the national fuel poverty scheme, ‘Warmer Homes Scotland’, being that the home must have a poor energy rating (i.e. an EPC rating of D, E, F or G).

In Wales, one of the eligibility criteria to receive free home energy efficiency improvements is for the home to have EPC rating of E or less, or D or less and someone in the home has an eligible health condition.

Additionally, pre and post installation EPC ratings should be required to qualify for certain support. In 2025/26, a pre and post EPC assessment will be introduced under NISEP for heat pump schemes only, which will be funded by the scheme (provided loft and cavity wall insulation have already been installed and minimum EPC ratings obtained).

While we support the use of current EPC metrics being initially considered as part of the eligibility criteria in the short-term and note that ‘Warmer Homes Scotland’ has successfully used unreformed EPC ratings to assess eligibility, it has been recognised that there is a need for EPC reform and this should also be prioritised in NI.

Some limitations identified with the existing EPC rating include the fact they must be updated regularly to ensure accuracy and are based on assumptions about fuel costs, which can quickly become outdated due to energy price fluctuations. Reforms are underway in Scotland, England and Wales, with removal of the energy cost metric considered in the recent consultation on ‘Improving the energy performance of privately rented homes in England and Wales,’ which sometimes results in a heat pump installation lowering a property’s EPC rating. Since electricity costs are often higher than oil, this could distort the overall rating and misrepresent a home’s true efficiency.

Given the EPC reform proposed throughout GB, including:

• in Scotland, where the government has recently published its response to the EPC reform consultation, in which they set out their intentions to introduce new ratings, redesign the certificates and improve the operational infrastructure, and
• in England and Wales, including a consultation on ‘Reforms to the Energy Performance of Buildings Regime’,

we encourage UK wide collaboration on this issue. DfC should actively engage with the UK and other devolved governments on these reforms.

Yes. We support the whole house retrofit approach which is important to reduce fuel poverty in the long- term, improve the energy efficiency of NI’s housing stock and enable a more cost-effective and just transition towards the installation of low carbon heating. This has to be based on the existing fabric of the property and the best pathway for that property to achieve a desired level of energy performance.

It is important for the scheme to recognise that one size doesn’t fit all and that different solutions will suit different properties to improve their energy performance. The University of Ulster’s ‘Domestic Energy Efficiency Scenarios for Northern Ireland’ report supports the need for a whole house retrofit approach, with a wide range of retrofit measures each contributing to significant reductions in energy demand.

The recently launched consultation seeking views on amending the ‘Energy Efficiency Regulations in England and Wales, outlines a range of exemptions that could be considered in a Northern Ireland context. This includes a high-cost exemption (all recommended installations exceed a particular cost cap), wall insulation exemption (if recommendation that insulation would negatively impact the fabric or structure of the property), third-party consent exemption and property devaluation exemption (if improvements devalue property by more than 5%).

Yes. A whole house approach is important to ensure all homes are energy efficient and to optimise fuel bill reductions.

Lessons can be learned from the Northern Ireland Housing Executive’s ‘Low Carbon Retrofit Programme’ which aims to upgrade 300 homes by spring 2025. The programme adopts the following principles to deliver a ‘whole house’ solution:

• Fabric first – optimal level of energy efficiency.
• Low carbon heating – principally heat pumps.
• Renewable generation and storage.
• Improved education and energy advice to householders.
• Detailed data monitoring to optimise efficiency.

A thorough assessment of a home is needed to ensure measures are suitable for both the property and its residents, accounting for factors such as disruption and health considerations

For hard to retrofit properties, we believe that bespoke or specialist advice should be offered to households and that exemptions to improve the energy efficiency of these types of homes should only be permitted when the fabric is improved as much as is practicable for the building, particularly given the low levels of insulation often present in traditional or protected buildings for instance. The National Trust has had considerable success in implementing efficiency measures to ensure their buildings were able to efficiently operate heat pumps.

The complexity of navigating these various measures and ensuring positive experiences and outcomes for households, highlights the need to adopt a flexible approach that considers the most suitable energy efficiency measures for specific houses, in addition to the need for end-to-end tailored guidance to support a just transition towards net zero.

See our response to question 11 for exceptional reasons that should be considered.

Yes. We agree that DfC’s new scheme should prioritise low carbon heating solutions where possible as it is our position that affordability and decarbonisation can be jointly achieved.

In many cases, low carbon heating solutions will result in lower fuel bills for householders and help to alleviate fuel poverty. For example, upgrading to a heat pump from an old oil boiler in a three-bed semi-detached home can save £30 per year or save £700 per year when converting from coal or a new electric storage heater.

Electrifying home heating is also important for reducing carbon emissions and decreasing reliance on fossil fuels and volatile international energy prices.

Effective insultation will be key to maximise the bill savings that can be achieved from installing a low carbon heating system. Therefore, any new fuel poverty scheme should include provisions to ensure properties are well insulated and ventilated, as highlighted in the draft strategy.

Yes. Supporting households to install renewable energy generation helps bring down energy bills. This is particularly important in Northern Ireland, given the closure of the NIRO in 2017, without a suitable replacement for incentivising new small-medium scale generation. In GB and Republic of Ireland, there has been consistent incentivised support (whether this was under the Renewable Obligation, the Feed-in-Tariff, CfD, the SRESS or other support schemes). In Northern Ireland, only a renewable electricity support scheme for 5MW+ generation is so far proposed.

An evaluation of the Northern Ireland Housing Executive’s (NIHE) Solar Photovoltaic (PV) Scheme showed consumers changed their behaviour to save electricity costs. This demonstrates that support for PV can be an effective technology for offsetting running costs of low carbon heating solution.

We would also advise that the Department give consideration to including heat batteries as a technology that could be eligible for support in cases where heat pumps are not suitable or technically feasible. An example where support is made available for solar and electric battery storage is under the Warmer Homes Scotland programme (‘WHS’) which is the Scottish Government’s national fuel poverty programme.

The new scheme should also be flexible and ensure it can offer support for emerging technologies where their efficacy has been proven.

No. We do not agree that rural properties should be specifically prioritised for energy efficiency support, provided their needs are separately considered when designing the strategy and that various statutory obligations to assess the impact and support the social and economic needs on those living in rural communities are fully considered.

Certain characteristics that make people more vulnerable to fuel poverty are proportionately higher in rural areas and therefore we expect a significant proportion of support to be directed to rural properties as a result. The factors more prevalent in rural properties, include: the higher proportion of homes not connected to the gas network (82% of rural homes), higher proportion using pre-payment meters, higher commuting expenditure, lower disposable income and a larger proportion of older homes.

Some rural, remote and island homes can also be more challenging and costly to retrofit with insulation and/or low-carbon heating, due to their age, size, longer commutes for installers and atypical design. Furthermore, off-grid properties have fewer heating alternatives, which can also result in it being more expensive to heat a rural property.

We therefore recommend that additional financial support for making home energy performance improvements is made available to those living in rural properties. As detailed in the previous paragraph, installations can cost disproportionately more, due to a variety of reasons, including limited availability of skilled installers and higher transportation (time and fuel) being factored into quotes, as well as the need for more targeted marketing.

Lessons can be learned from Scotland, where additional support for rural properties is available through a rural uplift of £1,500 under the Scottish Government’s Home Energy Scotland Grant and Loan. This uplift can be claimed by those living in Remote Rural and Island areas, or off-gas Accessible Rural Areas (defined by the Scottish Government’s Urban Rural Classification). Home Energy Scotland advisors are able to confirm if householders can claim this uplift or not.

We support this approach for home energy schemes to ensure funding is distributed according to need.

It is crucial that all households in Northern Ireland have access to schemes that support them to improve the energy efficiency of their homes and transition to low carbon heating. Different levels of support are likely to be necessary for householders in different situations. For example, those living in fuel poverty should be able to access fully funded installations while in the short-medium term, the non-fuel poor should receive subsidised installations.

As we note earlier in our response, when designing a grant scheme there will always be a compromise between simplicity of the scheme and effective targeting of households. The more complex a scheme is and the more hoops consumers must navigate to engage, the greater the risk is that people will be disengaged.

Whilst there are issues arising from assessing household income, which are acknowledged in depth in the consultation, it is worthwhile noting that NISEP operates a sliding scale approach, with a series of schemes designed to differentiate between those in greatest need and those more able to pay (albeit based on household income of all adults living in the residence).

Yes. Where regulatory requirements are in place for landlords to improve their assets, we think that loans are the fairest financing option for landlords.

Where regulatory requirements are not in place, there is a case to be made for the provision of support to tenants living in fuel poverty. Otherwise, there is a significant risk that properties inhabited by private tenants who struggle to pay their fuel bills will remain unimproved, leading to higher fuel bills than necessary.

This would be consistent with the approach taken by the Scottish Government in their national fuel poverty programme (Warmer Homes Scotland). Since 1 August 2017, householders living in privately rented properties have been subject to restrictions to the improvements available under Warmer Homes Scotland. Private rented sector properties that are covered by the statutory Repairing Standard (the minimum level of repair that private rented properties in Scotland must meet) no longer receive improvements that a landlord is legally obliged to provide. These properties are still eligible for other improvements available under Warmer Homes Scotland, if they are recommended.

We very much support existing levies on electricity bills in Northern Ireland and note the significant positive impact that the resultant NISEP programme has had on fuel poverty alleviation and emissions reductions over the last two decades.

However, in the context of the need for greater electrification of heat and transport, if Northern Ireland’s climate change targets are to be met, we think that a wider review (i.e. wider than considering levies solely in the context of their ability to support energy efficiency improvements in fuel poor homes) of levies on electricity bills and potential levies on bills for gas and unregulated heating fuels is required to ensure that climate change and fuel poverty goals can be met in the most effective way.

19. Should we explore introducing levies on gas to increase funding for such energy efficiency measures?

See response to question 18 above.

20. What are your thoughts on exploring any revenue-raising opportunities for energy efficiency schemes from unregulated heating sources such as home heating oil?

See response to question 18 above.

We agree that DfC should utilise and build referral pathways between government, local government, health professionals and the voluntary and community sector.

Given the pace and scale of change necessary to meet decarbonisation targets, the achievement of Northern Ireland’s ambitious net zero targets will require significant shifts in behaviour change at the individual, community and societal level.

A coordinated approach can contribute to raising awareness of available support among all households, establish trust to drive behavioural change (particularly among those most vulnerable) and help do more with less to alleviate fuel poverty, in line with the Northern Ireland Energy Strategy.

We know from our experience of delivering the Scottish Government’s Home Energy Scotland advice service, that referral networks have a vital role to play in ensuring that those most in need of help can access the support available.

Home Energy Scotland works with trusted partner organisations, including health and social care organisations, local charities, foodbanks etc. to build referral pathways for vulnerable households. While most householders contact them through the well-publicised freephone number, online or through outreach activity (public-facing events and webinars), a substantial number, around 12,800 in 2022-23 and 9,400 in 2023-24, are referred from other organisations, who have access to and are trusted by vulnerable householders.

During the 2022-23 and 2023-24 financial years around 9% and 7% respectively of all the unique households advised by HES were referred from trusted partner organisations. These organisations can make seamless referrals using an online referral portal which works in real time to put the householder’s details directly into HES’ database for advisors to follow up.

As well as developing referral networks with other organisations, Home Energy Scotland works with a number of partner organisations to support vulnerable households. Partnership working can take several forms, but the purpose is to encourage people who would benefit from the support to engage with the network. The following are some examples of this work:

• Energy advice stands at flu clinics in partnership with NHS These were targeted at the cohorts of vaccine recipients with the highest level of vulnerability and specifically included frail elderly people, those with chronic health conditions and disabled people.
• Attending information sessions being organised by support groups for their clients to tell them about the support we can provide and encourage them to engage with HES. Partner organisations inviting us to deliver these events include Alzheimer Scotland, Food Banks, Fair Start Scotland providers and NHS organised events in several Health Board areas.
• Partnership with East Ayrshire Women’s Aid – Those referred to HES through EAWA are often experiencing disruption to their living situation and support mostly focuses on practical energy This partnership means some of the most vulnerable and hard to reach have access to energy advice through HES.

The Belfast Warm and Well Project (WAWP), is an example of the effective impact of collaboration and referral pathways at a local level. The project offers advice, practical support and where appropriate, financial assistance to stay warm and well, supporting over 1,000 households in Belfast in 2024.

Simplifying referral processes, making access to services less bureaucratic, establishing trust and working with accredited organisations and networks is crucial to ensure timely and appropriate assistance reaches those who need it most.

We strongly support the proposal to establish a taskforce to develop frameworks for energy communities. Energy communities (and small-medium scale renewable generation) will play a pivotal role in reducing the cost of energy for households and small-medium enterprises. A taskforce should support the empowerment of individuals and communities to engage in energy projects and address barriers to participation.

Delivering community owned energy projects is complex and confusing. There are various stages to project development, from technical appraisals and feasibility studies all the way through to raising capital costs for construction and operational support. Expertise on various models that can be successfully applied to fund certain community projects will be essential. Local Energy Scotland’s guide explores the benefits of funding net zero projects from community benefit income.

Community energy organisations tend to be volunteer led, with limited time and capacity to develop the in-depth financial, technical and legal expertise required. End-to-end support is therefore crucial to hand hold community energy organisations through the numerous barriers to project completion.

We know from our delivering of the Community and Renewable Energy Scheme (CARES) on behalf of the Scottish Government and the Welsh Government Energy Service (WGES) how impactful end- to-end support can be:

• CARES has supported the installation of 60MW of renewable energy capacity in Scotland.
• WGES has supported the installation of 5MW of new renewable energy capacity.

We were also involved in an EU Heroes project in 2020 on enabling community led solar across Europe. One of the key policy recommendations from this project was to introduce a ‘supportive framework’ for energy communities and learning lessons from Scotland and Wales, that can be accessed from inception of an energy community and throughout its lifetime.

A taskforce with the necessary expertise and experience can support and accelerate the effective development of energy communities in Northern Ireland. A service providing end-to-end advice for communities seeking to develop local renewable energy projects should be considered by the taskforce as part of the enabling framework.

We agree that DfC should assess the most relevant recommendations of the NICEG6 guidelines and consider their implementation. Implementing these guidelines could ultimately help reduce winter mortality and the detrimental health effects associated with living in cold homes. The links between cold homes and poor health are well-documented. With NI’s Health and Social Care System already facing significant challenges – including the longest hospital waiting times in the UK – implementing NG6 guidelines is an urgent and necessary step towards improving public health and wellbeing.

A 2023 report by NEA and Marie Curie, found that there had been little consideration of the delivery and impact of NG6 in relation to key vulnerable groups and there were significant data gaps to enable progress to be tracked in England. DfC should consider the results of this report if implementing the NICE6 guidelines in NI. Some recommendations in the report that should be considered, include:

• Further analysis to understand the extent to which fuel poverty is having health consequences for vulnerable groups.
• Energy-related advice and support for the most vulnerable delivered in multiple formats, such as in-person and in-home support, which should be recognised in policy.
• Enhanced understanding of barriers in accessing support that vulnerable groups face, as well as implementing awareness raising campaigns.

We fully support DfC engaging with organisations that provide emergency support when needed and the development of a consistent, accessible approach and improvements of the pathway to long-term sustainable solutions that alleviate the need for emergency support. We welcome DFC’s commitment to work with organisations such as local government to increase awareness and accessibility of emergency financial support for vulnerable and fuel poor people across NI. .

We think that a one-stop-shop could play an important role in referring people to emergency support and in ensuring that they are provided with energy advice and/or referred to an appropriate support scheme. The Welsh Government’s Warm Homes Nest scheme which is the primary mechanism for tackling fuel poverty in Wales, offers crisis support for certain eligible households when they are without heating or hot water (boiler repair or replacement).

In Scotland, the Scottish Government’s Home Energy Scotland (‘HES’) advice service refers customers to energy crisis support schemes where these are available. This includes referrals to the ‘Fuel Insecurity Fund,’ the Fuel Bank Foundation’s pre-payment meter voucher scheme, Fuel Bank Foundation’s HEAT fund (for non-standard heating crisis support) and the Advice Direct Scotland administered Home Heating Support Fund.

In 2022-23 there were 11,661 referrals and signposts from Home Energy Scotland for crisis support rising to 15,904 referrals and signposts in 2023-24.

Yes. We agree that the impact of changing eligibility to the Winter Fuel Payment needs to be explored and better understood. We are particularly concerned that support may not be available to vulnerable low-income pensioners, particularly those who are marginally above the threshold.

Whilst improving the fabric of homes in the short-to-medium term must be considered a priority, vulnerable groups such as pensioners, who face living in cold, damp conditions need immediate support with heightened energy bills in the short-term.

Yes. Section 75 of the Northern Ireland Act provides a framework for assessing impacts and requires DfC to give due regard to promoting equality of opportunity in carrying out its functions.

Given the pace and scale of change facing consumers in Northern Ireland, in addition to certain specific challenges unique within the UK (such as our high reliance on oil and solid fuel heating), it is essential that DfC and other Departments engage with organisations that provide information, advice, training and tools to help consumers better understand the impacts of energy decisions on different consumer groups. This is highlighted by the Consumer Council’s Research Study on ’Attitudes to the Energy Transition,’ which found that there was a worrying decrease in awareness of the need to switch to zero carbon energy solutions (52%) and concluded that there was a need for improved public information regarding the energy transition.

In our response to the recent ‘Consultation on the Establishment of a Just Transition Commission’, we expressed concern that the oversight function proposed by the consultation for the Just Transition Commission (‘JTC’) was a reactive and overly restrictive role, as opposed to the proactive role intended under Section 37(2) of the ‘Climate Change Act (Northern Ireland) 2022′ (‘The Act’).

The JTC can provide a valuable independent and expert resource to help the Northern Ireland government understand the impacts of the many energy decisions they face. However, to do so, the JTC should be empowered to proactively assess and provide advice on the impacts of all energy decisions to “ensure that proposals, policies, strategies and plans required under the act comply with the Just Transition principle” as intended under ‘the Act’. Among other things this principle emphasises “the importance of taking action to reduce emissions, which so far as possible, reduces, with a view to eliminating, poverty, inequality and social deprivation.”

Another valuable resource for improving understanding of the impacts of energy decisions on different consumer groups are results of assessments conducted under the FCA’s Consumer Duty. This requires regulated organisations to categorise vulnerable groups, map their journeys (including where this extends beyond their responsibility), ensure a comprehensive customer understanding of the impacts of changes (eg scheme changes) and to evaluate and remediate any differential outcomes being experienced by defined groups at least annually (for certain regulated activities such as consumer loans).

A range of local and national expert advice organisations currently offer valuable guidance, resources and support for households on how to manage their energy costs. We welcome the Department’s proactive approach to engaging with these organisations throughout the development of the Fuel Poverty Strategy. The format of this approach should be used as guide on how the Department can engage and support organisations going forward, that provide information, training (such as is provided by National Energy Action) and tools to help raise consumer’s awareness of energy efficiency measures and how to control their energy costs.

This includes supporting community-based workshops, support for delivery of training to community leaders and local organisations and support to raise awareness on the availability of energy saving tools, as well as clear, accessible information and advice tailored to the individual’s needs (such as appropriate format and language). To further increase reach, a public awareness campaign should be launched to promote energy-saving tools, cost-saving measures, and support schemes across social media, TV, and local radio. Expanding these efforts will help ensure that information reaches as many people as possible, particularly those who might not engage with online resources.

Advice will be essential to ensure that everyone and in particular those affected most by fuel poverty are aware of available tariffs and how to switch to the most affordable one for them. Specifically in relation to switching, consumers should be directed to the Consumer Council’s (‘CCNI’) Electricity Price Comparison Tool, which enables consumers to compare tariffs and choose the best option for them.

However, it is important to recognise that some individuals may struggle to access or navigate online comparison tools and alternative support channels (for example phone based or in-person advice) have a role to play in ensuring that vulnerable people are adequately supported to ensure they are on the most affordable tariff.

In GB, energy comparison services have extended their service beyond comparing prices only and this should also be supported within Northern Ireland. For example, Citizens Advice has a guide where you can compare energy suppliers’ customer service. Our guide for switching suppliers in GB.

As detailed in previous responses, a coordinated advice service can proactively identify customers who can benefit from switching and direct them to the appropriate service.

Yes. We agree that the Department should prioritise targeted affordability support, including how to support those with higher energy needs.

Yes. Further research is essential to identify and address gaps in non-price protection for different energy users in NI. Key focus areas should includes:

Providing clarity on future energy sources

With about two-thirds of NI households reliant on home heating oil, it’s crucial to provide clear, impartial, and comprehensive advice on alternative heating options. This guidance should include information on the price volatility of both existing fuels and potential alternatives, such as biofuels.

Additionally, consumers need clarity regarding the future of the gas grid. It would be unfair to expect consumers to pay to transition from oil to natural gas if natural gas was also to be phased out in the short to medium term.

Enhancing support and engagement with pre-payment meter users

Investigate and address access and suitability issues faced by consumers using pre-payment meters (PPMs), especially gas PPMs, including difficulties topping up, obtaining a replacement top-up card, PayPoint operational outworkings and challenges in reading meters.

Assisting consumers dependent on solid fuels

Approximately 3% of consumers continue to rely on solid fuels as their primary energy source. Targeted support is necessary to help these individuals transition to alternative fuels, especially considering that many are rural residents, older adults, or individuals in vulnerable circumstances.

Supporting transition from biomass heating systems

Consumers currently using biomass as their primary heating source require adequate support to transition to new fuel types. This is particularly important for those who adopted biomass systems under a now defunct energy efficiency scheme.

Yes. The government should adopt clear technical standards and a common quality assurance standard or framework across all energy efficiency and low carbon heat grant schemes, to support a consistent and transparent approach, taking care not to require registration to multiple schemes. This standard or framework should include ensuring installer certification, adequate redress mechanisms in the sector and facilitate a coordinated approach to enhance consumer confidence and protection.

In England, the government has commenced the process of tightening existing quality assurance frameworks and have indicated that they will set out further plans for reform as part of the ‘Warm Homes Plan.’

Yes. We agreethat the government and other bodies, such as the Utility Regulator, have an obligation to ensure clear and enforceable consumer protections are implemented across all supported energy efficiency schemes.

Without a consistent approach, consumers could face confusion and uncertainty, undermining confidence in schemes. In order to engage households in the transition towards net-zero, it will be essential that they are aware of and understand any proposed or actual changes to schemes.

Households should feel empowered and confident that they can rely on any upgrades to their home being appropriate, being fit-for-purpose and being installed by certified operatives who have the appropriate skills to install these upgrades. Therefore, it is essential that protections are in place should any link in the supply chain fail.

We agree that installers should be registered to a certification scheme such as MCS. Ensuring that installers are registered to a certification scheme such as MCS will be vital to protect consumers during installation of emission reduction measures. It is however only one part of the equation and other actions will be required – for example the provision of a central point of contact of information and advice services for customers when they are seeking to retrofit their home.

As highlighted in the recent ‘Consultation on Support for Low Carbon Heating in Residential Buildings,’ research undertaken by the Consumer Council for NI and by Robinson, Bloomfield and Meek indicated that consumers can be sceptical of information that focuses only on the benefits. The report recommended that it is essential that consumers are protected from harmful business practices and that they should be provided with sufficient information to make informed decisions about which products are right for them.

We recognise the significant challenges posed by the shortage of skilled installers and how to ensure their geographical spread, given for instance that there are currently only 11 MCS certified contractors in Northern Ireland, compared to 128 in Wales. However, lessons can be learned from various programmes that have been successfully introduced in parts of GB to help to accelerate the upskilling of installers. For example, the Scottish Government’s Green Heat Installer Engagement programme, which we manage on their behalf, provides a range of support for installers including a ‘heat pump toolkit’ to encourage the heating industry to achieve MCS certification, with the ‘insulation installer toolkit’ encouraging the construction industry to increase the quality of their work and competency through the PAS2030 and through TrustMark registration. An MCS grant is also available to enable engineers to gain MCS certification and a ‘mobile heat pump van’ to support training of those in rural areas with no training provision.

In the context of consumer protection, the department might also be interested in the following:

• As part of its current review of Ofgem’s terms of reference, the UK Government’s Department of Energy Security and Net Zero has sought views on Ofgem’s remit in enforcing consumer law in respect of low carbon technologies, such as heat pumps and solar panels, and what the appropriate boundaries might be.
• Consumer Scotland – the statutory, independent body set up by the Scottish Parliament to promote consumer protection across water, energy and postal services is currently undertaking an investigation into consumer protections in the market for energy efficiency and low carbon products. While this investigation focusses solely on Scotland, we note that some of the issues being considered will be common across the UK and as such, the findings of the investigation, once they are published, may a useful source of information for the department as it considers appropriate consumer protections for the low carbon heating.
• The Competition Markets Authority’s (CMA) findings report published in May 2023 on ‘consumer protection in the green heating and insulation sector’. The findings of this work showed that consumers looking to buy low-carbon technologies can face difficulties and are not always treated fairly by businesses, concluding that the standards landscape is not working as effectively as it could. This is because it is complex and confusing for consumers to navigate, this is coupled with low consumer awareness which risks putting consumers off buying low carbon products or having negative experiences due to purchasing the wrong system for their home.

Crucially, the CMA report also summarised necessary steps from governments across the UK, including the prioritisation of centralised information and advice services for consumers.

We agree that the term ‘poverty’ can discourage some people from seeking the support they need and are entitled to. Language plays a crucial role in engagement, and we support the use of person- centred, sensitive and compassionate language, delivered in multiple languages where appropriate. Government messaging around fuel poverty should set the tone for the sector, by avoiding stigma and be framed in a way that encourages the widest possible participation and support.

However, while we recognise the benefits of more positive framing – such as ‘energy wellbeing’ – it is important that the term ‘fuel poverty’ is not removed entirely from government language, particularly in policy contexts. ‘Fuel poverty’ is a widely recognised term with an established legal (in GB) and policy framework and ensures that fuel poverty remains linked to broader discussions on poverty and inequality. We support the new strategy being called a Fuel Poverty Strategy rather than shifting solely to ‘energy wellbeing’, which could risk siloing fuel poverty from other types of poverty.

Clarity and transparency are also needed. The language used in schemes should clearly explain the processes and impacts of home energy upgrades, supporting consumers to make informed decisions based on their property and needs. In addition, government communications should draw on best practice for changing behaviour to remove any inconveniences and friction in application processes, making it easier for people to access support and minimising drop off throughout the process.

Separately in relation to the term ‘vulnerable’, we acknowledge that this is also widely recognised and embedded within regulatory frameworks. However, we have identified that there are significant prejudices associated with the term and sometimes those in need may not identify as being vulnerable or are reluctant to be categorised as such. Therefore, for instance, when engaging individuals and undertaking regulated activities obligated by the Financial Conduct Authority (that requires vulnerable groups to be reported on), we identify characteristics of vulnerability but in correspondence with individuals we evaluate if they require ‘additional support’ rather than referring to them as vulnerable or using this term.

Yes. We welcome this approach and the commitment to better utilise data and research from other organisations, to build a clearer picture of fuel poverty and energy wellbeing and inform the design and delivery of targeted policies.

However, we would like to see the final fuel poverty strategy include targets for reducing fuel poverty. The Department has indicated that previous fuel poverty targets were not met and has seemingly proposed substituting this with improved accountability through various assessments and an annual Ministerial Statement. While these measures are welcome, clear targets should also be set, as these can help drive accountability and progress.

Targets exist in England, Scotland, Wales, and the Republic of Ireland, including those related to energy efficiency. Lessons should be learned from these jurisdictions and the experiences of previous missed targets when setting realistically achievable targets. Previous failures should not be used as justification for avoiding setting targets.

We welcome the Department’s proposed expansion of indicators. Overall, we are positive about the indicators suggested but believe there are areas where they could be strengthened.

The primary purpose of these should be to identify those who are not living in a warm and healthy home and to ensure they are appropriately supported to do so.

Whilst a clear set of guidelines will be required to ensure these are as objective as possible, we welcome the approach to introduce a range of indicators, given the limited approach previously adopted had the potential to unfairly disadvantage certain groups, such as the working poor and those who have higher costs associated with additional essentials (eg those requiring certain medical equipment).

There has been a similar recognition in England that metrics based purely on household income are no longer appropriate for alleviating fuel poverty. For example, in response to efforts to alleviate fuel poverty flatlining in England, a report by the ‘Committee on Fuel Poverty’ has recommended replacing the ‘Low Income, Low Energy Efficiency’ (LILEE) metric, which is based on household income as “it no longer captures the full range of households facing unaffordable bills.”

Our main concern is the infrequency of the NI House Condition Survey (HCS), with the last survey conducted in 2016 and published in 2018, while the 2023 HCS remains unpublished. Delays in reporting reduce its effectiveness in informing policy. Additionally, as the HCS is based on a model developed for England, it may not fully capture the realities of fuel poverty in NI, where a much higher proportion of households rely on home heating oil. There are also concerns about the accuracy of self-reported data, as respondents may be uncertain about how their answers will be used.

One notable omission in the indicators is a measure of disconnection rates. Understanding how many households lose access to energy due to debt would provide critical insight into energy hardship. The draft strategy does not currently explore this in detail or consider how data from the Utility Regulator and energy suppliers could be used for this purpose. While the widespread rollout of smart meters is still a few years away, they could eventually provide valuable data on frequent disconnections.

Despite these concerns, many of the proposed indicators offer valuable insights. The decision to model extreme and severe fuel poverty annually is a welcome improvement, as it will allow for closer monitoring of the most vulnerable households. Introducing an “after housing costs” fuel poverty measure is also positive to provide a clearer picture of financial hardship, particularly among working families who may have high rent or mortgage payments. Similarly, the indicator assessing whether households are able to pay regular bills is crucial in NI where hidden energy debt is a significant issue. Many households may not formally fall into arrears with energy companies but instead delay filling their oil tanks or topping up prepayment meters, masking the true extent of their financial difficulties. The inclusion of indicators on home warmth and damp are also welcome.

Asking households whether they can keep their homes adequately warm acknowledges that energy needs vary based on health, age, and personal circumstances. Additionally, tracking the presence of damp and mould in homes is vital given their direct link to poor health. We welcome that this question is now included in the Family Resources Survey.

We agree with the introduction of an indictor based on energy confidence, agency or awareness, as it would be valuable to gauge people’s understanding and confidence in navigating available support and implementing long-term energy solutions. Tracking this over time would help identify areas where improvements are needed.

To ensure this indicator is as effective as possible, we recommend the Department collaborates with the Consumer Council for NI (‘CCNI) – the statutory body responsible for protecting, empowering, understanding and representing consumers – to develop this indictor, utilising their expertise and extensive research on consumer attitudes and experiences.

Given the pace and scale of change facing consumers in Northern Ireland, in addition to certain specific challenges unique within the UK (such as our high reliance on oil and solid fuel heating), it is essential that the Department of Communities and other Departments engage with organisations that provide advice, information, training and tools to help consumers better understand the impacts of energy decisions on different consumer groups, including National Energy Action (‘NEA’), Fuel Poverty Coalition (‘FPCNI’), the Consumer Council (‘CCNI’) and the Northern Ireland Housing Executive (;NIHE’). This is highlighted by the Consumer Council’s Research Study on ’Attitudes to the Energy Transition,’ which found that there was a worrying decrease in awareness of the need to switch to zero carbon energy solutions (52%).

Additionally, it is essential that an indicator based on energy confidence, agency or awareness carefully consider the PRS, which can help identify any gaps.

Yes. Carbon emissions data should be recorded and available for certain purposes but should not be used as a fuel poverty indicator.

However, it is important to note that decarbonisation and fuel poverty goals can align. For example, improved domestic energy efficiency, which reduces household energy demand has the dual benefit of reducing both a household’s overall energy bills and carbon emissions.

We welcome the Department’s commitment to continue to engage directly with people living in fuel poverty. Consideration should also be given to a ‘Lived Experience Advisory Group,’ which could provide valuable insight and challenge to the proposed multi-agency ‘Fuel Poverty Advisory Group.’

As recognised within the consultation and our responses to this, for engagement to be effective, it must be accessible to all (particularly vulnerable individuals), deliver positive customer experiences and be fair and transparent in delivering a just energy transition and warm and healthy home for everyone.

It is also important to proactively reach out to vulnerable and hard-to-reach individuals, who may be less likely to engage independently. This could involve community-based initiatives, partnerships with trusted local organisations and tailored approaches that consider language, digital access, and cultural differences. It is also important to address the barriers to participation which we have detailed in our response to question four.

As detailed in previous responses, we support the use of a national and local advice service for engaging with the fuel poor (see our response to question 21 for information on how the Home Energy Scotland model engages with the fuel poor and partners with stakeholders).

The Department may also be interested in some recent novel approaches to encouraging engagement, including the ‘Nest home energy support scheme quiz’, which has been successful at targeting over 800 unique households during the three-month period of the competition. Participants are guided through a non-intrusive, four question quiz online or over the phone (the accompanying text contains answers and ), with the ultimate goal of increasing awareness of certain low carbon technologies or energy efficiency measures, as well as driving engagement in the energy transition.

Yes. We fully support this proposal and see significant value in the establishment of a multi-agency Fuel Poverty Advisory Group. It is crucial that this group is independent of government while still influential in guiding, advising and challenging actions and progress over the lifetime of the Fuel Poverty Strategy. To sustain progress on the strategy, the group should have a structure that allows it to continue functioning even in the event of any disturbance to the functioning of the Executive.

Furthermore, we recommend the Advisory Group engages directly with those on the frontline – both individuals experiencing fuel poverty and those providing support.

We commend the DfC Climate Change Division team for their extensive stakeholder engagement throughout the development of this draft strategy. This has come across as a genuine effort to involve and learn from key stakeholders and community groups. We encourage that this approach continues to be exercised as the strategy is implemented.

Set statutory fuel poverty targets

The fuel poverty strategy must prioritise the setting of measurable targets, as the only region of the UK without such targets. This is contributing to lagging progress in monitoring and intervention. To support effective delivery and cross-departmental collaboration, the strategy must be supported by legislative targets that align with the NI Climate Change Act and the Energy Strategy for NI.

Digital Tools – Home Energy Efficiency

The Department may also be interested in the range of existing tools and data that are available to support the understanding of the impacts of energy efficiency policies and strategies across parts of the UK. These have proven valuable in supporting decision making around a just energy transition and which may be able to be tailored specifically to a Northern Ireland context. Some of these are listed below.

This includes for instance, the ‘NIHE – Home Energy Saving Tool’ and the property-level housing stock database ‘Home Analytics’, that we developed to provide address-level data on the energy performance of homes, which is utilised for example by Scottish local authorities and housing associations to support the development, targeting and delivery of policies and programmes such as area-based schemes and Local Heat and Energy Efficiency Strategies.

In response to user need, we also developed the Portfolio Energy Analysis Tool (‘PEAT’) Using data from Home Analytics, PEAT allows the modelling of energy improvement strategies for groups of buildings: for example, to assess the impact of installing cavity wall insulation across a whole street – in terms of the homes’ bills, energy and carbon performance. PEAT can also present data on what measures are required to bring all the homes in an area to (for example) Energy Performance Certificate “C” Standard. This is a key tool to help local authorities and social housing providers plan energy efficiency programmes to meet regulatory standards.

At the request of the Scottish government, a non-domestic version was also developed to assist the Scottish Government in the research, design and planning of non-domestic policies and schemes focused on: improving energy efficiency, increasing the uptake of low and zero emissions heating systems and accelerating decarbonisation efforts.

Separately, our ‘Homewise’ tool, which has address-level data for every property in GB, empowers residents to create warmer, healthier homes and save on their energy bills with a tailored retrofit action plan. By completing a simple online survey, residents can get a personalised home energy action plan, including indicative EPC rating and a breakdown of the cost for any work and potential savings, that is tailored to their needs and budget within minutes

Response submitted by: Darryn Mallon, Policy Lead Northern Ireland.