CIH Northern Ireland welcomes the opportunity to respond to the Department for Communities' consultation on a new fuel poverty strategy for Northern Ireland

Raising housing standards

QUESTION 3: What would a readily understandable and measurable definition of ‘thermal comfort’ look like?

CIH Northern Ireland believes that a readily understandable and measurable definition of thermal comfort should balance the need for a workable, population-level policy with the importance of individual affordability. While individual circumstances vary, a strong foundation can be built on evidence-based standards that aim to ensure households can reasonably afford to heat their homes. Therefore, we propose the following definition:

"Thermal comfort is achieved when a dwelling consistently maintains a warm, healthy temperature, appropriate to typical occupancy and activity, which households can reasonably afford to achieve without experiencing undue financial hardship."

This definition focuses on the home itself, setting a baseline standard that is applicable across the housing stock, while still acknowledging the crucial role of affordability. It has several key components:

• Warmth: This refers to achieving and maintaining a temperature range conducive to health and well-being, appropriate for typical occupancy and activities within the home. We support increasing the temperatures at which rooms in dwellings should be able to be maintained, reflecting World Health Organisation recommendations.These temperatures should be clearly defined and easily measurable using standard thermometers, with variations for different room types (e.g. living rooms, bedrooms). This removes the complexity of individual preferences while still setting a healthy baseline.
• Consistency: Fluctuations in temperature can be detrimental to health, even if the average temperature falls within an acceptable range. This can be measured through monitoring temperature variations over time, using tools like smart thermostats or data loggers.
• Reasonable affordability: This is the critical link to fuel poverty. Rather than assessing affordability on an individual household basis (which presents significant logistical challenges), this focuses on setting standards that are achievable for a reasonable proportion of households within a given income bracket. This could involve:
  • Energy efficiency standards: Setting minimum energy efficiency standards for dwellings to reduce the energy required for heating. This provides a baseline for affordability.
  • Targeted support: Recognising that even with improved energy efficiency, some households will still struggle, targeted support (grants, energy advice, social energy tariff) should be available for low-income households and those with specific vulnerabilities.
  • Regular review: The ‘reasonable affordability’ aspect should be regularly reviewed considering changing energy prices, household incomes and advancements in energy efficiency technologies. This ensures the standard remains relevant and effective.

Measurable elements

To make this definition measurable, the following data points should be collected and analysed:

• Indoor temperature: Measured using calibrated thermometers or data loggers.
• Energy performance certificates (EPCs): Used to assess the energy efficiency of dwellings.
• Standardised energy bills: Modelled or collected for representative households within different income brackets to assess affordability against the defined temperature ranges. This would create a benchmark for ‘reasonable affordability’ incorporating income thresholds and energy expenditure benchmarks.
• Fuel poverty indicator (at a population level): Calculated based on modelled energy expenditure and income data.
• Damp and mould: Assessed through data collation informed by good practice and regulatory requirements, linked to the thermal comfort standards.

Implementation

This definition should be incorporated into the housing fitness standard and the fuel poverty strategy. It should be used to:

• Set clear, achievable targets for thermal comfort based on dwelling characteristics and reasonable affordability.
• Monitor progress in achieving those targets at a population level.
• Identify areas and demographics where fuel poverty is most prevalent.
• Target support and interventions to those areas and households most in need.

By focusing on dwelling-level standards and ‘reasonable affordability’, this approach provides a workable policy framework while still addressing the core issue of fuel poverty. It allows for a consistent, measurable approach while acknowledging the need for targeted support for the most vulnerable.

Introducing Minimum Energy Efficiency Standards (MEES) in the private rented sector (PRS) by 2027

CIH Northern Ireland strongly believes that minimum energy efficiency standards (MEES) in the private rented sector (PRS) are a crucial tool for alleviating fuel poverty. The 2016 House Condition Survey estimated that 13 per cent of PRS properties were unfit. However, the effectiveness of MEES hinges on having the right information, overcoming key barriers and considering their application to other tenures.

QUESTION 4: For MEES in PRS to effectively alleviate fuel poverty, what information or data do you think would be useful and what barriers would we need to overcome?

To ensure MEES are effective in addressing fuel poverty, the following information and data are essential:

• Up-to-date EPCs: Accurate and readily available EPCs are the foundation of MEES. They provide a standardised assessment of a property's energy performance and identify areas for improvement. A regional database of EPCs, linked to individual properties, should be maintained and easily accessible to landlords, tenants and enforcement agencies.
• Revised energy performance measurement: CIH Northern Ireland recommends exploring the development of a revised energy performance measurement methodology that places a stronger emphasis on building fabric improvements. The current EPC system, while valuable, can be skewed by renewable energy installations, such as solar panels. This can create a misleading picture of a property's actual energy efficiency and potentially incentivise landlords to invest in renewables rather than essential fabric upgrades, when both need to be considered. A revised measurement system should better reflect the inherent energy efficiency of the building itself, separate from energy generation technologies. This could involve, for example, a fabric-first rating alongside the overall EPC rating. This will ensure that improvements are made to the fabric of the building, which remains an important way to reduce energy demand and tackle fuel poverty in the long term.
• Regional database of energy efficiency upgrades: A comprehensive database tracking energy efficiency improvements made to properties is crucial. This would allow for monitoring progress, identifying areas where improvements are lagging, and preventing landlords from claiming exemptions without undertaking necessary work. This database should be linked to the EPC database.
• Data on fuel poverty prevalence in the PRS: Understanding the extent of fuel poverty within the PRS is essential for targeting interventions. Data on energy expenditure, household income and vulnerability indicators within this sector should be collected and analysed.
• Information on property type, heating systems and energy costs: Detailed information about the characteristics of PRS properties, including the type of dwelling, heating systems used and energy costs, is necessary for developing tailored MEES and support programmes.
• Tenant feedback mechanisms: Creating channels for tenants to report issues related to energy efficiency and heating in their rented properties is crucial for effective enforcement of MEES. This could involve anonymous reporting systems or partnerships with tenant advocacy organisations.

Barriers to overcome

Landlord resistance: Some landlords may resist implementing MEES due to the costs involved. Alternatively, they may sell their properties, undermining the strategic objectives of tenancy security and supply of private rented homes. Overcoming this requires a combination of:

• Financial incentives: Offering grants, loans and tax breaks to help landlords finance energy efficiency upgrades. A sliding scale of support, prioritising smaller landlords and those with vulnerable tenants, should be considered.
• Clear and consistent communication: Providing landlords with clear information about their obligations, the benefits of energy efficiency improvements (including increased property value and tenant retention) and available financial support.
• Enforcement: Implementing robust enforcement mechanisms to ensure compliance with MEES, including penalties for non-compliance.
• Enforcement gaps: Enforcement of MEES can be challenging due to limited resources and capacity. Addressing this requires:
  
  • Adequate funding: Providing enforcement bodies with the necessary resources to enforce MEES effectively.
  • Training and guidance: Providing training and guidance to enforcement officers on how to assess energy efficiency and handle complaints.
  • Collaboration: Facilitating collaboration between local authorities, tenant organisations and other stakeholders to share information and coordinate enforcement efforts.
• Tenant displacement: Energy efficiency upgrades may sometimes require tenants to temporarily vacate their homes. Mitigating this requires:
  • Clear guidance: Providing clear guidance to landlords and tenants about their rights and responsibilities during upgrades.
  • Support for tenants: Offering support to tenants who are displaced, including assistance with finding temporary accommodation and covering moving costs.
  • Affordability for small-scale landlords: Small-scale landlords may face challenges in financing energy efficiency upgrades. Addressing this requires tailored financial assistance and advice to small-scale landlords.

QUESTION 5: Should MEES also be applied to other tenures? Please give reasons for your answer.

CIH Northern Ireland believes that tackling fuel poverty across all tenures is vital. MEES should initially be applied to both rented sectors, and relevant departments should undertake further work to understand the appropriateness of applying MEES to the owner-occupied sector, which is also likely to be necessary to meet decarbonisation targets. The reasons are:

• Fuel poverty is not tenure-specific: Fuel poverty affects households across all tenures. While the PRS may have a higher prevalence, owner-occupiers also struggle with energy costs, as do many social housing tenants while recognising the higher overall standard of social rented housing in Northern Ireland with over 75 per cent of social homes exceeding EPC band C. Addressing fuel poverty requires a comprehensive approach that tackles energy inefficiency in all types of housing.
• Health and well-being: Living in a cold, damp home has detrimental effects on health and well-being, regardless of tenure. Ensuring that all homes meet minimum energy efficiency standards is essential for protecting the health of the population.
• Climate change targets: Improving the energy efficiency of the entire housing stock is crucial for meeting Northern Ireland's climate change targets. Further work is needed to understand the practicalities of applying MEES to the owner-occupied sector, and to create a workable method of regulation.
• Equity: It is inequitable to apply MEES only to the rented sectors. All households deserve to live in warm and healthy homes, regardless of their tenure.

CIH Northern Ireland recognises the practical difficulties associated with implementing MEES in the owner-occupied sector. Further research and consultation are necessary to develop a workable regulatory framework that balances the need to address fuel poverty and decarbonisation targets with the rights and responsibilities of homeowners.

Phased approach

While MEES may ultimately apply to all tenures, a phased approach is sensible to address the specific challenges of each sector. It is most practical to first apply the standards to the rented sectors, where enforcement and regulation are more straightforward. This allows for the development of effective implementation strategies and the identification of potential issues.

Following the successful implementation of MEES in the rented sectors, relevant departments should then undertake further work to understand the appropriateness of applying MEES to the owner-occupied sector. This sector presents unique challenges, including political considerations and the complexities of regulation enforcement. However, to achieve necessary decarbonisation targets, the application of MEES to the owner-occupied sector will likely be necessary in the long term.

Further considerations include:

• Owner-occupation: Incentives, advice and financial support will be particularly important for encouraging owner-occupiers to improve the energy efficiency of their homes.
• Social housing: Social landlords have a responsibility to ensure their properties meet decent standards. Clear targets and funding mechanisms should be in place to support social housing providers in implementing MEES. Critically, to achieve the necessary fabric upgrades at scale within the social housing sector, CIH Northern Ireland believes a dedicated decarbonisation fund is required. This fund should be specifically targeted at large-scale fabric improvements in social housing, recognising the significant upfront investment required. This fund would enable social landlords to implement these upgrades efficiently and effectively, ensuring that social housing tenants benefit from warmer, healthier homes and lower energy bills. This is essential for both tackling fuel poverty and meeting decarbonisation targets.

By adopting a comprehensive approach to MEES, potentially covering all tenures and addressing the key barriers to implementation, including targeted funding for social housing decarbonisation, Northern Ireland can make significant progress in alleviating fuel poverty and creating a healthier, more sustainable housing sector.

Implementing improved Fitness Standards for all tenures by 2030

QUESTION 6: Do you agree that introducing updated fitness standards will contribute to making homes more energy efficient? Please provide reasons for your answer.

CIH Northern Ireland strongly agrees that introducing updated fitness standards will contribute to making homes more energy efficient, but it's crucial to understand how and to ensure the updated standards are designed effectively to achieve this goal.

Reasons for agreement:

• Direct link between fitness and energy efficiency: Many aspects of housing fitness are directly related to energy efficiency. For example:
  
  • Insulation: Adequate loft, wall and floor insulation are essential for both preventing excess cold (a key fitness standard concern) and reducing energy loss. Updated fitness standards should mandate minimum insulation levels.
  • Heating systems: Efficient and well-maintained heating systems are crucial for both thermal comfort and energy efficiency. Updated standards should require efficient heating systems and address issues like boiler age and performance.
  • Damp and mould: Addressing damp and mould (another fitness standard concern) often involves improving ventilation and insulation, which also contribute to energy efficiency.
  • Windows and doors: Draughty windows and doors contribute to both heat loss and excess cold. Updated standards should address window and door quality and airtightness, while also achieving adequate ventilation.
• Driving investment: Updated fitness standards can act as a driver for investment in energy efficiency improvements. By setting clear requirements, they can incentivise landlords and homeowners to upgrade their properties, leading to a wider improvement in the energy efficiency of the housing stock. This is particularly important in the private rented sector, where MEES and fitness standards can work in tandem.
• Targeting the worst properties: Updated fitness standards can help identify and target the worst performing properties in terms of energy efficiency. This allows for prioritising interventions and ensuring that the most vulnerable households living in the coldest and most inefficient homes receive the support they need.
• Foundation for MEES: Updated fitness standards can provide a strong foundation for MEES. By aligning fitness standards with energy efficiency requirements, it becomes easier to enforce MEES and ensure that landlords are taking the necessary steps to improve the energy performance of their properties.

To reiterate, many homeowners and housing providers will need financial support to meet the updated fitness standards. Grants, loans and other incentives should be available to help them make the necessary improvements. Furthermore, updated standards are only effective if they are properly enforced. Enforcement authorities must be given the necessary resources and training to ensure compliance.

By carefully considering these points, the introduction of updated fitness standards can be a powerful tool in improving the energy efficiency of homes in Northern Ireland and contributing significantly to the fight against fuel poverty.

Introducing a more ambitious energy efficiency scheme aligned with fuel poverty strategy principles

CIH Northern Ireland strongly believes that a coordinated and flexible approach is essential for effectively tackling fuel poverty. This includes aligning all government domestic energy schemes with the fuel poverty strategy principles, adopting a data-driven approach to eligibility criteria, and strategically using EPC ratings.

QUESTION 7: Do you agree that all government domestic energy schemes should take account of the Fuel Poverty Strategy principles?

CIH Northern Ireland strongly agrees that all government domestic energy schemes must take account of the fuel poverty strategy principles. This is crucial for several reasons:

• Maximising impact: Aligning schemes ensures that resources are used effectively and that interventions are targeted at those most in need. Without alignment, there's a risk of duplication, gaps in provision and inefficient use of public funds.
• Consistency and coherence: A consistent approach across all schemes creates a more coherent and understandable system for both homeowners and those seeking support. This reduces confusion and makes it easier for people to access the help they need.
• Prioritising fuel poverty: By aligning with the fuel poverty strategy principles, energy schemes can directly contribute to the overarching goal of alleviating fuel poverty. This ensures that the schemes are designed with the specific needs of fuel-poor households in mind.
• Holistic approach: Fuel poverty is a complex issue that requires a holistic approach. Aligning energy schemes with the fuel poverty strategy ensures that interventions are coordinated and address the multiple factors that contribute to fuel poverty, including low incomes, inefficient homes and high energy costs.

QUESTION 8: Do you agree that DfC should take a more flexible approach that considers current data when setting and reviewing: a) income thresholds and b) eligibility criteria?

CIH Northern Ireland strongly agrees that the Department for Communities (DfC) should adopt a more flexible, data-driven approach to setting and reviewing income thresholds and eligibility criteria for energy schemes. Rigid, outdated criteria can exclude many households struggling with fuel poverty. A flexible approach based on current data is essential for:

• Accurate targeting: Using up-to-date data on household incomes, energy costs and fuel poverty prevalence allows for more accurate targeting of support. This ensures that assistance reaches those who are genuinely in need.
• Responsiveness to change: Energy prices, household incomes and economic circumstances can change rapidly. A flexible approach allows DfC to respond to these changes and adjust eligibility criteria accordingly, ensuring that support remains relevant and effective.
• Addressing inequities: A data-driven approach can help identify and address inequities in access to support. For example, it can ensure that rural households, those with disabilities and other vulnerable groups are not disproportionately excluded from energy schemes.
• Streamlining processes: A flexible approach can also streamline application processes and reduce administrative burdens, making it easier for people to access support.

QUESTION 10: Should the Energy Performance Certificate (EPC) rating of a house be considered as part of eligibility criteria (i.e. the least energy efficient homes are considered first)? Please give reasons for your answer.

CIH Northern Ireland strongly supports using the EPC rating as a key part of the eligibility criteria for energy schemes, prioritising the least energy-efficient homes. This ‘fabric-first’ approach is essential for several reasons:

• Greatest impact: Investing in improving the energy efficiency of the coldest and least efficient homes has the greatest impact on reducing fuel poverty. These homes often have the highest energy bills and pose the greatest risk to the health and well-being of residents.
• Long-term solutions: Focusing on fabric improvements provides long-term and sustainable solutions to fuel poverty. These measures reduce energy demand and make homes warmer and more comfortable, regardless of fluctuations in energy prices. This is a more effective approach than relying solely on measures that address heating systems, which may become less efficient over time if the fabric is poor.
• Value for money: Investing in fabric improvements provides better value for money in the long run. While the upfront costs may be higher, these improvements reduce energy bills for years to come, benefiting both individual households and public funds.
• Supporting MEES: Using EPC ratings as eligibility criteria reinforces the importance of MEES and incentivises landlords to improve the energy performance of their properties.
• Addressing the root cause: Tackling the root cause of fuel poverty requires addressing the energy inefficiency of homes. Prioritising the least energy-efficient homes is the most direct way to achieve this.

However, CIH Northern Ireland reiterates the need for a revised energy performance methodology that places a stronger emphasis on actual building fabric. Relying solely on current EPC ratings may not represent the full picture, as discussed previously. A revised system would ensure that support is targeted at homes that are truly energy inefficient, including those with renewable energy installations. This will ensure that improvements are made to the fabric of the building, which is an important way to reduce energy demand and tackle fuel poverty in the long term.

Measures included in the new scheme

CIH Northern Ireland believes a comprehensive and targeted approach is essential for effectively addressing fuel poverty and decarbonising the housing stock. This includes adopting a whole house retrofit approach, prioritising fabric improvements, low carbon heating, supporting renewable technologies, and recognising the specific needs of rural properties.

While we strongly support the inclusion of all measures (fabric, low-carbon heating, and solar/batteries), it's crucial to follow a 'fabric first' approach. This means most of the funding in any new scheme should be directed towards fabric measures, with a cap or ceiling on the amount allocated to low-carbon technology. Another option could be to mandate that a new scheme includes an adequate minimum target of installations for fabric measures, such as loft, external/internal wall and/or underfloor insulation, which aligns with the way the Energy Company Obligation (ECO) scheme works in Great Britain. We can strongly support the inclusion of all measures, but it's vital to design the scheme in a way that ensures most of the funding goes towards fabric measures.

QUESTION 11: Do you agree that the new scheme should take a Whole House retrofit approach? Please give reasons for your answer.

CIH Northern Ireland strongly agrees that the new scheme should adopt a whole house retrofit approach. This approach, which considers the interconnectedness of different building elements, offers significant advantages:

• Maximising energy efficiency: A whole house approach considers the building as a system, recognising that improvements to one area like insulation can impact other areas such as ventilation. This holistic approach maximises energy savings and avoids unintended consequences, such as damp.
• Cost-effectiveness and minimising disruption: While the initial investment may be higher, a whole house approach can be more cost-effective in the long run. By addressing multiple issues at once, it avoids the need for repeated, disruptive interventions, promoting tenancy security and reducing the overall cost of achieving a high level of energy efficiency.
• Improved comfort and health: A whole house approach not only improves energy efficiency but also enhances thermal comfort, indoor air quality and overall health and well-being.
• Long-term sustainability: By focusing on fabric improvements and whole-building performance, a whole house approach creates more sustainable and resilient homes that are less vulnerable to future energy price fluctuations.

QUESTION 12: If the Whole House approach is used, do you agree that all recommended measures must be installed unless there are exceptional reasons not to? Please give reasons for your answer.

CIH Northern Ireland agrees that in principle, all recommended measures within a whole house retrofit should be installed to achieve maximum benefit. However, a degree of flexibility is necessary. ‘Exceptional reasons’ for not installing certain measures should be clearly defined and may include:

• Up-front capital expenditure: In some cases, the upfront cost of installing a particular measure may be prohibitively high for landlords and homeowners, especially without grant or other financial support. While a long-term cost-benefit analysis may demonstrative eventual savings, the immediate capital expenditure can be a significant barrier. A clear assessment of the financial implications, with consideration of the support available to the household, is essential.
• Technical feasibility: In some cases, certain measures may not be technically feasible due to the age, construction or location of the property.
• Listed building status: Listed buildings may have restrictions on alterations that prevent the installation of certain energy efficiency measures.

A clear process for assessing and documenting exceptional reasons should be established to ensure transparency and prevent abuse.

QUESTION 13: Do you agree that the new scheme should prioritise low carbon heating solutions where possible?

CIH Northern Ireland strongly agrees that the new scheme should prioritise low carbon heating solutions where possible. Over 68 per cent of domestic heating is still provided by oil-fired boilers. Low carbon heating is essential for meeting climate change targets and reducing reliance on fossil fuels. However, the ‘where possible’ is crucial.

• Appropriate technology: The choice of low carbon heating solution must be appropriate for the specific property and its location.
• Fabric first: A ‘fabric first’ approach is essential. Improving insulation and reducing heat loss should be prioritised where necessary before installing low carbon heating. This ensures that the heating system operates efficiently.
• Affordability: Low carbon heating solutions can have high upfront costs, and sometimes higher running costs. Financial support and incentives are essential to make these technologies accessible to low-income households in line with ‘just transition’ principles.

QUESTION 14: Do you agree that the new scheme should offer renewable technologies such as solar panels and battery storage to offset the running costs of low carbon heating solutions in low-income households? Please give reasons for your answer.

CIH Northern Ireland strongly supports offering renewable technologies, such as solar panels and battery storage, to offset the running costs of low carbon heating solutions, particularly in low-income households.

• Reduced energy bills: Renewable technologies can significantly reduce energy bills, making low carbon heating more affordable for low-income households.
• Energy independence: Generating their own electricity can give households greater energy independence and protect them from fluctuating energy prices.
• Environmental benefits: Renewable technologies contribute to reducing carbon emissions and achieving climate change targets.

Battery storage is particularly important as it allows households to store excess solar energy generated during the day and use it at night or during periods of low sunlight. This maximises the benefits of solar panels and improves the efficiency of low carbon heating systems.

QUESTION 15: Do you agree that rural properties should be prioritised for energy efficiency support? Please give reasons for your answer.

CIH Northern Ireland strongly agrees that rural properties should be prioritised for energy efficiency support. The challenges faced by rural households are well-documented, and our response to the Department for the Economy's consultation on support for low carbon heating in residential buildings further reinforces this point. Rural households often face a 'perfect storm' of factors that contribute to fuel poverty:

• Higher energy costs: Rural properties are frequently larger, older and less energy-efficient than urban homes. They are also more likely to rely on expensive off-grid fuels like oil and LPG, which are often subject to price volatility and lack the consumer protections afforded to mains gas customers. As we highlighted in our low-carbon heating consultation response, the lack of gas infrastructure in many rural areas means that switching to low-carbon heating solutions often involves significant upfront costs for technologies like heat pumps. 
• Limited access to services: Rural areas often have poorer access to energy efficiency advice, qualified installers and support programmes. The low-carbon heating consultation response emphasised the need for targeted outreach and support for rural communities, including information on available grants and incentives. 
• Higher upfront costs for low carbon technologies: As noted in our response to the Department for the Economy, the upfront costs of installing low-carbon heating systems can be particularly prohibitive for rural households, who may have lower average incomes and less access to financing options. This is compounded by the fact that many rural homes require significant fabric upgrades before low-carbon heating can be effectively installed.

Therefore, targeted and tailored support for rural households is crucial. This should include:

• Increased grant funding: Rural households should be eligible for higher levels of grant funding for energy efficiency and low carbon heating upgrades, recognising the higher costs involved.
• Dedicated advice services: Rural communities need access to dedicated advice services that understand their specific needs and can provide tailored guidance on energy efficiency and low-carbon heating options.
• Support for off-grid solutions: Support should be available for rural households to switch to more efficient and affordable off-grid heating systems, including exploring alternatives to oil and LPG.
• Community energy initiatives: Promoting and supporting community energy initiatives in rural areas can help overcome barriers to accessing renewable energy technologies.
• Fabric first approach: Given the prevalence of older, poorly insulated homes in rural areas, CIH Northern Ireland stresses the importance of a ‘fabric first’ approach in rural retrofit schemes.

By taking these specific actions, the fuel poverty strategy can effectively address the unique challenges faced by rural households and ensure that everyone has access to a warm and affordable home.

Alternative funding models

CIH Northern Ireland believes that a mix of funding mechanisms, including a sliding scale approach, targeted loans, carefully considered levies and the exploration of a social energy tariff, is necessary to effectively finance energy efficiency schemes and address fuel poverty.

QUESTION 16: Do you agree with a sliding scale approach to funding for home energy schemes?

CIH Northern Ireland agrees with a sliding scale approach to funding for home energy schemes. This approach, which tailors the level of financial assistance to the needs of individual households, offers several key benefits:

• Targeting resources: A sliding scale allows for targeting the most substantial support to those who are least able to afford energy efficiency improvements, namely low-income households and those with vulnerabilities. This ensures that public funds are used most effectively and that those in greatest need receive the help they require.
• Fairness and equity: A sliding scale recognises that different households have different financial capacities. It ensures that support is distributed fairly and equitably, considering individual circumstances.
• Incentivising action: A sliding scale can incentivise households to take action to improve their energy efficiency. Knowing that higher levels of support are available for those with lower incomes can encourage people to apply for schemes and make necessary upgrades.
• Maximising impact: By targeting resources strategically, a sliding scale approach can maximise the overall impact of energy efficiency schemes and contribute more effectively to reducing fuel poverty.

QUESTION 17: Do you agree that loans are the fairest financing option for landlords who are required to improve their assets? If not, what would you suggest as alternative funding options?

CIH Northern Ireland believes that loans can be a useful financing option for landlords required to improve their assets, but they are not necessarily the fairest or the only option. A balanced approach is needed.

• Loans: Loans can be a viable option for landlords who have the financial capacity to repay them. However, they may not be suitable for all landlords, particularly small-scale landlords, those who are highly geared or those with limited resources. Low-interest rates and flexible repayment terms are essential to make loans an attractive option.
• Grants: Grants should continue to be available for landlords, especially small-scale landlords and those who are improving properties occupied by low-income tenants. However, landlords should not be able to evict tenants from improved homes to readvertise the property for a higher rent. Tenants should receive adequate protections from evictions when private landlords receive public funding, or the wider potential issue of so-called ‘renovictions’, seen in parts of Britain and Ireland, could be prevented through prescribed, allowable reasons for tenancy termination. Grants and tenancy security are particularly important for ensuring that improvements are made in the private rented sector, and that sitting tenants, who often have little control over the energy efficiency of their homes, can benefit from the upgrades.
• Tax incentives: Tax incentives can also encourage landlords to invest in energy efficiency upgrades. For example, landlords could receive tax breaks for installing insulation, upgrading heating systems or fitting renewable energy technologies.
• Partnerships: Partnerships between landlords, relevant authorities and energy companies can facilitate access to funding and expertise. These partnerships can leverage resources and knowledge to deliver effective energy efficiency programmes.

A mix of these funding options is likely the most effective approach. The specific mix should be tailored to the circumstances of individual landlords, the fabric condition of the property, the types of improvements being made, and the profile of the household.

QUESTION 18: Do you agree that we should consider increasing levies from electricity bills to fund energy efficiency schemes for low-income households? Please give reasons for your answer.

CIH Northern Ireland believes that carefully considered levies on electricity bills could be a part of the funding mix for energy efficiency schemes for low-income households, but it is essential to proceed with caution and address potential concerns. Critically, alongside any consideration of increased levies, CIH Northern Ireland urges the exploration and implementation of a social energy tariff.

• Potential benefits: Levies can generate substantial revenue for energy efficiency schemes, providing a stable and dedicated source of funding.
• Potential concerns: There are concerns that levies could disproportionately impact low-income households, even if they are intended to benefit them. It is crucial to ensure that any levy is designed in a way that minimises the burden on those least able to pay. This could involve exemptions or reduced rates for low-income households.
• Social energy tariff: A social energy tariff, designed specifically for low-income and vulnerable households, would provide a direct and targeted way to reduce energy bills and help alleviate fuel poverty. This tariff should be set at a level that ensures affordability, allowing households to heat their homes adequately without facing undue financial hardship. The design and implementation of a social tariff should be carefully considered, considering good practice from other regions and ensuring that it is effectively targeted and administered. CIH Northern Ireland believes that exploring and implementing a social tariff should be a priority for the fuel poverty strategy.

QUESTION 19: Should we explore introducing levies on gas to increase funding for such energy efficiency measures? Please provide reasons for your answer.

CIH Northern Ireland believes that similar considerations apply to levies on gas bills as to electricity bills. While gas levies could generate additional revenue, it's crucial to assess the potential impact on low-income households and ensure that the levy is designed fairly. Given the transition to low-carbon heating, the long-term viability of gas levies as a funding source should also be carefully considered.

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

CIH Northern Ireland believes that a levy on heating oil has the potential to generate much-needed funds, but it's crucial to proceed with care. It's essential to analyse the potential impact of the levy on low-income households who are already struggling with high energy costs. The levy should be designed to minimise undue burden on them, perhaps through exemptions or reduced rates, while considering how to avoid exacerbating heating oil price fluctuations.

The interaction of decarbonisation policies and energy bill affordability

QUESTION 27: Do you agree that we should improve our understanding of the impacts of energy decisions on the energy bills of different consumer groups? If so, what would be the best way of understanding these impacts?

CIH Northern Ireland strongly agrees that a significantly improved understanding of the impacts of energy decisions on the energy bills of different consumer groups is essential for developing effective policies to tackle fuel poverty. Without this granular understanding, policies risk being poorly targeted, ineffective or even counterproductive.

Why improved understanding is crucial

• Targeted interventions: Different consumer groups have different energy needs, usage patterns and vulnerabilities. Understanding these differences is crucial for designing targeted interventions that address the specific challenges faced by each group. For example, rural households reliant on heating oil have different needs than urban households with gas central heating. Elderly residents living in poorly insulated homes have different needs than families with young children.
• Effective policy development: Robust data on the impact of energy decisions on different consumer groups is essential for developing evidence-based policies. Without this data, policies may be based on assumptions rather than realities, leading to unintended consequences.
• Measuring impact: Understanding the baseline impact of energy decisions on different consumer groups is crucial for measuring the effectiveness of energy efficiency programmes and other interventions. Without a baseline, it's impossible to determine whether policies are making a difference.
• Addressing inequities: Analysing the impact of energy decisions on different groups can reveal and address existing inequities in access to affordable energy. This can help ensure that policies are designed to protect the most vulnerable consumers.

Best ways of understanding these impacts

A multi-faceted approach is needed to gain a comprehensive understanding of the impacts of energy decisions:

• Detailed household surveys: Regular production of the House Condition Survey, capturing detailed information on energy usage, expenditure, demographics, dwelling characteristics and energy-related behaviours, are crucial. These surveys should be representative of the population and include sufficient sample sizes for different consumer groups.
• Smart meter data analysis: Smart meters provide granular data on energy consumption at the household level, offering invaluable insights into energy usage patterns and the impact of different energy decisions. CIH Northern Ireland believes that wider and more strategic use of smart meters is crucial for enhancing our understanding of these impacts. Analysing this data, while adhering to data privacy and ensuring robust data security, can provide detailed information on how different consumer groups use energy, the impact of energy efficiency measures, and the effectiveness of various tariffs. Linking smart meter data with other datasets (e.g. household demographics, dwelling characteristics) can further enhance the analysis, allowing for a truly granular understanding of energy usage and expenditure. We encourage the Department for Communities to work with energy suppliers and relevant stakeholders to promote the uptake of smart meters and ensure that the resulting data is used effectively for research and policy development. Smart meter data can be particularly useful in:
  
  • Evaluating the effectiveness of energy efficiency programmes
  • Identifying households in fuel poverty
  • Developing targeted support measures
  • Understanding the impact of different heating systems and technologies.
• Qualitative research: Quantitative data from surveys and smart meters should be complemented by qualitative research, such as focus groups and in-depth interviews. This can provide valuable context and insights into the lived experiences of different consumer groups and how they are affected by energy decisions. Qualitative research can also help identify barriers to accessing affordable energy and inform the design of more effective support programmes.
• Collaboration with energy suppliers and consumer organisations: Energy suppliers and consumer organisations have valuable data and insights into energy usage patterns and the challenges faced by different consumer groups. Collaboration with these bodies can enhance data collection and analysis efforts.
• Longitudinal studies: Tracking energy usage and expenditure over time is important for understanding the long-term impact of energy decisions and policies. This can help identify trends and inform the development of sustainable solutions.
• Data disaggregation: All data collected should be disaggregated by key demographic factors (e.g. income, age, location, disability, household size) to ensure that the analysis is sensitive to the needs of different consumer groups.

By combining these approaches, policymakers can gain a much deeper understanding of the complex relationship between energy decisions and energy bills, enabling them to develop more effective and equitable policies to address fuel poverty.

Ensuring redress and consumer protection

CIH Northern Ireland strongly believes that a common quality assurance standard or framework and a consistent approach to consumer protection are essential across all government-supported energy efficiency and low-carbon heat grant schemes. This is crucial for ensuring value for money, building consumer confidence and maximising the impact of these vital programmes.

QUESTION 32: What are your views on whether government should adopt a common quality assurance standard or framework across all energy efficiency and low carbon heat grant schemes?

CIH Northern Ireland unequivocally agrees that government must adopt a common quality assurance standard or framework across all energy efficiency and low-carbon heat grant schemes. The lack of a consistent approach currently creates several problems:

• Inconsistent quality: Without a common standard, the quality of installations can vary significantly, leading to poor performance, safety risks and wasted public funds. A common framework ensures that all installations meet a minimum standard, protecting consumers and maximising the effectiveness of the schemes.
• Confusion for consumers: Different standards and requirements across different schemes can be confusing for consumers, making it difficult for them to compare options and make informed decisions. A common framework simplifies the process and makes it easier for consumers to understand their rights and responsibilities.
• Difficult enforcement: Without a clear and consistent standard, it is difficult for regulators to monitor and enforce quality. A common framework facilitates enforcement and ensures that installers are held accountable for their work.
• Hindered market development: A fragmented approach can hinder the development of a robust and competitive market for energy efficiency and low-carbon heating products and services. A common standard creates a level playing field for installers and encourages innovation.

The framework should incorporate:

• Installer certification: All installers participating in government-supported schemes should be required to be certified by a recognised body, demonstrating their competence and adherence to best practices.
• Product standards: Minimum performance standards should be set for all products and materials used in energy efficiency and low-carbon heating installations.
• Installation standards: Clear and detailed installation standards should be established, covering all aspects of the installation process, from initial assessment to final commissioning. This could draw upon existing standards like PAS 2035 for retrofits.
• Inspection and monitoring: A system for independent inspection and monitoring of installations should be put in place to ensure compliance with the quality standards.
• Consumer feedback mechanisms: Consumers should have a clear and accessible route to provide feedback on their experience with installations, allowing for continuous improvement of the quality assurance framework.

QUESTION 33: Do you agree that government should take a common approach to consumer protection across all supported energy efficiency schemes?

CIH Northern Ireland strongly agrees that government must take a common approach to consumer protection across all supported energy efficiency schemes. Consumers investing in these measures, often with significant financial outlay, must be protected from:

• Mis-selling and misleading information: Consumers should receive accurate and unbiased advice on the suitability and performance of different energy efficiency and low-carbon heating technologies.
• Substandard workmanship: Installations should be carried out to a high standard by qualified and certified installers.
• Faulty products: Products should meet minimum performance and safety standards.
• Lack of after-sales support: Consumers should have access to clear information on warranties, maintenance requirements and dispute resolution procedures.

A common approach to consumer protection should include:

• Clear and accessible information: Consumers should be provided with clear and comprehensive information about their rights and responsibilities, including details of warranties, guarantees and complaint procedures.
• Robust complaint mechanisms: Consumers should have access to effective and timely mechanisms for resolving disputes with installers or suppliers.
• Independent advice services: Consumers should be able to access independent advice services to help them navigate the complexities of energy efficiency and low-carbon heating options.
• Enforcement: Effective enforcement mechanisms should be in place to ensure that installers and suppliers comply with consumer protection regulations.

By implementing a common quality assurance framework and a consistent approach to consumer protection, the government can build consumer confidence in energy efficiency and low-carbon heating schemes, encourage wider participation and ensure that these vital programmes deliver their intended benefits.

Fuel poverty definition: from singular to multiple

CIH Northern Ireland believes that a comprehensive and nuanced approach is essential for accurately measuring and understanding fuel poverty. This includes using a basket of indicators, carefully considering the specific indicators included, exploring an indicator related to energy confidence/agency/awareness, and recognising the distinct role of carbon emissions.

QUESTION 35: Do you agree that government should take a basket of indicators approach to measuring and understanding fuel poverty?

CIH Northern Ireland strongly agrees that government should adopt a basket of indicators approach to measuring and understanding fuel poverty. Relying on a single indicator, such as the low-income high costs (LIHC) measure, provides an incomplete picture of the complex realities of fuel poverty. A basket of indicators allows for a more comprehensive and nuanced understanding of the problem, capturing the multiple dimensions of fuel poverty.

However, while we agree that the basket is a good approach, one drawback is that it doesn’t give the strategy a firm target to measure progress against. We therefore support the NI fuel poverty coalition’s proposal that the strategy include primary and secondary indicators, a common approach in some European countries. This would mean there is limited headline and statutory metrics against which overall progress is measured, plus a suite of other indicators that can be used to understand the problem and inform any potential changes to regulations and scheme design.

QUESTION 36: Are the indicators suggested the correct ones? Please provide reasons for your answer.

CIH Northern Ireland supports the principle of a basket of indicators but believes the specific indicators should be carefully reviewed and may need refinement. While the suggested indicators likely include important factors like income, energy expenditure and dwelling characteristics, it's crucial to ensure that the basket:

• Captures the depth of fuel poverty: The indicators should reflect the lived experience of fuel poverty, including the ‘heat or eat’ dilemma, self-rationing of energy use and the impact on physical and mental health.
• Considers vulnerable groups: The basket should include indicators that are sensitive to the specific vulnerabilities of different groups, such as elderly residents, people with disabilities and families with young children.
• Addresses rural fuel poverty: Given the unique challenges faced by rural households, the basket should include indicators that capture the specific dimensions of rural fuel poverty, such as reliance on expensive off-grid fuels and limited access to energy efficiency services. This should include consideration of fuel costs for those not on mains gas.
• Is measurable and reliable: The chosen indicators must be measurable using reliable data sources. Data collection methods should be robust and consistent to ensure comparability over time and across different areas.
• Is regularly reviewed: The basket of indicators should be regularly reviewed and updated to reflect changes in energy markets, housing conditions and our understanding of fuel poverty.

QUESTION 37: If you agree with the introduction of an indicator based on energy confidence, agency or awareness, do you have suggestions about what kind of indicator might be most valuable?

CIH Northern Ireland agrees that incorporating an indicator related to energy confidence, agency or awareness could be valuable. This recognises that fuel poverty is not just about income and energy costs but also about people's ability to understand, manage and control their energy use. A valuable indicator could focus on:

• Knowledge of energy efficiency measures: Does the household understand what steps they can take to improve the energy efficiency of their home?
• Awareness of available support: Is the household aware of available grants, loans and advice services related to energy efficiency and fuel poverty?
• Confidence in managing energy bills: Does the household feel confident in their ability to understand their energy bills, switch suppliers and access the best tariffs?
• Agency to act: Does the household feel empowered to take action to improve their energy situation?

This could be measured through survey questions that assess knowledge, awareness, confidence and perceived control over energy use.

QUESTION 38: Do you agree with our proposal that carbon emissions are not used as a fuel poverty indicator? Please provide reasons for your answer.

CIH Northern Ireland agrees that carbon emissions should not be used as a direct fuel poverty indicator. While reducing carbon emissions is a crucial goal, linking it directly to fuel poverty measurement can be misleading and counterproductive.

• Conflating separate issues: Fuel poverty is primarily about affordability and access to adequate warmth. Carbon emissions are related to the source of energy used, not necessarily the amount of energy used or the ability to afford it. Conflating these distinct issues can obscure the drivers of fuel poverty.
• Potential for regressive impacts: Focusing on carbon emissions as a fuel poverty indicator could lead to policies that disproportionately burden low-income households who may have limited options for switching to low-carbon fuels. For example, policies that penalise the use of heating oil could exacerbate fuel poverty in rural areas.
• Focus on outcomes: Fuel poverty measurement should focus on outcomes, such as the ability to heat a home to a healthy temperature and avoid fuel debt. Carbon emissions are an input to the energy system, not a direct measure of well-being.

However, this does not mean that carbon emissions are irrelevant to the broader goal of tackling fuel poverty. Improving energy efficiency and promoting low-carbon heating are essential for both reducing fuel poverty and achieving climate change targets. These goals should be pursued through separate but complementary policies. A ‘fabric first’ approach, as previously emphasised, can contribute to both.

Governance, transparency and accountability

CIH Northern Ireland believes that continuous and meaningful engagement with people experiencing fuel poverty is essential for developing effective policies and support programmes. A fuel poverty advisory group, properly structured and empowered, can play a vital role in facilitating this engagement.

QUESTION 39: What is the best way to continue to engage with people experiencing fuel poverty?

CIH Northern Ireland believes that a multi-faceted approach is needed to effectively engage with people experiencing fuel poverty:

• Meaningful participation: Engagement should go beyond simply consulting people; it should involve meaningful participation in the design, implementation and evaluation of policies and programmes. This means ensuring that people with lived experience of fuel poverty have a real voice in shaping the solutions that affect them.
• Accessibility: Engagement methods should be accessible to all, considering different communication preferences, levels of digital literacy and potential barriers related to language, disability or caring responsibilities. This could involve a mix of online and offline methods, including community meetings, focus groups, surveys and one-on-one consultations.
• Trusted intermediaries: Working through trusted intermediaries, such as Supporting Communities and other community organisations, advice agencies and social housing providers, can be an effective way to reach people experiencing fuel poverty, particularly those who may be reluctant to engage directly with government.
• Feedback mechanisms: Clear and accessible feedback mechanisms should be in place to ensure that the views and experiences of people experiencing fuel poverty are heard and acted upon. This could involve regular reporting on how feedback has influenced policy decisions.
• Longitudinal engagement: Engagement should be an ongoing process, not a one-off event. Regular dialogue with people experiencing fuel poverty is essential for understanding how their needs and experiences change over time and for ensuring that policies remain relevant and effective.
• Recognition and remuneration: Recognising and, where appropriate, remunerating people for their time and expertise in contributing to engagement activities is important for ensuring their continued involvement and demonstrating the value of their input.

QUESTION 40: Do you agree with the proposal for a Fuel Poverty Advisory Group, if not, can you suggest an alternative proposal?

CIH Northern Ireland agrees with the proposal for a fuel poverty advisory group. Such a group, if properly constituted and empowered, can play a crucial role in:

• Providing expert advice: The group can provide expert advice to government on the causes of fuel poverty, the effectiveness of existing policies, and the development of new solutions.
• Championing the needs of fuel-poor households: The group can act as a champion for the needs of people experiencing fuel poverty, ensuring that their voices are heard, and their concerns are addressed.
• Facilitating collaboration: The group can facilitate collaboration between government departments, energy suppliers, consumer organisations and other stakeholders involved in tackling fuel poverty.
• Monitoring progress: The group can monitor progress towards achieving fuel poverty targets and hold government accountable for its performance.

To ensure the fuel poverty advisory group is effective, it is essential that:

• It includes representatives from a wide range of organisations and individuals with expertise in fuel poverty, including people with lived experience of fuel poverty. Meaningful representation of those with lived experience is critical.
• It has clear terms of reference and a defined role. Its remit should include providing advice on policy development, monitoring progress and promoting public awareness of fuel poverty.
• It is independent and has the support it needs to operate effectively.

CIH Northern Ireland believes that a well-structured fuel poverty advisory group is an important component of a comprehensive strategy to address fuel poverty in Northern Ireland.

Visit the Department for Communities' website for more information on the consultation.

For more information on our response contact Justin Cartwright CIHCM, national director CIH Northern Ireland, on justin.cartwright@cih.org.