CIH NI summary of Department for Communities consultation on a new fuel poverty strategy for Northern Ireland

Raising housing standards

The consultation proposes introducing a new Decent Homes Standard for social housing by 2026. This standard is noted as underdevelopment by the DfC. Their focus in this consultation is on Criterion D, whereby a home should ‘provide a reasonable degree of thermal comfort’. They suggest that this is a subjective measure, and ask:

Q3: What would a readily understandable and measurable definition of ‘thermal comfort look like?

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

Private rented (PRS) dwellings were more likely to be in fuel poverty in the DfC’s last stock condition survey, with common issues noted around damp, mould, and low indoor temperatures. DfC has enabling legislation to introduce these standards in the PRS. Landlords would be required to comply with new MEES standards within this strategy period, with the exact date subject to consultation. They ask:

Q4: 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?

Q5: Should MEES also be applied to other tenures? Please give reasons for your answer.

Implementing improved Fitness Standards for all tenures by 2030

The Fitness Standard is a basic standard for human habitation, but it has not been significantly updated since 1981, and it is noted that it therefore lags behind other jurisdictions. They therefore want to update Fitness Standard by 2030, and note that the standard particularly requires updating around minimum standards for thermal comfort and adequate heating. They ask:

Q6: Do you agree that introducing updated fitness standards will contribute to making homes more energy efficient? Please provide reasons for your answer.

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

A new energy efficiency scheme is proposed to replace the Affordable Warmth Scheme, introduced in 2014 and due to conclude in March 2026. The new scheme is proposed to be more ambitious, long-term in nature, flexible, and transparent. They also discuss reviewing the eligibility criteria to take more account of levels of disposable income, not household income. This is partly because household income does not go as far in larger households, or households with disabilities. They ask:

Q7: Do you agree that all government domestic energy schemes should take account of the Fuel Poverty Strategy principles?

Q8: 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?

Q10: 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.

Measures included in the new scheme

This section of the consultation discusses the measures that could be included in a new scheme, discussing the benefits of installing efficient heating, insulation, low-carbon technologies (e.g. solar PV, batteries), and other efficiency measures (e.g. glazing). It is noted that the previous programme comprised individual measures, and applicants could choose which measures to install even if they were not the most suitable for each individual household. The consultation therefore proposes replicating the ‘whole house’ approach used in other nations.

The consultation also discusses the importance of low-carbon heating and electrical technologies to meet climate change obligations, focusing on heat pumps and the replacement of fossil fuel boilers. It also discusses rural fuel poverty and the reliance of often poor-quality homes in rural areas in Northern Ireland on oil. They ask:

Q11: Do you agree that the new scheme should take a Whole House retrofit approach? Please give reasons for your answer

Q12: 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

Q13: Do you agree that the new scheme should prioritise low carbon heating solutions where possible?

Q14: 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.

Q15: Do you agree that rural properties should be prioritised for energy efficiency support? Please give reasons for your answer.

Alternative funding models

The consultation recognises that the scale of energy efficiency investment to meet new targets will be considerable, and asks for views on additional financing options could be leveraged and brought to the table. This includes private investment from landlords and homeowners, accompanied by a sliding scale approach whereby those with greatest need receive the most support while those more able to pay contribute in line with their circumstances. They ask:

Q16: Do you agree with a sliding scale approach to funding for home energy schemes?

Q17: 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?

Q18: 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.

Q19: Should we explore introducing levies on gas to increase funding for such energy efficiency measures? Please provide reasons for your answer.

Q20: What are your thoughts on exploring any revenue-raising opportunities for energy efficiency schemes from unregulated heating sources such as home heating oil?

The interaction of decarbonisation policies and energy bill affordability

Decarbonising homes is necessary to meet climate change obligations, but it is recognised that achieving a Just Transition in Northern Ireland requires decarbonisation to be fair. The costs, benefits, and trade-offs of action are complex, including how energy efficiency schemes are paid for (i.e. through bills). Costs and benefits also fall differently on different consumer groups (e.g. households with disabilities or long-term illnesses). They ask:

Q27: 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?

Ensuring redress and consumer protection

The consultation recognises that protections are already in place for consumers in Northern Ireland, but some areas could be strengthened, particularly in oil and LPG markets, for prepayment meter users, and those with different vulnerabilities. They therefore want to ensure that: a) trusted advice is available to all, b) people have confidence in the measures they are installing in their home, c) installations are quality and carried out by skilled installers, and d) there is a simple redress process for when things go wrong. They ask:

Q32: 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?

Q33: Do you agree that government should take a common approach to consumer protection across all supported energy efficiency schemes?

Fuel poverty definition: from singular to multiple

Notably, the consultation proposes moving away from having a singular and headline fuel poverty indicator, to a ‘basket’ approach that includes multiple indicators. Their proposed basket includes:

• The current 10 per cent indicator, before and after housing costs
• A subjective measure of people’s ability to pay regular bills without cutting back on other essentials
• Household energy expenditure relative to all expenditure
• Presence of damp
• Whether the home can be kept adequately warm in cold weather
• Excess winter mortality
• Annual modelling of figures for both extreme and severe fuel poverty.
• SAP and income data
• Impact of different drivers on fuel poverty (i.e. income, fuel prices, home efficiency)
• People’s awareness and confidence in being able to address their own energy issues.

They ask:

Q35: Do you agree that government should take a basket of indicators approach to measuring and understanding fuel poverty?

Q36: Are the indicators suggested the correct ones? Please provide reasons for your answer

Q37: 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?

Q38: Do you agree with our proposal that carbon emissions are not used as a fuel poverty indicator? Please provide reasons for your answer

Governance, transparency, and accountability

They propose continued engagement with fuel poor households and the establishment of a Fuel Poverty Advisory Group to ensure they can receive independent scrutiny and challenge from households and stakeholders. They ask:

Q39: What is the best way to continue to engage with people experiencing fuel poverty?

Q40: Do you agree with the proposal for a Fuel Poverty Advisory Group, if not, can you suggest an alternative proposal?

Visit DfCs website for more information about the consultation.

The consultation closes on 23.59 on Thursday 6 March 2025. The contact for responding is: FuelPovertyStrategy@communities-ni.gov.uk