CIH response to DESNZ review of the Fuel Poverty Strategy

1. Should the 2030 fuel poverty target be retained? Please explain your reasoning. 

Yes, we believe the fuel poverty target should be retained.

We recognise the trade-offs inherent to retaining the target and agree that it will be challenging to meet given the lack of progress that has been made over the last few years. However, we ultimately agree with the reasoning in the consultation document, that retaining the target would ensure that a consistent focus on upgrading the energy efficiency of households on the lowest incomes in this parliament is maintained. We would also be concerned that delaying the target would send an unwelcome signal that fuel poverty is not a priority of the new government in its first parliamentary term, and leave open the possibility that investment associated with the Warm Homes Plan – which is desperately needed – is redirected elsewhere.

4a. What are your views on retaining the Low Income Low Energy Efficiency metric as a measure of structural fuel poverty and as the official measure of progress to the statutory fuel poverty target in England?

Despite its drawbacks, we agree with the principle of retaining the Low Income Low Energy Efficiency (LILEE) metric as both a measure of structural fuel poverty and as the official measure of progress towards the statutory fuel poverty target. 

However, we agree that the exact form the target should take should be dependent on the government’s eventual decision on new Energy Performance Certificate (EPC) metrics, set out in its consultation on reforms to the Energy Performance of Buildings regime. The current LILEE metric is based on the headline energy costs metric (or EER), and the metric used to measure fuel poverty should ideally be based on energy costs. This is because it is the metric that corresponds most closely to fuel poverty. However, we could envisage a situation where the approach taken to Minimum Energy Efficiency Standards, focusing on a primary fabric metric and a choice of secondary metric, would be appropriate for a fuel poverty definition if a low-income component was included. 

4b. What are your views on whether to adopt an additional indicator to monitor the impact of energy prices on the affordability of energy?

We strongly agree that an additional indicator should be adopted to monitor the impact of energy prices on the affordability of energy. 

4c. What are your views on the form of an energy affordability indicator, including whether this should include an income constraint and considerations on the basis on which to determine unaffordable energy requirements? Please provide any supporting evidence.

We think the definition used in Scotland could be a suitable basis for the form of energy affordability indicator that should be adopted in England.

A summary of Scottish legislation describes a fuel poor household as one where: 

• More than 10 per cent (20 per cent for extreme fuel poverty) of net income is required to pay for their reasonable fuel needs after housing costs have been deducted.
• The remaining household income is not enough to maintain an acceptable standard of living, defined as at least 90 per cent of the UK Minimum Income Standard (MIS) once childcare costs and disability or care benefits are deducted.[i]

We think this approach and its associated legislative definition[ii] offers advantages, specifically:

• It acknowledges that other essential costs, especially childcare costs and disability or care benefits, affect the ability of a household to access affordable warmth, not just housing costs. It also acknowledges that groups with these other costs are more likely to have extended periods in the home, which requires higher energy use and costs.
• It is based on a robust, independent definition of what constitutes an acceptable standard of living, based on the UK Minimum Income Standard established by the University of Loughborough.[iii]
• It includes a measure of ‘extreme’ fuel poverty, which we think would be valuable to adopt in England as a measure of extreme energy unaffordability, in addition to an indicator based on 10 per cent of income.

We would also encourage the government to look closely at the recently proposed ‘basket’ or scorecard indicator approach in Northern Ireland’s fuel poverty strategy consultation.[iv] We agree with the justification for adopting a basket approach in Northern Ireland, specifically that:

• “Indicators help us to understand the persistence of a problem, identify trends, make comparisons with other countries, identify the people affected by the problem and design and deliver policy. However, no single indicator can fulfil all these roles, and such statistics do not necessarily tell us about the outcomes of being fuel poor. This becomes more important if we want to prioritise better health by focusing on those most likely to be adversely impacted by living in a cold, damp home.”[v]

Importantly, and as the Northern Ireland consultation recognises, this is primarily about making better use of existing data collected from a range of sources to enable a more person-centric, nuanced understanding of fuel poverty and its impacts. In England, it could include a range of other indicators collected through the English Housing Survey, ONS Living Costs and Food Survey, ONS excess mortality statistics, and the Understanding Society survey, such as:

• Damp and mould prevalence
• Overall decency (measured by the Decent Homes Standard)
• Estimated excess winter mortality attributable to fuel poverty
• Weekly or monthly household expenditure on electricity, gas and other fuels

Doing this would also bring England more in line with European countries that have long benefited from multi-indicator approaches to fuel poverty.[vi] The advantage of these approaches it also that they enable connections to be made between fuel poverty policy and wider health, housing, and welfare concerns, and how they can be addressed holistically across government.

5. What are your views on adapting or implementing the Worst First principle, in order to maximise the number of fuel poor homes brought to Band C while ensuring that the worst homes are not left behind? Please provide any supporting evidence.  

We agree that ‘worst first’ should be carried forward as a core principle of the fuel poverty strategy.

6. What are your views on how we could better define or implement the cost effectiveness principle? Please provide any supporting evidence. 

We agree that cost-effectiveness should be carried forward as a core principle of the fuel poverty strategy.

Our only comment is that the cost-effectiveness principle should consider wider co-benefits for society and the economy. For example, in 2023, the Building Research Establishment demonstrated that tackling cold homes would save the NHS £540 million per year.[vii] There are as-yet unquantified but clear links between fuel poverty and poorer educational outcomes, which harms the economy and society in different ways (see our response to Question 18). Energy unaffordability has extensive knock-on financial impacts for the social housing sector, causing costly repairs and maintenance issues such as frozen or burst piping, and driving the accumulation of rent arrears.[viii] There is also now robust evidence that improving the energy efficiency of lower-income homes boosts local economic growth, as energy bill savings are spent on local high streets.[ix] While more exact analysis is required, the evidence to date is sufficient to show that tackling fuel poverty will lead to savings across other areas of the economy and society. We would like to see these savings acknowledged as a central part of the cost-effectiveness principle, as well as in the design of a plan to improve the energy performance of fuel poor homes and the principles of energy bill support.

7. What are your views on how we could better define or implement the vulnerability principle? Please provide any supporting evidence.

Responses could include views on:

• How to better incorporate consideration of health inequalities and vulnerabilities into fuel poverty policies
• How to better target fuel poor households who are vulnerable
• How to better track the rates and impacts of fuel poverty on households with specific vulnerabilities

We agree that vulnerability should be carried forward as a core principle of the fuel poverty strategy.

There are opportunities for targeting fuel poor and vulnerable households that stem from the Regulator of Social Housing’s new proactive regulatory regime and consumer standards in social housing.

Specifically, social landlords are now required to “understand the diverse needs of tenants, including those arising from protected characteristics, language barriers, and additional support needs” and “assess whether all tenants have fair access to, and equitable outcomes of, housing and landlord services.”[x] In the accompanying Code of Practice, the Regulator of Social Housing states:

• “Registered providers are expected to have robust information about their tenants so that they can deliver fair and equitable outcomes for tenants in relation to the housing and landlord services they provide. This should include, but not be limited to, relevant information on protected characteristics, and any support or communication needs. It is for registered providers to work with tenants to decide the most effective approach to gathering this information and keeping it up to date, and to share with tenants how they will make use of the data. Registered providers should explore a range of methods for collecting this information from tenants to encourage a good response rate.”[xi]

In response to this guidance, individual social landlords are beginning to collect the required information about their residents. At a sector level, the National Housing Federation is leading a project entitled Knowing our Homes,[xii] which aims to produce a standardised way of collecting and using this information across all social landlords. Although this will take time, a likely outcome of the new consumer standards will be that social landlords will acquire a large amount of information about the support and communication needs of their residents. It may be possible, working with the Regulator of Social Housing and the wider sector, to explore how this information could be used (with permission of the resident) to better target fuel poverty support at vulnerable households. This might be administratively challenging for social landlords and the sector, but if the incentive was providing vital energy bill support for their vulnerable residents, these challenges could be overcome and provide vital assistance.

With regards to the role of healthcare systems and health inequalities in fuel poverty policy, we agree with the detailed evidence submitted to the consultation by National Energy Action and the Centre for Sustainable Energy on this topic. Health and housing partnerships offer significant opportunities for targeting support and should be leveraged to provide fuel poverty support wherever possible.[xiii]

8. What are your views on how we could better define or implement the sustainability principle? Please provide any supporting evidence.

Responses could include views on:  

• How the transition to net zero can be best implemented for fuel poor households
• The role of fabric first in alleviating fuel poverty
• The role of fossil fuels within government schemes addressing fuel poverty
• How smart technologies could be used to support fuel poor homes
• How home retrofit can support climate change adaptation

How the transition to net zero can be best implemented for fuel poor households

It is essential that the transition to net zero is fair and equitable. CIH strongly believes that net zero is an unmissable opportunity to eliminate fuel poverty and ensure everyone can live in a warm, safe home. To do this, we feel the following steps are necessary.

To the greatest extent possible, the new fuel poverty strategy should commit to fully funding the transition to low-carbon heating for fuel poor households, simply because the cost of heat pumps and other low-carbon heating technologies is typically unaffordable for them. Research undertaken by Energy Systems Catapult as part of the Electrification of Heat trials reported a total cost per property of £14,800 including the heat pump unit, additional measures (e.g. thermal storage) and installation.[xiv] When additional measures were excluded, the average cost of a low temperature air source heat pump installed through the project was £9,000, but with a minimum cost of £5,300 and a maximum cost of £19,600 – the latter over £10,000 above the average. A wide range of costs is also reported in another study by the UK Energy Research Centre (UKERC),[xv] and research by E3G has highlighted the higher upfront costs for retrofitting larger, leakier, detached properties in rural areas with a heat pump.[xvi]

For fuel poor households, these costs are unaffordable, and will continue to be even if government policies such as the Clean Heat Market Mechanism reduce the cost of heat pumps. This is not just because of their low household incomes, but because of the likelihood of them not having sufficient savings to afford the upfront capital costs of low-carbon heating technologies. Data from the English Housing Survey does not disaggregate savings by income or fuel poverty status, but it shows only 27 per cent of owner occupiers have savings of £16,000 or more.[xvii] Even when savings are present in lower-income households, research suggests it occurs for typically short-term purchases or anticipated expenses, or to provide a financial safety net, not for planned forms of high capital expenditure.[xviii] Academic research has also shown that the interlinked cost of living and energy crises have led to lower levels of financial resilience among lower-income households, partly because paying for essentials during these crises has drained the small quantity of savings they have.[xix] In this context, it is plainly untenable for fuel poor households to afford the transition to net zero without financial support. If these households are not to be left behind, government needs to commit to fully funding the transition for fuel poor households; this needs to encompass the upfront costs of low-carbon heating technologies (including heat network connections as well as heat pumps), and any ancillary costs, such as upgrading pipework, installing new radiators, and fitting hot water tanks.

The new fuel poverty strategy should commit to providing sufficient funds to ensure the social housing sector can meet net zero. Analysis by Savills has shown that the total estimated cost of decarbonising the local authority housing sector (including ALMOs) is £25 billion to 2050.[xx] Similar analysis undertaken by Savills for the National Housing Federation estimates that £36 billion is required to decarbonise housing association homes.[xxi] This level of investment is required on top of the significant investment already being made into energy efficiency and net zero by the sector; the Regulator of Social Housing (RSH) emphasised in its most recent assessment of sector finances that sector “financial results demonstrate significant levels of investment in the quality, safety and energy efficiency of existing stock.”[xxii] However, more generally, the RSH also found that sector finances are experiencing multiple pressures associated with soaring repairs and maintenance spend, building safety costs, the cost of building new homes, and low levels of interest cover.[xxiii]

Research we have undertaken with our members demonstrates the cost of the transition on an individual provider level. For example, one housing association that has undertaken detailed stock modelling and archetype analysis estimates that the cost of meeting net zero will be between £30,000 and £45,000 per home. The average cost per home is £40,000, with an estimated total cost of £1.6 billion to decarbonise all of their c. 50,000 homes, or £64 million per annum to 2050. A second housing association, with a high proportion of hard-to-treat homes, estimates that the cost of decarbonising some of their homes will be well in excess of £70,000, especially if wall insulation is required to reduce the running costs of heat pumps to a level that is affordable for low-income and fuel poor tenants.[xxiv] Given the financial pressures on the sector, this level of investment is unrealistic for providers and cannot be met through rents alone. In addition, we are aware that some social housing providers are beginning to be challenged by the RSH about the cost of net zero in their business plans (where it is included in business plans).

We therefore need to see the principle of fully funding low-carbon heating systems in social housing, inaugurated in the Warm Homes: Social Housing Fund, continued and expanded.

Reducing the running costs of electricity and heat networks is essential to facilitating the transition for fuel poor households, and should be a central pillar of the sustainability principle. This will be essential for making low-carbon heating affordable for fuel poor households. The challenges associated with the high price of electricity relative to gas are well-established, and we will leave other organisations to evidence this point more fully in their responses.[xxv]

We would add two specific points on this theme. Firstly, our research has shown that many social housing providers are reluctant to install heat pumps in their homes until the price of electricity reduces significantly.[xxvi] Some providers have undertaken detailed modelling of the running costs of heat pumps for their residents, and have included key variables such as coefficients of performance (COP), external temperature, and the energy efficiency of the home. Many are concerned that installing heat pumps without optimising the internal piping/radiators of the home and reducing its energy demand will increase fuel bills. As regulated organisations with a social purpose, and with many residents on low incomes, some providers we have spoken to have affirmed that the price of electricity must reduce before heat pumps become a viable solution for their residents. Put differently, the relatively high price of electricity is holding back the transition to heat pumps in social housing, a sector that is generally expected to lead the way in the installation of low-carbon heating between now and 2030.

Secondly, we have concerns about the affordability of heat networks for low-income households. Most domestic heat networks have never been subject to prior regulation, and the absence of price protection has often led to energy price shocks being passed quickly to bills and service charges. For example, one study reported that some heat network customers experienced price increases of 700 per cent during the energy crisis, with increases impacting the worst-off particularly hard.[xxvii] For social housing residents, with higher levels of financial vulnerability, ill-health, and disability than those in other tenures, these price increases were and continue to be especially detrimental.[xxviii] We therefore wholly welcome the action taken by DESNZ and Ofgem to regulate the heat network sector.[xxix]

However, there are specific challenges in the following areas:

• We have an ongoing concern, cited in a report released by the Public Accounts Committee on heat decarbonisation, that connecting low-income and vulnerable households to heat networks could increase running costs compared to the gas systems they replace, irrespective of the low-carbon counterfactual.[xxx] The previous government’s consultation on heat network zoning set out a possible conditional exemption for connection in situations where the demographics of residents mean a risk of significant increase in fuel poverty, and no mitigations are available. However, this would be tantamount to these households being left behind by the transition. Affirmative, positive action is needed to ensure fuel poor households can benefit from heat network zoning policy.
• In relation to DESNZ and Ofgem’s most recent consultation on implementing heat network consumer protection, government is minded to introduce a fair pricing framework instead of a price cap for the heat network sector. We have some reservations about the suitability of this framework to protect households from fuel poverty.[xxxi] ‘Affordability’ is a key plank of the framework, but it does not necessarily correspond to the parallel desired outcome that households ‘pay a reasonable and fair price’. A price that is fair and reasonable is not necessarily affordable for households in or at-risk of fuel poverty, or who have additional health-related needs for heat, such as households with terminal illnesses or young children in the home. Even a price that is the lowest possible a heat network can offer while remaining viable may be unaffordable for some households, especially once the full costs of complying with regulation have been passed through to consumers by heat network suppliers.
• Generally, households connected to heat networks have found it difficult to benefit from fuel poverty support schemes, as evidenced by the challenges in passing on energy crisis bill support to recipients through the Energy Bills Discount Scheme.[xxxii]

In summary, we feel more attention is needed by DESNZ to reducing the running costs of electricity to make the transition to net zero affordable for fuel poor households, and to making the heating and hot water costs associated with heat network transitions affordable for fuel poor households.

There are also a range of other barriers fuel poor households will experience before they can access and use a heat pump in a way that meets their heating needs; we agree with and endorse National Energy Action’s response to Question 8 on this topic.

Tailored, personalised advice and support will be even more critical to making the transition to net zero work for fuel poor households, and should be more centrally embedded in the sustainability principle. We have set out elsewhere in this response the importance of including sufficient funding for advice and support services in fuel poverty support schemes (see Question 11).

Evidence from previous evaluations of fuel poverty schemes demonstrates how important this is for the transition to net zero. In DESNZ’s prior evaluation of the Social Housing Decarbonisation Fund demonstrator, it was found that “confidence in using new measures tended to be positively influenced by receiving clear information and a demonstration or explanation for how measures worked.” This was especially the case for heat pumps, which one beneficiary described as “unbelievably overwhelming […] you need to be a rocket scientist to understand it.”[xxxiii] Similarly, in an evaluation of the Warm Homes Fund, a fuel poverty programme funded by National Grid, “the most common negative experience raised by interviewees was a lack of adequate advice about how to effectively use and operate their new heating system.”[xxxiv] Again, this was a particular issue when the new heating system was a heat pump, with beneficiaries sometimes not offered appropriate advice about suitable tariffs, or about how low-temperature heating systems actually work. Across both evaluations, beneficiaries also experienced challenges with understanding complex instruction manuals and using their new heating controls.

For many fuel poor households, what is required to mitigate these challenges is tailored, personalised, energy advice. This needs to be provided by someone who understands not just the low-carbon technology, but also fuel poor households and their heating needs, how they live in their home, and their possible concerns about affordability. Although both evaluations cited in the prior paragraph highlighted challenges, they also identified instances of good practice, such as resident liaison officers at local authorities and housing associations rewriting complex manufacturer’s instructions to make them more accessible for beneficiary households. We are aware of housing providers that will pay multiple visits to a household after the installation of a heat pump (e.g. one week after installation, four weeks after installation, immediately before the heating season begins) to check the system is working correctly and is meeting the needs of the resident. Mainstreaming and standardising these forms of good practice need to be central to any strategy to install heat pumps in fuel poor homes.

As in our response to Question 11, detailed advice and support before, throughout, and after the heat pump installation journey needs to be seen as critical to the success of the net zero transition for fuel poor households. Without it, fuel poor households are less likely to benefit from the advantages of low-carbon heating.

The role of fabric first in alleviating fuel poverty

We think the approach taken by government to Minimum Energy Efficiency Standards, which uses fabric as the primary metric, is generally the correct one for addressing fuel poverty, and should be reflected in the fuel poverty strategy. We also agree with the action taken by government to strengthen standards as part of the Warm Homes Plan.

In our research with social housing providers on their decarbonisation strategies, we found a clear prioritisation of demand reduction measures across housing associations and local authorities between now and 2030.[xxxv] This is due to a combination of carbon reduction, sustainability, and fuel poverty imperatives, driven in part by previous government strategies (e.g. the 2017 Clean Growth Strategy, the 2021 fuel poverty strategy and its associated statutory targets), national emissions reduction targets, and the anticipation of forthcoming Minimum Energy Efficiency Standards regulations. Providers are increasingly focusing on low-cost measures such as topping up loft insulation and upgrading lighting, windows, and doors as part of cyclical works to move homes from EPC Band D to EPC Band C by 2030. No providers who took part in our research were planning to install low-carbon heating at significant scale before 2030 in existing homes, with most looking towards 2035 as the most realistic year to begin fitting low-carbon heating systems across their stock. (A case study of a typical net zero pathway for a social landlord is provided below in Box 1). Based on engagements with our members, we feel that this approach – prioritising demand reduction measures to reduce fuel bills immediately while also enabling the subsequent installation of affordable low-carbon heating – is the best approach for the fuel poverty strategy to take.

How home retrofit can support climate change adaptation

This is a vital question, and we are pleased to see the consultation document considering the importance of retrofit for climate adaptation.

CIH strongly feels that retrofit programmes need to include climate resilience and adaptation measures, and the fuel poverty strategy should commit to exploring how this can be achieved. This has been recommended previously. For example, in its landmark 2019 report on the future of UK housing, the Committee on Climate Change included as a priority recommendation that the UK’s 29 million homes needed to be made low-carbon, low-energy, and resilient to a changing climate.[xxxvi] However, retrofit programmes have not focused on meaningful climate resilience measures for homes, such as shutters, ventilation, tree planting, and reflective paint to prevent overheating, or reinforced doors, self-closing airbricks, or sustainable drainage systems to reduce flood risks. A very significant barrier to the inclusion of these measures is the role of the Standard Assessment Procedure (SAP) (and in future, the Home Energy Model) in determining eligibility criteria for retrofit programmes. SAP does not recognise any of these measures, and SAP’s fundamental role in providing the underpinning architecture for eligibility and targeting in government retrofit programmes automatically leads to the omission of climate resilience measures from those programmes.

In previous years, it might have been possible to argue that this was of secondary importance to installing low-carbon heating and insulation measures, but the extent of the planet’s warming and our growing understanding of its impact on health and housing means we now need to place climate adaptation on an equal footing to other retrofit priorities. While climate projections carry an inherent degree of uncertainty, the likelihood of limiting warming to 1.5°C, as per the Paris Agreement, is becoming vanishingly small. According to the UN Environment Programme, there remains a large possibility that eventual global warming will exceed 2°C or even 3°C,[xxxvii] a possibility that some climate scientists now believe to be inevitable.[xxxviii] At the most pessimistic end of the different global warming scenarios, the extreme climate events we currently think of as rare (such as heatwaves and flood events) will inexorably become the norm.[xxxix] 

This will lead to greater risks to our homes. Academic research has shown that even now, up to four fifths of UK households report their homes overheating in hot weather, an increase from just one fifth in 2011.[xl] There is significant evidence that overheating exacerbates risks to health and wellbeing, especially for very young and older people, when indoor temperatures exceed 25°C.[xli] If temperatures continue to rise, overheating in buildings could, according to the Chartered Institution of Building Services Engineers (CIBSE), cause 4,500 premature deaths per year by 2050,[xlii] especially among vulnerable groups such as older and disabled people. Beyond heat, approximately 6.3 million UK homes are at risk of flooding, a number that will rise to 8 million in 2050 on current climate trajectories.[xliii] Evidence from the Environment Agency shows that one third of people who experience a flood event develop depression, anxiety, and/or post-traumatic stress disorder (PTSD).[xliv] Wind and driven rain will also increasingly affect homes across the western and southern coastlines of the UK, making them more vulnerable to rapid heat loss and serious fabric problems.[xlv]

We firmly believe that these issues are a fuel poverty problem, not just a climate or housing problem. This is because academic research has demonstrated that lower-income households often face an increased risk of experiencing harm or detriment during extreme climate events because of their relative inability to access domestic energy services.[xlvi] Specifically, mitigation strategies within the home are often reliant on access to electricity (e.g. for mechanical ventilation in heatwaves) and capital measures such as reinforced flood doors or insulation (which can be difficult for fuel poor households to afford and/or access). In addition, some mitigation strategies necessitate spending an increased proportion of the day or week at home (e.g. during flood events or severe storms), which increases the need for essential energy usage to fulfil basic household needs. This was starkly illustrated during the Covid-19 pandemic when households were placed into lockdown over the winter of 2020/21, with the Institute of Health Equity noting that “‘lockdown’ restrictions confining people to their homes” contributed to rapid rises in fuel poverty from 2020.[xlvii] There are therefore considerable overlaps between fuel poverty – especially if defined as the inability to afford domestic energy services such as electricity - and susceptibility to the harms associated with extreme climate events.

In addition, there are other questions we need to tackle on the links between retrofit and climate resilience. PAS2035 is the official standard for whole-house retrofit, and specifies how retrofit projects should be managed and delivered. Compliance with it is rightly a requirement of all current government funded retrofit schemes. PAS2035 covers climate risks, especially overheating, in several places. The Retrofit Assessor role is required to consider “additional information that might have an impact on the retrofit project now and in the future”, including “climate change-induced environmental risks, such as increased flooding, extreme weather conditions, overheating and increased relative humidity.”[xlviii] Retrofit designs are meant to include measures to prevent overheating, in accordance with several allied documents, especially the methodology for the assessment of overheating risk in homes, published by the Chartered Institute of Building Services Engineers (CIBSE).[xlix] A list of measures, such as means of reducing internal heat loads and limiting solar gain, is also included, as is a stipulation to provide advice to the occupant about potential overheating risk.

In theory, PAS2035 is a comprehensive guide to minimising unintended climate risks during retrofit design and delivery.[l] In practice, there is no evidence of whether homes retrofitted in compliance with it are sufficiently resilient to extreme climate events, especially those associated with warming scenarios of 2°C or higher. Furthermore, as TrustMark have suggested, “the percentage of work currently undertaken under PAS2035 relates predominately to the funded schemes and is a small percentage of all the work carried out in properties across the UK to improve energy efficiency, reduce carbon emissions and reduce energy bills.”[li] This is because outside of government funded schemes, there is no requirement to consider climate resilience in retrofit to the extent that PAS2035 does. Furthermore, CIH have received feedback from our members that the twin priorities of retaining heat in winter and cooling in summer can be hard to balance in retrofit work, and that focusing on heat demand can inadvertently exacerbate overheating issues in some homes that receive energy efficiency upgrades.

To be clear, CIH does not at present have conclusive answers to some of these problems, and we include them here in the in the spirit of working collaboratively to further understand the issues and potential solutions.[lii] For the purposes of the fuel poverty strategy, we think the following actions are worthy of consideration if we are to use home retrofit to support climate change adaptation:

• Reviewing or ‘stress testing’ the effectiveness of PAS2035 sufficiently to protect fuel poor homes undergoing retrofit from the climate risks associated with global warming scenarios of 2°C or higher.
• Examining how to collect reliable data on the links between climate risk and fuel poverty. For example, the English Housing Survey currently collects subjective data on overheating, but does not consider the relationship between overheating variables and fuel poverty.
• Considering options for how to include climate resilience measures in retrofit programmes in the future. This could involve:
  • For the rented sectors, incorporating climate resilience into an updated Decent Homes Standard (DHS), potentially via the creation of a ‘Criterion E’. This new criterion would stipulate that a home cannot be defined as decent unless a) it has a ‘climate resilience audit’ carried out, and b) it has been subsequently upgraded with all recommended measures to meet a reasonable definition of being climate resilient. Linking this new DHS to a suitable funding stream, perhaps provided through a new Decent Homes Programme that consolidates and simplifies existing funding streams for retrofit, building safety, and housing quality, could enable social housing providers to deliver climate adaptation measures from 2030.[liii]
  • For all sectors, amending the Energy Performance of Buildings regime to include a climate resilience metric on Energy Performance Certificates (EPCs). This could allow climate resilience measures without any current relationship to SAP/HEM to be eligible for future retrofit programmes.[liv]
  • Introducing innovation funds as part of future retrofit programmes (e.g. a future Wave 4 of the Warm Homes: Social Housing Fund) to trial the installation of climate resilience measures alongside wider energy efficiency and low-carbon heating measures. This would enable us to gather real-world evidence of the practicalities of integrating climate resilience measures into retrofit programmes, especially if accompanied by robust, independent evaluation, and understand the readiness of the supply chain to meet demand for climate resilience measures.

Lastly, we would make a final point about the continuing importance of policy tackling cold homes even in global warming scenarios of 2°C or higher. The evidence is clear that we will see a reduction in the intensity, duration, and likelihood of cold events because of increased warming.[lv] However, this does not mean that the problem of cold homes will be usurped by problems associated with overheating or other climate risks. Some of the most prominent extreme cold events have been caused by sudden stratospheric warming events (SSWs), which have been connected to extreme cold snaps such as the ’Beast from the East' in 2018.[lvi] Although scientific opinion is not entirely settled,[lvii] there seems to be insufficient evidence to suggest that the likelihood of SSW occurrence, and thus associated extreme cold snaps, will change significantly in the 21st century.[lviii] It is therefore likely that extreme cold events, even if fewer in frequency, will continue to occur and result in detrimental consequences for fuel poor households. We must not fall into a trap of thinking that the problem of cold homes will be mitigated by global warming, even warming at the extreme end of climate modelling scenarios (e.g. 3°C or higher).

10. What are your views on the factors set out above which will determine what is ‘reasonably practicable’ in relation to meeting the fuel poverty target? Are there any additional factors that should be considered in the analysis of the number of homes that can achieve the target level by the target date? Please provide any supporting evidence.  

We agree with the narrative and factors set out in the consultation document. We also agree with the focus on more tightly defining what is meant by reasonably practicable.

11. What are your priority recommendations for an updated plan to improve the energy performance of fuel poor homes? 

CIH works across the entire housing sector, and supports the development of a plan that aims to improve energy performance of all fuel poor homes across all tenures. However, our expertise and research with our members has focused on the social housing sector, and we therefore restrict our detailed comments here to that sector. 

Support schemes

We have several recommendations for how we think schemes could be improved in the future, based on our work with social housing providers. It is worth noting first that we believe the latest iterations of the Warm Homes: Social Housing Fund and the new Local Grant fund are the best designed yet. Our members have commented positively on the design of the Local Grant scheme and welcome the improvements made in the Social Housing Fund from previous waves of the Social Housing Decarbonisation Fund. Our recommendations are made in the spirit of applying a principle of continuous improvement to already well-designed schemes.

Our recommendations are:

Any updated plan must allocate sufficient funding to support schemes to meet – or get as close as possible to – retained or revised statutory fuel poverty targets. National Energy Action’s 2022/23 fuel poverty monitor found that a minimum of £18 billion for energy efficiency measures needs to be invested into fuel poor households to meet the statutory fuel poverty target.[lix] Of this, National Energy Action estimated that £10.8 billion would need to come from the public purse if no low-income household is to be asked to make their own contribution. It is also not sufficient to rely on the finances of local authorities and housing associations to upgrade fuel poor social homes; the social housing sector is facing multiple financial pressures associated with repairs and maintenance, building safety, building new social homes, and the growing costs of regulation that constrain investment in improving energy efficiency. Analysis by Savills shows that it would cost £3.5 billion to improve all local authority homes to EPC Band C by 2030, an unrealistic figure for local authorities and ALMOs to afford given years of cuts to their Housing Revenue Accounts.[lx]

Many social housing providers will therefore remain heavily reliant on grant funding to play their part in meeting statutory fuel poverty targets. To support the sector, we agree with the recommendation made by the National Infrastructure Commission, and would like to see a total of £5 billion invested by government in social housing retrofit between now and 2030.[lxi] This would build on the welcome recent allocation of funds to the Warm Homes: Social Housing Fund and Local Grant schemes.

If resources are more limited, we have two suggestions for how funding could be targeted, with particular reference to the guiding principles of the strategy. These are:

• Firstly, building on Wave 3 of the Warm Homes: Social Housing Fund, allocating further funding to social housing providers to upgrade the energy efficiency of social homes. We feel this offers a likely route to efficient, cost-effective delivery against the strategy’s objectives, because:
  • As the consultation document notes, due to low household incomes in the sector, 56 per cent (around 600,000) of social rented households at EPC Band D or worse are classified by government statistics as fuel poor.[lxii] This means targeting these homes is more likely to contribute to the statutory fuel poverty target while enabling delivery at scale.
  • In addition, government statistics show that 59 per cent of social rented households contain someone with a long-term illness or disability.[lxiii] This means that targeting social homes is more likely to result in energy efficiency upgrades in the homes of people vulnerable to cold-related ill-health.
  • Social housing providers more than match fund government money. In Wave 2.2. of the Social Housing Decarbonisation Fund, £75 million of government funding was match funded with £139 million of match funding.[lxiv] Releasing further funding from the government’s Warm Homes Plan to the social housing sector would unlock a significant amount of additional investment towards meeting the fuel poverty strategy, supporting the cost-effectiveness principle.
  • Wave 3 of the Warm Homes: Social Housing Fund was significantly oversubscribed, and the sector is well-placed to maximise delivery after years of learning from previous waves (especially if barriers to delivery, noted below, are removed).
  • With reference to wider government objectives, prioritising investment in social housing would ensure that the sector has more funding to use for building new homes, contributing to the government’s target of building 1.5 million homes this parliament.[lxv]
• Secondly, innovative area-based approaches, focused on the bottom one or two deciles of the Index of Multiple Deprivation, could result in the cost-effective upgrading of homes in areas most likely to have high fuel poverty prevalence. Housing providers we have spoken to as part of our engagement for this consultation are keen to develop area-based approaches, and many have been participating in programmes such as the MCS Foundation’s Local Area Retrofit Accelerator (LARA) project.[lxvi] A frustration housing providers have is that they can often only upgrade social homes within very deprived areas, leaving fuel poor homes in other tenures untouched. If government took a more coordinating role, bringing local authorities, housing associations, private landlords, and other stakeholders in deprived areas together to develop area-based financing and delivery options, larger numbers of fuel poor households in these areas could be upgraded cost-effectively. A new or adjusted programme based on the Warm Homes: Local Grant, and explicitly targeting the most deprived quintile of communities across the country, could facilitate this. There are previous examples of this kind of approach being successful (see Box 2 below).[lxvii]

Advice and support, including staffing and revenue costs, should feature more prominently in an updated plan for the delivery of support schemes than previously. Evidence from evaluations of fuel poverty schemes has consistently shown that households experience better journeys and receive better outcomes if the installation of energy efficiency and heating measures is accompanied by tailored, personalised advice and support.[lxviii] The presence of this support has several benefits:

• It allows crucial income maximisation and wider energy-related support to be provided at the same time as a capital measure, improving the outcome for the household.
• It enables tailored, personalised instructions to be provided to households about how optimally to  use any heating systems, heating controls, or smart technologies that are installed in their homes, as well as how to ventilate their homes properly and access any specialised tariffs that they might benefit from (e.g. time-of-use tariffs where a heat pump is installed). This is especially important for heat pump retrofits (see our response to Question 8 above).
• It enables ‘translation’ of information between beneficiary households and surveyors/installers, the latter of whom may not be best placed to communicate effectively with vulnerable households or households with specific communication needs.
• It can help to  resolve challenges effectively during pre-installation stages, such as the need for loft clearances or tackling hoarding issues that prevent access.

While these benefits are clear, evidence we have gathered from social housing providers has shown that issues resourcing this advice and support are common (e.g. staffing and training costs). We have also received feedback that the current A&A ceiling in the Warm Homes: Social Housing Fund (15 per cent) rarely makes a meaningful contribution to resourcing the advice and support that is required.[lxix] This ultimately contributes to resident refusals, the issuing of change requests, the withdrawal of some homes from retrofit programmes, and the partial failure of funded projects. In contrast, the privately funded Warm Homes Fund provided funding to some of its grant recipients for both capital measures and advice. The evaluation of the programme found that this enabled grant recipients to offer in-depth support to very vulnerable households to help them manage the pre-installation, installation, and post-installation process, support that they otherwise would not have been able to resource.[lxx] As a result, 100 per cent of Warm Homes Fund project representatives who responded to an evaluation survey agreed that funding for advice should be included in retrofit programmes.[lxxi]

We therefore think there is a case for providing a greater proportion of funding for A&A and staffing costs, to unlock the benefits listed above and avoid the withdrawal of some homes from retrofit projects, improving delivery rates and reducing the amount of unspent capital grant returned by grant recipients. It would also have the advantage of supporting housing associations and local authorities to build skilled advice provision services internally, for example through offering long-term contracts and retrofit training opportunities to resident liaison officers and sustainability teams.[lxxii]

To the greatest extent possible, the ‘strategic partnership’ approach should become standard in allocating funds to housing associations and local authorities. It is clear from our research with social housing providers that the transition from competitive bidding processes to strategic partnerships, as inaugurated in the Warm Homes: Social Housing Fund, offers significant delivery advantages.[lxxiii] Pending the successful completion of the first wave of projects through the Social Housing Fund, this model should become the norm for how funding is allocated for energy efficiency and clean heating measures from 2030 onwards, and as devolution accelerates.

Government and Ofgem should play a more active role in ensuring that energy retail suppliers and distribution network operators (DNOs) do not hold back the delivery of an updated plan and its corresponding retrofit programmes in social housing. Research we have undertaken with CIH members, which we have submitted to Ofgem’s end-to-end review of the connections process,[lxxiv] has shown that retrofit projects are frequently delayed by issues caused by energy suppliers and DNOs. Retrofit programmes in social housing are highly coordinated and sequential, involving multiple stages from initial resident engagement, to surveys, to the phased installation of energy efficiency and other measures. Any delay or interruption to one part of the process for individual homes can have knock-on effects that, in the worst cases, can lead to the issuing of a change request.

In one example shared with us by a member, a meter box needed be moved from the external skin of a dwelling. This required the energy supplier and the relevant DNO, one to remove and refit the meter, and the other to alter the service. However, in this case, and other cases like it, the energy supplier will only communicate with the resident (i.e. the account holder), and the DNO must be lined up to alter the service in sequence before the project can move on to the next stage. In the example shared with us, this was extremely challenging to coordinate effectively, leading to a delay and added cost in staff time to the retrofit of the home in question. In other cases, we have been told about delays in DNOs providing ‘unlooping’ services to homes, issues about requesting quotes from DNOs, and perceived delays in quotations being provided after a request has been made. These delays were described by our members as excessive, and as having significant impacts on their retrofit programmes.

It is also worth noting that these issues have been identified in previous government evaluations. The previous government’s process evaluation of the Social Housing Decarbonisation Fund (SHDF) demonstrator noted that “delays caused by the challenge of coordinating distribution network operation companies to relocate electricity and gas boxes in Fenland, and to move power cables affecting changes to roofing in Wychavon, also created significant delivery delays for these projects.”[lxxv] In its most recent evaluation of the SHDF Wave 1, similar issues were highlighted: “delayed sign off on heat pumps and overhead lines for solar panels from DNOs caused […] delays in delivery.”[lxxvi] Outside of social housing, the government’s evaluation of the Boiler Upgrade Scheme found that 45 per cent of installers cited DNO approval as a challenge to delivering installations.[lxxvii] Ofgem’s proposed actions as part of their end-to-end connections review are welcome and should help, but we feel government and Ofgem should consider this issue more closely.

As part of an updated plan, government should consider how to support heat network providers, especially those run on a not-for-profit basis, with technical upgrades relating to the Heat Network Technical Assurance Scheme (HNTAS). Although not typically discussed in the context of fuel poverty, the government’s recent consultation on implementing heat network consumer protections noted that medical and health-related requirements for heating and hot water may be more prevalent in the heat network sector.[lxxviii] We do not have accurate data on how many fuel poor households are connected to heat networks, but fuel poor households may comprise a significant proportion of all heat network customers. In this context, we agree with the intentions behind HNTAS to improve the efficiency of legacy heat networks because it will reduce heating and hot water bills for heat network customers. However, the costs of doing this may run into the several billions, far in excess of funding currently committed to the Heat Network Efficiency Scheme (HNES) and through the low-carbon heat incentive in the Warm Homes: Social Housing Fund, adding pressure to the already stretched finances of social housing providers running heat networks on a not-for-profit basis. Upgrading, or potentially decommissioning and replacing, legacy heat networks should be seen as a fuel poverty issue, and future scheme design should give more consideration to how upgrading legacy networks can contribute to fuel poverty alleviation.

The challenges of retrofitting complex mixed-tenure estates remain acute. To address this, the plan should consider establishing a new, initially small demonstrator fund for complex mixed-tenure clean heating retrofits and associated placemaking initiatives. This should explicitly be positioned as an innovation fund to improve the energy performance of the most difficult tower blocks and hard-to-treat estates, and be premised on the same high-risk, high-reward (HRHR) principles guiding the new government’s missions. Our research undertaken with members suggests that this type of innovative approach is required to meet the challenges of complex mixed-tenure retrofit, particularly in blocks or estates with a diverse mix of social rented, private rented, and leasehold homes.[lxxix]

Regulation

We support the introduce of Minimum Energy Efficiency Standards in the rented sectors, and agree they should be central to the plan to improve the energy performance of fuel poor homes.

We think, to the greatest extent possible, that the plan should commit to a minimum standard that is the same across both rented sectors. It would not be fair or reasonable for tenants in either rented sector to have a lower minimum standard than the other; tenants should be able to expect the same minimum level of energy efficiency regardless of who their landlord is.

However, we do feel there is some justification for flexibility in government’s approach towards each rented sector, and subsectors within those. The social housing sector is already working towards improving its homes to EPC Band C by 2030; this is costed in many (but not all) business plans, and is reflected in the rapid progress that has been made in the sector since 2010. (The proportion of social rented homes at EPC Band C or above has risen from approximately 24 per cent in 2010 to 76 per cent in 2024.)[lxxx] In contrast, progress in the private rented sector has been much slower. We think this provides some justification for a slightly different approach in each rented sector; specifically, the government’s approach to developing the transition period and policy details for the social rented sector should seek to align as closely as possible with existing sector business plans.

Similarly, the private rented sector is not homogeneous; it contains landlords of different sizes and ownership structures. CIH has members who work in assets and sustainability teams for large for-profit private landlords that nonetheless let their homes at social rent and intermediate rent rates; they are, in important respects, privately owned social landlords. These landlords have the same approach to investment in energy performance as the social housing sector, and some have extremely high levels of energy efficiency across their portfolios. For example, 97 per cent of one private landlord’s homes are EPC Band B or above,[lxxxi] and others have detailed sustainability strategies including commitments to reach EPC Band C (or better) by 2030.[lxxxii]

Regulation should therefore set a minimum standard, but seek to work collaboratively with social landlords and what we have above termed ‘privately owned social landlords’ to align the approach to regulation, especially transition periods, with existing business plans.

Lastly, while we do not have a firm view on this, we do think government should explore the practicalities and feasibility of applying minimum energy efficiency standards to the owner-occupied sector. This would clearly need to be approached differently than the rented sectors, but may be required to meet post-2030 net zero targets and carbon budgets.

12. What are your priority recommendations for the design of energy bill support for fuel poor households?

Responses could include views on: 

• who should receive support
• what form that support should take
• any additional policies which would contribute to the updated fuel poverty strategy to support fuel poor households with the cost of energy

We support the intention to review the current Warm Home Discount scheme and consult on its potential replacement before it expires at the end of March 2026.

Research we have undertaken on fuel poverty in the social rented sector has found that tenants in energy efficient (i.e. EPC Band C or better) homes still face persistent challenges in affording the energy they need to stay warm and safe.[lxxxiii] As well as the cost of energy, this is primarily due to their much lower household incomes, and higher levels of ill-health and disability, which lead to higher required fuel costs. Both of these features are mainly driven by the way that social housing is allocated according to need. Our research also suggests that social housing residents are unlikely to be able to afford the current running costs of low-carbon heating technologies without energy bill support of some kind, even after interventions such as rebalancing gas and electricity levies.[lxxxiv]

This means that energy efficiency improvements – while vital – are on their own insufficient to enable many households to access affordable warmth. While we have less evidence and expertise in the other tenures, the same will likely be true for some owner occupiers and tenants in the private rented sector. We think this justifies a long-term, sustained intervention in energy bill reduction. The aim of this intervention should be to bridge between the present situation, and a future where the electrification of heating and the abundant generation of cheap renewable electricity drives down energy bills for fuel poor households across the country. It should also be to make clean heating affordable for fuel poor households by cutting the cost of electricity (and heat networks costs) significantly.

CIH supports the introduction of a social tariff as the best way of accomplishing this, but we acknowledge the constrained financial environment that government is facing. We would therefore suggest the following guiding principles for the development of energy bill support.

• Affordability. The depth of support must be guided by a rigorous assessment of the minimum that is required to enable people to access the energy they need for good health and wellbeing. For a social tariff, this would mean pricing it below the default tariff price cap. For example, analysis produced by Age UK suggests that a tariff rate could be set at 50 per cent of the energy tariff market rate, or 50 per cent below the price cap – whichever delivers the greatest cost savings to households.[lxxxv] If a rebate approach was to be taken, this at minimum needs to be guided by the fuel poverty gap for different groups of fuel poor and vulnerable households.
• Automatic enrolment. Previous energy bill support schemes have often been exclusionary to certain vulnerable groups because they require people to apply. This has created barriers to access, for example for digitally excluded households (who may struggle with complex online application processes), or households who speak English as an additional language.[lxxxvi] Developing mechanisms for automatic enrolment will therefore be important to ensure support reaches all households that are eligible.
• Implementation across the entire energy market. It is critical that households without a relationship to a domestic energy retail supplier, such as households connected to private wire networks, are not excluded from accessing energy bill support. The Covid-19 pandemic illustrated the challenges of delivering energy bill support to these groups, and the implementation of bill support should seek to include them by design from the beginning.[lxxxvii]
• Wide-ranging eligibility criteria. The projections noted in the consultation document suggest that 8.9 million households in England – or approximately one third of all households – were unable to keep their homes warm at an affordable cost in 2023. Research by National Energy Action has documented how a range of vulnerable groups, including (but not limited to) older people, prepayment meter users, and those with a terminal illness have been unable to afford their required energy costs, with detrimental impacts for their health and wellbeing.[lxxxviii] CIH’s work has also shown that social housing residents are particularly affected by higher energy prices.[lxxxix] While the exact eligibility criteria would require further analysis and consultation by government, this evidence shows that if bill support is to be a truly effective solution to energy unaffordability, it will need wide eligibility criteria that can encompass as large a proportion of low-income and vulnerable households as possible.
• Long-term funding and commitment. There seems to be insufficient evidence to suggest that any energy bill reductions that occur as a result of the Review of Energy Market Arrangements (REMA) and the Clean Power 2030 mission will take place until the 2030s, at the earliest. This, combined with the likelihood of energy network investment being added to consumer energy bills and persistently volatile international gas markets,[xc] suggests that energy affordability will remain an ongoing problem in low-income homes that are upgraded to EPC Band C (or equivalent) through the government’s Warm Homes Plan. In this context, energy bill support must be committed to, and funded, on a long-term basis, at least until significant decreases in the wholesale cost of electricity can be passed directly to consumer bills.

13. What do you think are the priorities for government to support fuel poor households in accessing the energy market fairly and effectively? 

Primarily, the exclusion of fuel poor and vulnerable households from the energy market needs to be seen as more of a function of how the market is designed. Ofgem’s definition of vulnerability recognises that it arises when a consumer’s personal circumstances and characteristics combine with aspects of the market to create situations of detriment or underrepresentation.[xci] Accordingly, in addition to a focus on supporting fuel poor households with access, the government’s priority for policy development in this area should be on minimising those ‘aspects of the market’ that lead directly to detriment and underrepresentation for fuel poor and vulnerable households.

The digitalisation of energy services and products is a noteworthy example. Statistics compiled by the Good Things Foundation shows that 8.5 million people in the UK lack basic digital skills, and that 3.7 million families are below the Minimum Digital Living Standard.[xcii] Research from Citizens Advice has shown that it is persistently difficult for these consumers to take part in the energy retail market.[xciii] It is often more challenging for them to choose a new supplier and get the best deal without using price comparison sites, and many suppliers have shifted their customer services to rely heavily on online channels. Academic research has also shown that the digitalisation of energy services has a number of unintended but harmful impacts for fuel poor and vulnerable consumers, such as the erosion of trust between consumers and suppliers.[xciv] A 2023 report by the House of Lords Communications and Digital Committee found that too many services, including those of energy suppliers, are not accessible digitally for those with additional needs or maintained offline for those who cannot or do not want to use digital services.[xcv]

We recognise that steps have been taken in recent years to minimise or eliminate ‘aspects of the market’ that contribute to detriment and underrepresentation for energy consumers. Ofgem’s work on consumer vulnerability has increasingly placed exclusion and accessibility at its centre. However, we are now at a juncture where the energy market is set to become more complex, with the introduction of minimum half-hourly settlement enabling proliferation of time-of-use tariffs, demand flexibility services, and initiatives such as heat-as-a-service. Ofgem has acknowledged, as part of its recent consultation on refreshing its vulnerability strategy, that this complexity will open new risks for fuel poor and vulnerable consumers.[xcvi] They state that “where innovative products and services are not accessible to all consumers, some consumers can experience harm by missing out on energy and cost saving benefits.”[xcvii] Digitally excluded consumers and consumers with health-related needs for energy are also not well placed to benefit from innovative products and services, such as time-of-use tariffs.[xcviii] For example, research from the Research Institute for Disabled Consumers has shown that smart heating controls are often not designed in a way that maximises their use by disabled and older people,[xcix] and some of our members working for specialist older people’s housing providers have previously highlighted to us that they have struggled to find smart products that are suitable for their residents.

Based on this evidence, we feel there should be two priorities for government. These are:

• Working with Ofgem to ensure that innovative energy products and services are based on clear principles of inclusion by design.[c] By supporting energy products and services that are designed to meet the needs and preferences of fuel poor consumers, government and Ofgem can ensure that these consumers can benefit from them. Generally, the design of the energy market should, wherever possible, follow principles of inclusion by design.
• Supporting, and where necessary funding, local and trusted services to provide tailored, person-centred advice to fuel poor and vulnerable consumers about an increasingly complex energy market, and how they can benefit from it. While we agree with the development of online and telephone advice services, the evidence above suggests that there are many circumstances in which consumers will need detailed, in-person advice, delivered by trained energy advice professionals, to  understand properly and access innovative energy products and services. If this is not provided, the possibility that they will be left behind increases. We strongly agree with the government’s intention to learn from and build on the Local Energy Advice Demonstrator (LEAD) pilots, and think the findings of this programme will be relevant for supporting fuel poor households to access energy efficiency advice as well as advice about how to engage with the energy market.

16. How could access to quality advice be improved to support the fuel poor? Where should advice be targeted?  

We strongly agree with the government’s intention to learn from and build on best practice from the Local Energy Advice Demonstrator (LEAD) programme. This should be used to inform future policy development. The provision of tailored, personalised energy efficiency advice is vital for the reasons noted in the consultation document, and for the reasons we have set out in response to Questions 8 and 13.

17. How could vulnerable households be supported to access advice? Is there a role for the health and social care workforce or other professional groups supporting vulnerable households? 

It should be as simple and straightforward as possible for fuel poor households to access energy-related advice and support. There is a clear role for housing professionals, especially those working for housing associations and local authorities, to support vulnerable households to access advice. Through their day-to-day work, social housing providers regularly come into contact with tenants experiencing energy affordability issues. Additionally, many housing providers have longstanding money advice teams who act as a trusted source of advice and information for tenants, including on energy. The role of these teams was particularly evident during the cost of living crisis and energy price increases in recent years.

Housing professionals can therefore play a critical role in at least four ways:

• Providing energy advice directly to tenants through their own money advice teams
• Signposting tenants to appropriate services such as those provided by National Energy Action and Citizens Advice
• Developing referral partnerships with specific energy advice organisations
• Directly funding posts or staff time at specific energy advice organisations to provide energy advice to their tenants.

Many housing providers will do more than one of these actions simultaneously; they may, for example, have money advice teams that provide simple advice to tenants around areas such as draughtproofing, and referral relationships with expert energy advice organisations if tenants need more bespoke support, tailored to their circumstances.

18. How else can government improve understanding of fuel poverty and its impacts?

Responses could include views on:  

• Any evidence gaps which need to be filled to improve our collective understanding of fuel poverty and its impacts
• Examples of best practice which could improve our understanding of fuel poverty

We have two suggestions here.

1. There is a lack of research and evidence on how fuel poverty is caused and experienced in households without a connection to a domestic retail supplier. There has been some noteworthy research in recent years, such as attempts to understand how fuel poverty can be tackled in Gypsy, Traveller, Roma and Nomadic communities.[ci] However, the causes and consequences of fuel poverty in settings such as care homes, district heating networks, park homes, as well as in more theoretically transient but often semi-permanent circumstances such as temporary accommodation, hostels and B&Bs, and lodging, are poorly understood. More research is needed to close these gaps.

2. There is a lack of robust evidence on how fuel poverty impacts educational attainment in children and young people. Usually, the hypothesis suggests that children and young people growing up in cold homes are less likely to do well at school, affecting their life chances. For example, a 2022 report by the Institute of Health Equity states that “cold homes are more prone to damp and mould […] UK children miss more school days due to disease burden from damp than any EU member state, with rates over 80 per cent higher than the EU average.” The report also notes that “it is much more difficult for children to do homework and study in a cold home where households crowd into one or two heated rooms”.[cii] However, to date there is no robust, quantitative evidence of a link between fuel poverty and educational outcomes. There is no evidence that children living in fuel poverty have worse educational outcomes, where outcomes are defined as either progress 8 or attainment 8. We think DESNZ and Department for Education (DfE) could work together to scope and commission a study looking at this link, with the aim of establishing whether it exists. This could be based on large-scale longitudinal surveys, such as Understanding Society and/or the Family Resources Survey, possibly linked to data in the National Pupil Database. This would also support the government’s Plan for Change milestone to break down barriers to opportunity and give children the best start in life.

20. Do you have any further views or evidence on how the 2021 fuel poverty strategy should be updated?

We have two further points.

Firstly, there is no mention in the consultation document of the Future Homes Standard.

In the last ten years, government data shows that over 100,000 homes have been built that are EPC Band D or below, and could require retrofitting to meet the fuel poverty target (if retained). In 2024 alone, this data shows that over 6,000 new homes were built with an EPC rating of Band D or below.[ciii] The introduction of the Future Homes Standard is therefore critical to tackling fuel poverty and ensuring that current and future generations have homes to live in that are warm, safe, and affordable.

We therefore urge the government to see the Future Homes Standard as a vital part of fuel poverty policy and confirm its introduction without delay, following the technical consultation last year. Every new home that is constructed and occupied today that does not meet a high energy performance specification is putting current and future generations at risk of fuel poverty.

Secondly, we note the evidence in the consultation document that housing costs are increasingly driving fuel poverty. The most effective way of reducing housing costs in the long-term is investment in social housing, which will increase the number of people who can benefit from below-market rents, free up household budgets for spending on energy costs, and mitigate the impact of soaring private sector rents on fuel poverty levels.

Currently, the supply of new social homes in England lags far behind the numbers needed - falling by 85 per cent since 2010.[civ] The investment required is far above current investment levels but will be partly offset by substantial savings in the housing benefit costs of low-income residents being able to move out of the private sector, through NHS savings through lower levels of cold-related illness, and by reducing, and eventually removing, the need to use expensive, private sector temporary accommodation. Research by the National Housing Federation and Shelter has also found that building 90,000 social rent homes could add £51.2 billion to the economy over the next 30 years, and that the investment would break even after three years.[cv]

In the short-term, the immediate priority for tackling unaffordable housing costs is ensuring local housing allowance (LHA) rates reflect the true cost of renting. Approximately 1.8 million private renters in England – one in three of all private renters – receive help through universal credit or legacy housing benefit to afford their home. The local housing allowance (LHA) sets the maximum amount they can claim and is meant to ensure that people can access the cheapest 30 per cent of local homes.[cvi] However, since the last uprating (April 2024) 30th percentile rents have increased by around 6 per cent for the one, two and three-bedroom categories and by 11 and 4 per cent in the shared and four–bedroom categories respectively. Out of 760 LHA rates in England, there were only 12 where the 30th percentile rent had fallen or was unchanged.[cvii] Overall, this means that a higher proportion of household income is being spent on housing costs, reducing the amount that can be spent on energy, and thus indirectly contributing to fuel poverty.

The fuel poverty strategy should therefore look to align as closely as possible with the government’s forthcoming housing strategy to ensure the twin benefits of tackling fuel poverty and tackling high housing costs are realised.

 

 

• [i] Scottish Government (nd) Home energy and fuel poverty.
• [ii] Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019.
• [iii] Centre for Research in Social Policy (nd) The Minimum Income Standard for the United Kingdom.
• [iv] Department for Communities, Northern Ireland (2024) Consultation on a draft Fuel Poverty Strategy.
• [v] Department for Communities, Northern Ireland (2024) Consultation on a draft Fuel Poverty Strategy, p.47.
• [vi] See European Parliament (2023) Energy poverty in the EU.
• [vii] Building Research Establishment (2023) Tackling cold homes would save the NHS £540mn per year, new BRE research reveals.
• [viii] CIH (2023) A social energy tariff: the benefits of energy market reform for the social housing sector.
• [ix] Newcastle University, NEA, and Energy Audit Company (2023) Warm Homes Fund Programme Evaluation: Final Report.
• [x] Regulator of Social Housing (2024) Transparency, Influence and Accountability Standard.
• [xi] Regulator of Social Housing (2024) Consumer standards Code of Practice, p.7.
• [xii] National Housing Federation (2024) Knowing our Homes – proposals on collecting resident information.
• [xiii] See CIH (2024) Building blocks for life: How to develop effective health and housing partnerships.
• [xiv] Energy Systems Catapult (2022) Electrification of Heat: Home Surveys and Install Report.
• [xv] UKERC (2023) Decarbonising Home Heating: An Evidence Review of Domestic Heat Pump Installed Costs.
• [xvi] E3G (2023) Supporting warmer homes for rural communities.
• [xvii] English Housing Survey (2023) English Housing Survey 2021 to 2022: social rented sector.
• [xviii] Personal Finance Research Centre (2009) Saving in lower-income households: A review of the evidence.
• [xix] Burlinson, A. et al. (2024) Household energy price resilience in the face of gas and electricity market crises, Energy Economics.
• [xx] Savills (2024) Housing Revenue Account research update.
• [xxi] Savills (2021) Decarbonising the Housing Association Sector: costs and funding options.
• [xxii] Regulator of Social Housing (2025) 2024 Global Accounts of private registered providers.
• [xxiii] Regulator of Social Housing (2025) 2024 Global Accounts of private registered providers.
• [xxiv] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [xxv] See for example E3G (2023) Making clean heat accessible to all: options for lowering heat pump running costs.
• [xxvi] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [xxvii] Social Market Foundation (2023) We can’t keep heating like this: a fairer deal for heat networks.
• [xxviii] CIH (2024) CIH's response to Ofgem’s affordability and debt call for input.
• [xxix] See our response to DESNZ and Ofgem’s consultation on implementing consumer protections in the heat network sector: CIH (2025) CIH response to Ofgem and DESNZ consultation on implementing heat network consumer protections.
• [xxx] Public Accounts Committee (2024) Decarbonising home heating, p.17.
• [xxxi] CIH (2025) CIH response to Ofgem and DESNZ consultation on implementing heat network consumer protections.
• [xxxii] See National Audit Office (2024) Energy bills support: an update, p.39.
• [xxxiii] DESNZ (2024) Whole House Retrofit (WHR) and Social Housing Decarbonisation Fund Demonstrator (SHDF(D)): Joint Outcome and Economic Evaluation Report, p.11.
• [xxxiv] Newcastle University, NEA, and Energy Audit Company (2023) Warm Homes Fund Programme Evaluation: Final Report, p.120.
• [xxxv] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [xxxvi] Committee on Climate Change (2019) UK housing: Fit for the future?
• [xxxvii] UNEP (2024) Emissions Gap Report 2024.
• [xxxviii] Guardian (2024) World’s top climate scientists expect global heating to blast past 1.5C target.
• [xxxix] IPCC (2021) Chapter 11: Weather and Climate Extreme Events in a Changing Climate.
• [xl] Khosravi, F. et al. (2024) Drastic Overheating of Housing Stock: A Wake-Up Call for the UK Government.
• [xli] See UKHSA (2022) Staying safe in extreme heat.
• [xlii] CIBSE (2020) Overheating position statement.
• [xliii] Environment Agency (2024) National assessment of flood and coastal erosion risk in England 2024.
• [xliv] Public Health England (2020) The English National Study of Flooding and Health: summary of the evidence gathered to date.
• [xlv] DESNZ (2024) Project wind-driven rain in the United Kingdom.
• [xlvi] Chen, C. et al. (2022) Extreme events, energy security and equality through micro- and macro-levels: Concepts, challenges and methods, Energy Research and Social Science.
• [xlvii] Institute of Health Equity (2022) Fuel poverty, cold homes and health inequalities, p.7.
• [xlviii] Cited in Scott, M. and Yesudas, M.N. (2025) Turning up the heat: nine discussion questions on overheating in domestic homes in the UK.
• [xlix] CIBSE (2017) TM59 Design methodology for the assessment of overheating risk in homes.
• [l] Scott, M. and Yesudas, M.N. (2025) Turning up the heat: nine discussion questions on overheating in domestic homes in the UK.
• [li] TrustMark (2024) (2024) Supplementary written evidence submitted by TrustMark (2005) Limited (HEA0176) to the ESNZ inquiry into heating our homes.
• [lii] Scott, M. and Yesudas, M.N. (2025) Turning up the heat: nine discussion questions on overheating in domestic homes in the UK.
• [liii] See Southwark Council (2024) Securing the Future of Council Housing, p.19.
• [liv] See CIH’s (2025) response to MHCLG’s consultation on reforms to the Energy Performance of Buildings regime.
• [lv] Met Office (nd) UK and Global extreme events – Cold.
• [lvi] Met Office (nd) Sudden stratospheric warmings.
• [lvii] Hall, R.J. et al. (2023) Surface hazards in North-west Europe following sudden stratospheric warming events, Environmental Research Letters.
• [lviii] Ayarzagüena, B. et al. (2018) No robust evidence of future changes in major stratospheric sudden warmings: a multi-model assessment from CCMI, Atmospheric Chemistry and Physics.
• [lix] National Energy Action (2024) Energy crisis: two years in – urgent action on fuel poverty policy.
• [lx] Savills (2024) Housing Revenue Account research update.
• [lxi] National Infrastructure Commission (nd) Second National Infrastructure Assessment: energy and reaching net zero.
• [lxii] DESNZ (2024) 2023 fuel poverty detailed tables under the Low Income Low Energy Efficiency (LILEE) indicator.
• [lxiii] MHCLG (2024) English Housing Survey: Chapter 1: Profile of households and dwellings.
• [lxiv] DESNZ (2024) Social Housing Decarbonisation Fund Wave 2.2: successful bids.
• [lxv] See CIH (2025) Submission to 2025 spending review, for more detail.
• [lxvi] See MCS Foundation (nd) Local Area Retrofit Accelerator (LARA).
• [lxvii] Example in Box 2 taken from Newcastle University, NEA, and Energy Audit Company (2023) Case study: Leeds City Council.
• [lxviii] Newcastle University, NEA, and Energy Audit Company (2023) Warm Homes Fund Programme Evaluation: Final Report.
• [lxix] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [lxx] See Newcastle University, NEA, and Energy Audit Company (2023) Warm Homes Fund Programme Evaluation – Final Report, p.26-27.
• [lxxi] See Newcastle University, NEA, and Energy Audit Company (2023) The DEEP Blueprint: A blueprint for the Design of Energy Efficiency Programmes (DEEP), p.23. Specifically, 100% of Warm Homes Fund project representatives said it was fairly or very important to provide fuel-poor households with in-depth advice on how to use and operate their new heating systems, and 100% also said it was fairly or very important to deliver energy advice and income maximisation services in parallel to the installation of insulation and heating system measures.
• [lxxii] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [lxxiii] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [lxxiv] CIH (2024) response to Ofgem’s end-to-end review of the connections process.
• [lxxv] DESNZ (2024) Whole House Retrofit (WHR) and Social Housing Decarbonisation Fund Demonstrator (SHDF(D)): Joint Outcome and Economic Evaluation Report, p.47.
• [lxxvi] DESNZ (2024) Social Housing Decarbonisation Fund (SHDF) Wave 1: Process Evaluation Report, p.70.
• [lxxvii] DESNZ (2024) Evaluation of the Boiler Upgrade Scheme 2024 Interim Report, p.26-27.
• [lxxviii] DESNZ and Ofgem (2024) Heat networks regulation: implementing consumer protections.
• [lxxix] CIH (2024) Decarbonisation strategies in the social housing sector. Unpublished research.
• [lxxx] CIH analysis of DESNZ (multiple dates) Fuel poverty statistics.
• [lxxxi] See written evidence submitted to the LUHC committee by Sage Homes.
• [lxxxii] See G2M Group’s work on sustainability.
• [lxxxiii] CIH (2024) Response to Ofgem’s affordability and debt call for input.
• [lxxxiv] CIH (2023) A social energy tariff: the benefits of energy market reform for the social housing sector.
• [lxxxv] Age UK (2023) Keeping the lights on: The case for an energy social tariff.
• [lxxxvi] Chambers, J. et al (2022) Digitalisation without detriment: A research agenda for digital inclusion in the future energy system, People, Place and Policy.
• [lxxxvii] National Energy Action (2020) UK Fuel Poverty Monitor 2019-20.
• [lxxxviii] National Energy Action (2022) Fuel Poverty Monitor 2021-22.
• [lxxxix] CIH (2024) Response to Ofgem’s affordability and debt call for input.
• [xc] Resolution Foundation (2024) Powering Britain: can we decarbonise electricity without disadvantaging poor families?
• [xci] Ofgem (2019) Consumer vulnerability strategy 2025.
• [xcii] Good Things Foundation (2024) Digital Nation 2024.
• [xciii] Citizens Advice (2022) Access Denied: Digital disadvantage and exclusion in the energy market.
• [xciv] Chambers, J. et al (2022) Digitalisation without detriment: A research agenda for digital inclusion in the future energy system, People, Place and Policy.
• [xcv] House of Lords Communications and Digital Committee (2024) Digital exclusion in the UK.
• [xcvi] Ofgem (2024) Consumer Vulnerability Strategy refresh.
• [xcvii] Ofgem (2024) Consumer Vulnerability Strategy refresh, p.32.
• [xcviii] Citizen’s Advice (2023) A flexible future: extending the benefits of energy flexibility to more households.
• [xcix] See RIDC’s analysis of heating controls for disabled and older people.
• [c] See Fair By Design (nd) Inclusive design.
• [ci] National Energy Action (2023) Plugged In: Final Report.
• [cii] Institute of Health Equity (2022) Fuel poverty, cold homes and health inequalities, p.17.
• [ciii] MHCLG (2025) Energy Performance of Buildings Certificates (EPC) in England and Wales 2008 to 31 December 2024.
• [civ] CIH (2023) Homes at the heart: a strategy for housing.
• [cv] CEBR (2024) The economic impact of building social housing.
• [cvi] See CIH (2023) Homes at the heart: a strategy for housing, p.24.
• [cvii] See CIH (2025) Submission to 2025 spending review, for more detail.

Visit the government's website for more information on the consultation.

For more information on our response please contact Matthew Scott, senior policy officer, matthew.scott@cih.org.