Act on Energy response to the review of the Fuel Poverty Strategy consultation

With more than two decades of support for people with energy advice, we’ve welcomed the opportunity to share our views on the current fuel poverty consultation launched by the Department for Energy Security and Net Zero.

Fuel Poverty is a persistent issue and the statistics show little change over the last few years. And yet the demand for our support service has grown considerably. What’s more, the context around fuel poverty has evolved – an energy crisis requiring direct government support to millions of people has suddenly highlighted the scale of ongoing costs and debt which was previously largely hidden from mainstream media.

This is why we want to see an ambitious, person-centred approach to Fuel Poverty and that’s why the 2030 target should be maintained and objectives upheld, keeping that sense of urgency and determination.

Whilst we agree that the Low-Income Low Energy Efficiency metric should be maintained – we do see the need for additional indicators to monitor the impact of energy prices on energy affordability. We support calls for a rigorous, academic approach for additional indicators especially around the issue of taking housing costs into consideration.

We fully support the ‘worst first’ principle (improving warm homes to those in most need) but we must place people at the heart of this principle and not the buildings itself.  And even when schemes can support this approach, they are often too complex and nuanced to allow for full and proper upgrades. Getting the fundamentals of a home’s fabric sorted – as well as delivering expert energy advice - is absolutely essential before we add in the shining new technologies.

We agree with the need for the cost effectiveness principle – and particularly the focus of health. 'Cold homes = poor health' is well documented and we have considerable evidence from our own work in delivering support for patients with cold homes and helping to reduce re-admission rates.

That’s why, when it comes to the Vulnerability principle, we want to see a much more targeted integration of health and social care - as well as the wider energy market. Our project with Cadent Foundation and Birmingham NHS (BCHC) is addressing this very issue.

Fuel poverty is, of course, a public health issue and we need a sustained, co-ordinated campaign to tackle it. Just as public hath campaigns in the past have targeted smoking and wearing seat belts, so we need to focus on the damage that cold and damp homes are doing to our nation’s health.

For decades we have been hearing about data sharing. Indeed, departments are keen to show the progress they have made with great data analytics – but it seems the use of the data is very limited. We should be able to identify those households in need (and likely in/at risk of fuel poverty) very quickly with the amount of data that is already held by energy suppliers and government departments alike. The reluctance to data share and hiding behind confidentiality and GDPR is often mis-interpreted and becomes a barrier to success.

We are also supportive of the sustainability principle – whilst acknowledging that there is no one size fits all and that the drive to net zero must be a fair transition so that no one is left behind. Our work with Coventry City Council has highlighted this very point.  

And whilst many of the energy efficiencies targeting fuel poor households have made a difference individually – the gap is ever widening, with access to newer technologies (and cheaper bills – such as time of use tariffs, DFS and lower unit rates) still far out of reach for most of our client base.

Our work on Customer Journey Support for various programmes such as LADs and HUGs has shown the critical need for support before, during and after retrofit. This is particularly acute for those who are vulnerable and may be digitally excluded in seeking help and support elsewhere. We have evidence of great installations leaving householders clueless in how to use, monitor and make the most of the new technology. This leads to wider reputational damage across the whole sector and a reluctance for people to engage.

Of course, this goes hand-in-hand with the need to urgently rebalance the full costs associated with electricity – and a fairer distribution of how levies are applied. Applying this through electricity is a regressive tax which is, by design, disproportionately affecting those who can least afford it.  Whilst we know that a move to general taxation is politically unpleasant, there must at least be a shift to from electricity to gas costs.  

In terms of our priorities to improve the energy performance of fuel poor homes:

Improving homes:  

Expanding the scope of LA energy efficiency schemes and assuring we are delivering fabric first approach where possible. We also require better targeted use of data and campaigning to ensure those who are most vulnerable to fuel poverty have access to this support.

Ensure that the MEES is closely aligned to delivering outcomes for fuel poor homes providing LAs with funding and the ability to place meaningful sanctions on landlords who are renting properties that are Cat 1 hazards as part of the HHSRS process.

It is also important that landlords are provided with right advice on EE measures so that they can make well informed choices and install measures that do not lead to unintended consequences.  

Closing the fuel poverty gap that exists most prominently across the private rental sector.  

Bill support:  

Affordability is key, and many are still in danger of self-rationing. That’s why we are supportive of a fair and well thought out social tariff which already exists in other sectors (water, broadband) which must also consider any cliff edge. We agree with the principle of withdrawing the Winter Fuel Payment from its universal to a more targeted approach. But this is just one element, and we need to see a widening of the WHD to include a broader group.

Essential reform of standing charges to a more progressive distribution of costs is beyond due.  

Fair access to the energy market:  

Higher and targeted funding for energy support advice charities like ourselves, who are effectively propping up the statutory sector by supporting residents above and beyond their energy needs.  We are often the only recourse to advice and support that is left for people – and we are running the role that the suppliers themselves should often be fulfilling.

We are at the forefront of explaining the complex changes that are happening in our energy industry – with more to come.  When people still do not understand their bills (tariffs, payment types etc) there is little hope that we can engage them with zonal pricing and flexible tariffs.

We are calling for a co-ordinated and sustained education campaign backed by UK government, essential to ensure a level playing field – something which extends far beyond fuel poverty.

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