Fuel Poverty Commitment for Wales

Transcription

1 Association for the Conservation of Energy 13 January 2003 Westgate House 2a Prebend Street London N1 8PT Tel: Fax: Web: Jenny Wright Housing Directorate Welsh Assembly Government Cathays Park Cardiff CF10 3NQ Dear Jenny Fuel Poverty Commitment for Wales The Association for the Conservation of Energy is a lobbying, campaigning and policy research organisation, and has worked in the field of energy efficiency since Our lobbying and campaigning work represents the interests of our membership: major manufacturers and distributors of energy saving equipment in the United Kingdom. Our policy research is funded independently, and is focused on four key themes: policies and programmes to encourage increased energy efficiency; the environmental benefits of increased energy efficiency; the social impacts of energy use and of investment in energy efficiency measures; and organisational roles in the process of implementing energy efficiency policy. The Association is represented on the Energy Efficiency Partnership for Homes Steering Group, Fuel Poverty Group and Hard to Treat Homes Sub-Group. Our recent research publications include Affordable Warmth in Hard to Heat Homes, a project funded by the EAGA Charitable Trust. We welcome this opportunity to respond to the consultation exercise on the Fuel Poverty Commitment for Wales prompted by the requirements of the Warm Homes and Energy Conservation Act Our responses to specific questions raised in the consultation document are attached as an appendix to this letter. However there are three more general points that we wish to raise at this stage: 1. Experience from other devolved nations It is very pleasing to see that the approach in Wales has benefited from the work carried out in the other devolved nations (are you referring to England and, if so, are we devolved?) and lessons learned from their consultations. We applaud the Welsh Assembly both for its positive approach towards committing to sustainable Page 1 of 5

2 development and for explicitly stating that this consultation on fuel poverty falls within that framework. 2. Definitions of income One of the most controversial issues in the discussions on fuel poverty strategy has been that of the definition of income. ACE is one of the original participants in the National Right to Fuel Group which campaigned for the recognition of Fuel Poverty and a strategy and target for its elimination. In our view, using a definition of income that includes the cost of housing is an unacceptable way of artificially reducing the numbers who need to be brought out of fuel poverty. The definition should be based on the proportion of disposable income required to provide an acceptable heating regime. Hence for those on benefits it should be based on income excluding Housing Benefit and ISMI. The Welsh Assembly should press for the UK Government to drop the net income definition in the overall UK Strategy. 3. HEES as a proxy We appreciate that as yet, Wales does not have sufficient data to make an accurate assessment of the number in fuel poverty. We welcome the efforts that are being undertaken to get a more accurate picture. However we are concerned that throughout the consultation, eligibility for HEES is used as a proxy for fuel poverty, when experiences in the rest of the UK indicate (and research is being undertaken to clarify this) that as much as 50% of those eligible for HEES are not fuel poor, and possibly 50% of the fuel poor are not eligible for HEES. This may give the same figure for the purposes of estimates before better data are gained, but by referring to eligibility for HEES as the measure a dangerous precedent is being set. It should be made clearer in the final document that the two are not viewed as synonymous. We congratulate the Assembly on producing a robust and challenging target but point out that two elements require robust definition in order that the target can be evaluated in due course. The definition of fuel poverty has already been discussed, the other is vulnerable households. The Trade and Industry Committee on Fuel Poverty rightly pointed out that there is a need for clarity so that we can determine in 2010, 2012 and 2018 whether the targets have been met, without bickering about whether the right definitions were used. We should not let this prevent taking action now to reduce the problem of fuel poverty, but the definitions do need to be agreed and appropriate. Our responses to the questions raised in the consultation document are attached. Yours sincerely Jacky Pett Senior Researcher Page 2 of 5

3 Appendix: Response to specific questions Is the definition of fuel poverty that we have chosen for monitoring purposes appropriate? Is there merit in considering the gross/net income issue? It is essential that the definition of fuel poverty uses disposable income, excluding that spent on housing costs. The Assembly may wish to publish statistics on the net income definition as a benchmark. Are the public and private sector activities working well together? If not, what could be done to maximise synergy between policies and programmes? There are significant problems about using eligibility for HEES as the qualifying mark for grants and the definition of fuel poverty, not least that only half the fuel poor (estimated from emerging research) are being addressed. Wales should have an additional concern that measures that are needed in a large proportion of Welsh housing are not yet cost-effective under HEES or EEC and it is possible for someone eligible for HEES to receive measures that do nothing to raise them out of fuel poverty, but potentially disqualify them from any future grants. Further work therefore needs to be done to enable private sector activities to take place without some of the constraints currently in place so that they can address areas of need, e.g. by allowing grant funded activity to all vulnerable groups. More also needs to be done to encourage housing associations in Wales to bid for funding under HEES and maximise opportunities under EEC. However the Assembly should be congratulated on the partnerships that have developed such as Putting Wales First. Can we improve the way that we target help through HEES and other programmes/activities? Is the level and type assistance adequate to meet the stated objectives? What more is needed? The first part of this question is covered by the response to the question above. Whether the level and type of assistance is adequate will depend on the results of the data gathering to produce a realistic rather than a proxy figure for the number of fuel poor in Wales. What we do know is that Wales has a higher proportion of solid wall and off-gas network homes, and these are not adequately addressed by current measures so more is needed to provide these measures. Are there any other ways in which the Welsh Assembly Government could help to lift people out of fuel poverty? Welsh Assembly Government is to be congratulated on the range of activities and the inclusive approach, founded partly on its sustainability principles. One area that has only briefly been addressed is the area of retraining people to participate in home improvement measures. The training programme for gas fitters is commendable, but areas of skills shortage exist in most areas of the building trade, and fitting gas central heating where there is a gas pipeline will not make a lot of difference to dwellings in a state of disrepair. Building trades need thorough grounding in the need for and practice of insulation and quality workmanship if the benefits of cheaper heating systems are to be realised. Page 3 of 5

4 Given fluctuations in the costs of fuel and the lack of mains gas in many parts of Wales, are we doing enough to examine opportunities for more sustainable and local power generation sources? No-one is doing enough, but Wales is at present doing more than most with the studies of options and evaluation of solutions for particular types of properties. This needs to be disseminated not only to the housing and energy professionals, but also to the population, to create demand for warm, healthy homes in a traditional style. It is important for the options to be kept wide there will be many solutions and not just one right one. Does the Welsh Housing Quality Standard go far enough in raising standards of energy efficiency? How could it be improved? The Welsh HQS is dramatically better than any equivalent in other parts of the UK. It does not go far enough, and an improvement would be if SAP took account of carbon emissions and not just fuel cost, but at present it is a pragmatic standard that is usable and understandable. However it only applies to social housing stock. The Assembly does not have powers to address the private sector directly, but does need to provide information about privately owned (rented or owner-occupied) housing to get owners to raise their standards to the same quality. If more people knew, they might be ashamed of living in poorer quality housing than council housing. What more can we do to improve the profile of energy efficiency and fuel poverty among local authorities in Wales? The Assembly should be congratulated on getting the RSLs and Local Authorities to work together to produce their HECA reports. One issue that has been mentioned by individuals in authorities in England is that their councillors do not understand the issues of fuel poverty and energy conservation or their responsibilities under HECA. The situation may be different in Wales, but a briefing for public representatives may be fruitful. We look forward to seeing how the post funded by EST and the Assembly at the Welsh Local Government Association moves this agenda forward. Comments are invited on how best the interface between fuel poverty amongst older people and broader agenda to improve services for them and plan for an ageing society can be addressed. The anecdotal evidence cited in paragraph 4.41 suggests that more consideration needs to be given to heat conservation rather than heat production, especially among older people who have often grown up in a cold home and therefore see this as healthy. More thought needs to be given to what older people see as a benefit and the issues of a comfortable home, rather than insisting on technical fixes that the individuals do not want, and do not perceive they need. More thought also needs to be given to the stages of life after 60, as pensioners have changing requirements as they get older. Consideration should be given to working with pensions providers to ensure that everyone receiving their pension for the first time is encouraged to set their home in order for their older age. Are we doing enough to link fuel poverty as an issue with health practitioners and community capacitors? Programmes such as Keep Well this Winter and health referrals are good and need to be continued; too many programmes such as this have too limited a timeframe. Do Page 4 of 5

5 the Assembly consider that senior health professionals and health policy makers are sufficiently engaged with the issue to endorse and enforce activity by case workers? Are we reaching all people in fuel poverty or are some being missed? If they are how could programmes respond? This is already covered by the reliance on HEES eligibility; the fuel poor are not being adequately reached and until much more is known about the incidence, location and severity of fuel poverty in Wales, and whether it links to poverty, house condition or fuel price or a combination of all three, we will continue to miss people. Programmes can only respond to the missing group when they have the information to help them find them. Some assumptions can be made and measures applied that would also be applicable to non-fuel poor. The Assembly should consider whether the benefits of a broader programme (e.g. of lower carbon emissions) and the lack of cost in identifying difficult to identify fuel poor households offset the additional cost of supplying measures for fuel rich households. Does the strategy identify all those with a role to play? How might the Welsh Assembly Government ensure those that have a contribution to make are engaged and able to play a full part? The strategy covers all the housing, health, building and energy professionals and their support organisations and NGOs. Local policy makers and individuals have not been addressed, although isolated case studies may be available. The Assembly might like to consider how local business, especially the media and those with published corporate social responsibility programmes can also play a part in educating everyone about the issues and ensuring that any fuel poor household understands that they do not have to put up with it and that they are entitled to a better quality of life. Are our interim objectives, target dates and proposals for monitoring appropriate? That you have interim measures is commendable. Most are clear and actionable. The definition of vulnerable needs to be clarified. Do you wish to clarify whether the March 2007 target is for HEES to have assisted a total of households or the target is to reduce fuel poverty by 43% of the number identified in the 2004 Welsh Housing and Condition Survey. There is no guarantee that households assisted by HEES will mean are brought out of fuel poverty, which is what 43% of the current HEES proxy would be. We hope these comments are helpful. For clarification or to discuss any of them further please contact Jacky Pett, Senior Researcher at jacky@ukace.org or Page 5 of 5