Consultation Responses

In April 2022, in the same week that it published its “ECO4: 2022 – 2026” response to the Energy Company Obligation, the Department for Business, Energy and Industrial Strategy (BEIS) also issued its Response to the Warm Home Discount. (Link opens as a PDF.)

The document follows a consultation held between June and August last year, which drew 87 individual responses from across 79 organisations. In its executive summary, BEIS writes: “In the Energy White Paper in December 2020, the Government committed to extend, expand, and consult on reforming the scheme from 2022 onwards. The scheme will be extended to 2025/26 at least and expanded to £475m (in 2020 prices) per year.”

In that same week, the NIA submitted its response to the Welsh Government’s proposals for the next iteration of the Warm Homes Programme. The following are some key points from that response:

• Tackling the climate emergency, alleviating fuel poverty and creating a socially just nation can be mutually compatible goals. For example, insulating a building helps to reduce carbon emissions, to lower residents’ bills and thus to alleviate fuel poverty.
• However, priorities can conflict. For example, as things stand, it is more cost effective for a homeowner to replace a broken boiler with a new one, rather than installing a low-carbon alternative such as an Air Source Heat Pump.
• It is important that the Warm Homes Programme works effectively towards shared objectives of meeting fuel poverty obligations, meeting statutory climate change targets, and keeping household bills affordable across the wider population. The Programme should prioritise a holistic approach for measures that provide the best outcome in the long-term.

We also responded to the following question: “What is the gap in provision which you believe the next Warm Homes Programme should fill to achieve a greater benefit for Wales?” We noted that the Warm Homes Programme should take a fabric first approach and promote a whole house retrofit in order to fulfil its aims and to reach its targets.

Other responses included the following:

• We support the proposal in the optimised retrofit model, to “maximise airtightness, eliminate thermal bridging, optimise insulation, solar gain and natural ventilation so reducing heat loss and making homes fabric ready.”
• The Warm Homes Programme must consider the quality of installations, ensuring that they are to the highest standards, namely to PAS2035/2030. Requiring TrustMark registration for all installations ensures adherence to the TrustMark framework and to PAS2035/2030. The NIA suggests that this be considered for the Warm Homes Grant.
• The quality of installations should not be sacrificed for the sake of reducing costs. The ambition to reduce energy-use in new buildings is welcome, but this should be achieved via the installation of high-quality measures.
• Fuel poverty is highest in the 75+ age group. We therefore suggest that this age group is prioritised in the next iteration of the Warm Homes Programme.
• It is welcome that the proposal wishes to alter the definition to include single-occupant homes aged under 25 years of age as vulnerable, but we suggest it be extended also to 55-64s.
• We agree with the ‘worst first’ principle to prioritise those most severely fuel-poor. Such homes tend to be more costly to retrofit as they are usually harder to treat, but we would suggest that the policy cannot leave them behind even if they are more costly, as that would contribute to failures in meeting fuel poverty and climate targets.
• We suggest that fuel poverty targets are made statutory in order to demonstrate commitment. This will help to give manufacturers, advisory services, installers and wider supply chain partners the certainty they need to invest and help achieve the Programme’s targets.
• We broadly agree that the Warm Homes Programme should be extended to other households (in both the owner-occupier and private rented sector). 84% of fuel-poor households in Wales are in that very sector.

NIA Consultation Response 

Our response also encompasses recommendations for measures that should be included or excluded from the next iteration of the Warm Homes Programme, responses to questions about funding sources, and the prioritisation of certain types of homes and residents. The full 12-page document can be viewed here. (PDF.)

We would like to thank all those members who contributed to the consultation.