Housing Rights submitted our response to the Fuel Poverty Strategy Consultation. We welcome the strategy's outcomes-based approach and the commitment to developing indicators to monitor progress.
We agree with the proposed vision and guiding principles and believe it appropriate that the strategy is linked to the Climate Change Act (NI) 2022.
Housing Rights made several recommendations to help ensure the success of the strategy in addressing fuel poverty and contributing to meeting climate targets. These are laid out below.
Make homes more energy efficient:
- a needs-based strategy should place a sharp focus on the private rented sector by ensuring that MEEs are adequately enforced and deliver a tangible improvement in housing standards in the private rented sector
- the Department for Communities should replace the current minimum fitness standard with the Housing Health and Safety Rating System (HHSRS) liaise with the Department of Health on a number of areas where housing and health are linked to work together to tackle poor housing and fuel poverty
- for the strategy and new fitness standard to succeed, adequate resourcing must be made available for enforcement.
- eligibility thresholds for energy efficiency schemes should increase in line with minimum wage levels, inflation and increases to the cost of living. EPC rating should also be considered in eligibility criteria
- invest significant funding into a new Affordable Warmth Scheme, and adopt a ‘whole house’ retrofit approach to maximise impact toward ending fuel poverty and meeting climate targets
- informed by our recent research on a Just Transition, ensure funding models are fair and do not risk negative consequences for private renters
Collaborate and build capacity:
- ensure referral pathways are resilient and accessible by mirroring best practices in Northern Ireland and include pathways from energy companies to advice organisations
- include experts by experience and members of local communities in task forces and working groups to enable energy communities. This would ensure the strategy is participative and result in better policy outcomes
- legislate to allow discretionary support grants to be used for fuel costs
Governance and accountability:
- disaggregate statistics by income level and on a cross-tenure basis. Given the link between fuel poverty and housing tenure, and fuel poverty and income level, this is essential for ensuring need is identified and targeted
- include an additional indicator for ability to pay utility/fuel bills without going without
- ensure the strategy is participative and engages people experiencing fuel poverty by including them in decision-making through the Advisory Group for the duration of the strategy’s existence