The G15's response to government consultation on fuel poverty targets

3 April 2025

Position statement

We agree with the 2030 fuel poverty target, as it encourages both private and social landlords to take necessary steps towards creating energy-efficient homes. Improving the energy efficiency of homes is a priority for G15 members, as we recognise how important it is for residents’ health and wellbeing to live in warm homes without having to make financial sacrifices. As social housing providers in London, where affordability challenges are particularly acute, it is a priority for us that residents’ energy bills remain affordable.

To ensure an inclusive approach, both EPC reforms and a fuel poverty target that considers energy affordability is necessary. Many residents may live in homes rated EPC C or above yet still face challenges in paying their energy bills. Establishing this target will ensure these households don’t get left behind when trying to eliminate fuel poverty.

Although we have made significant progress towards the 2030 fuel poverty target, getting all G15 homes up to EPC C by 2030 is challenging to meet under current circumstances. The current widespread shortages of labour and skills in the construction sector also often create barriers for retrofit projects. Social landlords are facing acute financial challenges due to rising interest rates, inflationary pressures and a significantly increased post-Grenfell regulatory burden. We call on government to introduce a Warm and Decent Homes fund that offers a long-term, single source of grant funding for necessary modifications. This is opposed to the current system that relies on multiple different short-term funding schemes from competitive grants.

In addition to improving the energy efficiency of homes, ensuring comprehensive and effective knowledge sharing on how energy markets, tariffs, and pay caps work through information campaigns is essential for fighting fuel poverty. Reaching targets also requires a holistic approach with considers how structural inequalities, fuel poverty, and physical and mental health issues are interlinked. This involves collaboration with existing community services and the NHS.

Fuel poverty targets/objectives

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

We agree with the retention of the 2030 target as it is vital to maintain momentum and accountability in the fight to end fuel poverty. It has been a constructive incentive for landlords to retrofit homes, which is a sustainable and long-term solution to fuel poverty. Improving energy performance should continue to be central to strategy as this will lower the amount Government spends on supporting households with their bills during inevitable energy price fluctuations. As pointed out by the consultation, improving the energy efficiency of homes has taken 112,000 households out of fuel poverty from 2022 to 2023 (1).

However, if Government wants G15 members to meet this target, a range of policy interventions (outlined in our response to question 11) would be required, including a Warm and Decent Homes Fund, which provides long-term and coordinated financial support. There are only five years left until the 2030 target, and harder-to-treat homes in fuel poverty require more investment.

While having this target has been useful, the Government should consider improving the fuel poverty measures associated with it. As stated in our response to the Reforms to the Energy Performance of Buildings regime consultation, G15 members welcome proposed EPC and SAP 2012 reforms, which are the basis of the fuel poverty target. Due to deficiencies in SAP methodology, we are sometimes imprecisely measuring the energy efficiency of homes, meaning some households in fuel poverty are not being accounted for.

Members are supportive of an “affordability-based target” that introduces an additional fuel poverty statistical indicator to sit aside LILEE. While direct energy support and energy prices significantly affect fuel poverty, this approach is not comprehensive enough. While we appreciate the government's efforts to improve EPCs, relying solely on a building's energy efficiency metric will make it challenging to identify all households living in fuel poverty. A family can be living in an energy efficient home and still struggle to afford to heat their home due to factors such as higher than average energy ned, income levels, and energy prices.

Despite there having been progress towards fuel poverty targets in the social rented sector - 68% of housing association dwellings were band C or above in 2023 (2) compared to 59% in 2012 (3) - many of our residents are struggling to pay their bills. The Peabody Index from November-December 2024 shows that 44% of residents stated that they had gone without heating to save money, and this increased to 51% amongst residents who aren’t in paid employment. Additionally, 31% were unable to pay for necessities (e.g., food or electricity) in the last year. Despite making progress towards the current targets, fuel poverty is still a huge problem amongst G15 residents.

We would like a target to prevent individuals in EPC A-C homes struggling to pay energy bills from being left behind and incentivise the government to create policies that ensure these households can effectively heat their homes. These issues will be further expanded on in question 4.

2. What are your views on an alternative fuel poverty target objective and what this objective should be?

The alternative fuel poverty target should be based on improvements to EPC and SAP 2012 and should also include an additional “affordability-based target”.

3. What are your views on the objective date? We welcome views on the target date for the current 2030 objective and a date for any alternative objective which could replace or succeed the 2030 target

The objective date should remain, as changing the date may send a message that this work is not urgent or a priority. However, it should be considered in the context of the significant regulatory changes in the social housing sector, as these will constrain the resources, we are able to allocate towards retrofitting and energy efficiency upgrades. Consideration could be given to additional interim milestones beyond 2025 to track progress.

Measuring fuel poverty

4. What are your views on:

A) 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?

Although LILEE has been useful the following issues should be considered: (1) issues with the ability of EPC to consistently capture the energy efficiency of a home with accuracy, (2) the SAP methodology standard occupancy assumptions, (3) missing EPC certificates.

To consistently measure the energy efficiency of homes, data gathered in previous EPC assessments should be available for use in future EPC calculations. Also, the training quality of energy assessors should be improved, and Accreditation Schemes should be given more responsibility to oversee this due to inconsistencies in interpretation between assessors. EPC improvements will ensure better fuel poverty targeting via LILEE.

Although SAP is useful for measuring energy efficiency of a home and is not biased by the occupier’s demand for energy, it uses standard occupancy assumptions (the number of people in the home and the usual temperature required for a healthy home) that may not reflect the reality of all households. As a result, it can sometimes be an inaccurate basis for a fuel poverty measure when used on its own. One household may be able to afford to heat their home while another can’t due to the number of their occupants and other circumstances. For example, it does not account for the individual characteristics of a household that might mean they use more energy, such as residents requiring medical equipment such as an oxygen pump. Having an overcrowded home, resulting in an increase in lighting and hot water usage, is not accounted for in EPC measures. As London social landlords, this is particularly pertinent for us as overcrowding is more common amongst both social renters (9% of households) and Londoners (11% of households) (4).

Some homes do not yet have an EPC certificate and in these cases, it is very difficult for these residents to claim the Warm Homes Discount or be included in progress towards fuel poverty. A study from Rightmove estimated that there are approximately 11 million homes in England and Wales that do not have an EPC rating as they haven’t been sold or let since the certificates were introduced (5). As mentioned in our response to question 5, we believe landlords should be required to obtain an EPC certificate between tenancies.

Again, this makes LILEE a non-holistic measure of fuel poverty on its own that may exclude some individuals in fuel poverty.

B) whether to adopt an additional indicator to monitor the impact of energy prices on the affordability of energy?

An indicator to monitor the impact of energy prices is important and linking energy prices to the receipt of benefits makes sense given the large impacts of energy price fluctuations. Rising energy costs have unfortunately pushed more people into fuel poverty, including those who may have previously been just above the fuel poverty line or who had never experienced it due to their higher household income. Therefore, the government needs to be mindful of this issue and work on making fuel costs more affordable in the long term. However, if such a measure is implemented, it should ensure that fuel poverty interventions are targeted at those who need them the most.

C) 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?

An additional affordability indicator is necessary as the current measure does not effectively fulfil the “energy affordability” pillar. As mentioned, the LILEE metric, while useful, is imperfect and may not accurately detect all of those who are struggling. We require a fuel poverty measurement that accounts for those living in cold homes in all energy bands, including those in EPC A-C homes.

Although we welcome EPC reforms and are looking forward to the results of these changes, even with an improved system there will still be people in energy-efficient homes who are facing cold conditions and struggling with high energy bills.

We agree the measure should include an income constraint and should not be simply the 10% “after housing costs” indicator. As mentioned in our response to question 4B, a fuel poverty measure should ensure that only the worst off are included.

Strategic principles

Worst First

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 strongly support the Worst First principle as it is essential to make sure the least energy efficient homes are not left behind. When it is possible to do so with operational delivery constraints, prioritising EPC E-G homes (and those with electrical convector, oil, and immersion hot water systems) delivers the largest impact on fuel poverty. Although not many of our homes are EPC E-G, we cannot ignore these properties as they are not thermally efficient, make for high energy bills, and are at risk for damp and mould. Although EPC E-G homes must be prioritised, Government should also consider incorporating an area-based approach into “Worst First” to avoid duplication of work later down the line.

Government is correct in pointing out that focusing on these homes is aligned with the sustainability principle and will support the overall decarbonisation of housing stock

As will be expanded on in question 11, having long-term funding certainty for these works is essential to bringing the worst homes up to EPC C and ensuring this process is value for money.

To ease upgrades especially on the most difficult properties, we would like Government to provide levers to encourage landlords to upgrade homes when they become void. This would prevent disruption for residents as works would be able to be done before move in.

Cost Effectiveness

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

A wider definition of cost-effectiveness is needed – including health savings, carbon reductions, and resident wellbeing – not just upfront capital vs fuel bill savings.

As expanded on in our response to question 11, support schemes for heat decarbonisation and household energy efficiency are not optimal value for money. We require a Warm and Decent Homes fund that provides long-term, certain funding to coordinate decarbonisation efforts across different programmes.

We also want to emphasise the importance of the energy hierarchy for getting value for money as required by London Plan energy policies.

Cost caps are welcome for homes that are especially expensive to bring to EPC C. However, there are some homes that will not reach EPC C by 2030 using fabric first measures. In this case, the cost cap should be factored in with a caveat that the home should be improved to the highest EPC grade where possible with fabric first measures.

Vulnerability

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 welcome the efforts of Government to prioritise vulnerable households in their fuel poverty strategy. However, Government must take a consistent and coordinated approach in supporting vulnerable groups. It is important to consider that many vulnerable individuals are likely to be placed in fuel poverty under the proposed changes to Personal Independence Payment (PIP). Under the government's proposals, assessments for the daily living component of PIP will be more stringent, potentially impacting hundreds of thousands of people (6). If the Government would like to better target fuel poor households who are vulnerable, it should carefully consider these upcoming reforms.

Sustainability

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, including batteries and solar, could be used to support fuel poor homes
How home retrofit can support climate change adaptation

Working towards net zero should be a central part of Government’s fuel poverty strategy. EPC reform to ensure the effective and accurate rating of energy efficiency is key to this. It's also crucial to focus on finding solutions to retrofit challenges, such as addressing labour and construction material supply issues, carrying out work when properties become vacant, and engaging residents in the retrofit process.

We appreciate that fabric first approaches can be expensive or not feasible and can become a barrier to retrofit, but we should maintain the “Fabric First” policy where practical. Increasing renewable energy generation and energy storage could be a valid choice where “Fabric First” is deemed not viable.

We would like to emphasise the important role that decarbonising social housing plays in the route to net zero and fuel poverty goals. Social landlords are currently facing other demands that impact our ability to reach 2030 and 2050 net zero targets. As emphasised in our response to question 11, a long term and robust Warm and Decent Homes fund is required if we are to reach net zero.

In addition, Government should take this time to look at carbon tariffs on electricity use. Carbon factors are out of date making electricity unit costs higher and increasing the ‘spark gap’ acting as a disincentive for heat pump adoption.

Other

9. Are there any additional principles that you think should be considered for inclusion in the new strategy?

We would like Government to consider the following:

Simplicity: Ensure residents have access to reliable guidance and education to make operating heating systems easy.
Equity: Ensure marginalised and underrepresented groups are not left behind.
Co-production: Involve residents in the design and delivery of fuel poverty interventions.

Defining reasonably practicable

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 analysis of the number of homes that can achieve the target level by the target date? Please provide any supporting evidence.

A clearer national framework on “reasonably practicable” would aid consistency. We suggest considering technical feasibility, cost limits, resident disruption, planning constraints (e.g., listed buildings), and landlord capacity when determining “reasonably practicable”. There should be an option to evaluate fabric first principles and solar/battery storage with a hierarchy of measures.

Low cost, High impact

LED lighting: easy upgrade, minimal tenant disruption
Draught-proofing: low-cost, boosts comfort
Loft insulation top up (to 270 mm): especially valuable in uninsulated or under-insulated lofts
Pipe and cylinder lagging: reduces heat loss from hot water system
Heating controls (TRVs, smart thermostat)

Medium cost, Strong impact

Cavity wall insulation: Excellent ROI in suitable homes; very low regret
Underfloor insulation (timber floors): Good comfort gains; increasingly common in SHDF projects.
Smart thermostats: Helps optimise energy use, especially gas heating
Solar PV (4kW system): Depends on usage profile; better with daytime demand or battery

High Cost, Long term impact

Battery Storage: boosts value of solar PV, especially for off-peak storage
Solar + Battery Combined: Best for homes with high daytime or evening loads. Works well in flats or communal setups with flexibility aggregation.
Double Glazing
Air Source Heat Pump (ASHP): Payback improves with low-carbon tariffs and fabric upgrades Ground Source where possible (better efficiency and lower cost to use than ASHP).
External wall insulation Key for solid wall homes; reduces mould and damp risk.
Triple Glazing

Improving energy performances

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

Below are the priority recommendations for an updated plan:

Robust long-term funding without a bidding process which includes (but is not limited to) full funding for hard to treat homes to increase them to EPC C.
Guidance should be given by government to local authorities, so they understand the works being carried out under the Warm Homes Fund. The impact on low-income homes should be considered when planning applications are submitted in certain areas and priority should be given to those cases due to the amount of time given to carry out the works under the funding.
Support should be given to community projects to help fund initiatives that support low-income homes.
Support and training for the sector to deliver the energy efficiency measures.
Review of PAS 2035 requirements to ensure they are not excessively slowing retrofit processes and increasing their costs. Although an assessment is needed, supply and demand have put a pressure on the industry, and the lack of retrofit assessors has affected delivery and thus costs. The cost of the PAS assessment should not be more than the total cost of the measures installed.

We strongly emphasise the need for robust long-term funding. Although we appreciate funding via Warm Homes, this is not sufficient to support the 2030 target. The fund supports 225,000 low-income households over a delivery period of 3 years meaning many in fuel poverty will have to wait until beyond this period.

The current funding process is also not good value for money. Competitive rounds of bidding result in wasted bid costs, an unpredictable pipeline, and a pepper-pot of uncoordinated (often competing) projects. In turn, this is holding back supply chain growth and the speed of delivery. Further supply and demand issues and skills gaps among contractors also make project delivery difficult.

The social housing sector faces significant costs especially from decarbonisation, fire safety and regenerating old housing stock. The estimated cost of decarbonisation for housing associations is an additional £36 billion on top of existing spending plans (7). As London-based social landlords, we face additional financial pressures from the additional costs of operating in London. In total, the estimated cost of repairing all hazards in London’s social rented homes is £348m, while the total for England is £842m (8). London therefore accounts for 42% of the total costs whilst only accounting for 15% of England’s population.

Members urge Government to introduce a new long term joint funding pot for investment in existing homes. We have a great opportunity to coordinate efforts across repairs and planned maintenance programmes with decarbonisation works to advance action and invest more efficiently; leading to better value for money and ultimately improved outcomes for residents. The introduction of a new long-term fund is even more vital given upcoming legislative changes, such as the introduction of a new Decent Homes Standard and Awaab’s Law, which will create significant financial burdens for social landlords. Without a long-term commitment on funding, landlords cannot prepare, or undertake, large, complex and strategic retrofit activities to combat fuel poverty. As mentioned in our response to question 5, our homes in most desperate need of retrofit will require significant and long-term investment.

A staggered 5 to 10-year fund, that fully funds harder to treat homes, would change this. We would be able to invest in a workforce, undertake large scale and long-term improvement projects, and work in collaboration with other organisations (both inside and outside the sector). All of which would speed up our route to net zero, whilst saving money that can be put into new supply.

Energy affordability

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

Government should consider the following:

Retention and expansion of Warm Homes Discount
Flexible tariff models for electric heating users in social housing
Reduction/alteration in the use of PAYG
Support for homes in fuel poverty EPC A-C
Improve and increase energy saving advice and prioritise public awareness campaigns to encourage retrofitting.
A review debt recovery methods of energy companies, reducing the average energy debt and making arrangements more affordable.

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

We agree with Government that reforming prepayment meter practices is important to energy market access. It is essential for us to ensure that prepayment meters are not causing a burden on those already at risk of fuel poverty. If a resident has a prepayment meter, they are unable to spread the cost of energy over the year (9). The complexity of tariffs makes it challenging to compare providers effectively, further complicating the process for consumers (10). This could be rectified by suppliers giving energy customers a choice and information regarding tariff options. Government should also consider implementing policies where energy providers give debt relief for those in fuel poverty.

Energy companies should take the initiative to provide tailored energy-saving advice to the households they supply, as they are best positioned to understand each home's unique energy usage and identify potential savings. This advice should be specific to the household’s needs, rather than generic, to ensure it offers the most value and benefit to the residents.

Targeting fuel-poor households

14. What are your views on how to improve targeting of fuel poor households? Please provide any supporting evidence.

Responses could include views on:

Alternative ways to set criteria to verify the eligibility of fuel poor households
Views on tools that can support better targeting of fuel poor households
How to improve the targeting of support for children and people with health conditions
The role of referrals to help reach vulnerable households
How to target support schemes to hard to reach, or treat, properties.

Reforming EPC is a positive move towards more effectively targeting fuel-poor households. However, the absence of an EPC assessment should not prevent a home from receiving support through the Warm Homes grant. Prioritising the assessment of all homes should remain a key goal, despite the challenges posed by the current skills shortage.

Government should provide more regularly updated data on the fuel poverty levels of residents and consider supplying more specific data at street level or even property level where possible. We appreciate the GDPR regulations that prevent individual-level information on fuel poverty. However, the most recent data we have was collected in 2022 which is now outdated. We agree that using means-tested benefits as the proxy support schemes should be reviewed as this can exclude a significant proportion of the fuel poor population.

In terms of how to target support schemes in hard-to-treat properties, and as emphasised in our response to question 5, hard to treat homes at EPC F and G should be fully funded. We agree that support schemes should be able to reach those living in park homes, houses in multiple occupation (HMOs) and rural areas.

Access to quality advice

15. What else could improve partnership and learning to support the fuel poor?

Raising awareness of fuel poverty and its impact is essential. Education on energy efficiency can help residents to buy into retrofit as it can help them understand the large impact it has on both personal finances and the Government’s net zero goals. Increasing information accessibility on both maximising heating system efficiency and energy price caps, tariffs, and bills can help consumers control their expenditure. National Energy Action and Citizens Advice have been instrumental in increasing access to guidance on energy efficiency.

Spreading information on fuel poverty requires communication and collaboration between Government and local authorities to ensure clear and unified messaging. We favour Government’s support in helping local areas decarbonise through funding Local Net Zero Hubs and Community Energy Projects. Funding to embed energy advisors within housing associations and/or local authority hubs would enable us to offer valuable advice and assess whether households are experiencing fuel poverty. Energy advisors could help residents engage with fabric-first and eco installations to teach them how to use these systems effectively, including adjusting their energy behaviours to maximise benefits. Support should be long-term, extending beyond the point of installation.

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

Access to quality advice for supporting the fuel poor could be improved by collaborating with local charities and social care services, as these organisations are often trusted and well-connected with vulnerable individuals. Collaborating with the NHS can also help, as healthcare providers can provide direct and accurate advice to those most affected by fuel poverty and suffering from related health conditions. A public awareness campaign that is simple, clear, and accessible to all, including those without internet access, would ensure that information reaches a broader audience.

A combined and holistic approach to advice should also be considered. The Responsive Retrofit pilot, a programme delivered by Clarion Futures (the charitable foundation of G15 member Clarion Housing Group) combined money and energy guidance and warm home packs with low-level efficiency measures installed after a holistic home energy assessment. The pilot was found to be impactful: While many pilot clients surveyed continued to report difficulty heating their home (79%), this was reduced by 17% (11).

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?

There is certainly a role for the health and social care workforce to play in access to advice. As mentioned in the response to question 16, these groups have knowledge and understanding on how fuel poverty affects people’s health and wellbeing.

Improving understanding of fuel poverty

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

To improve understanding of fuel poverty and its impacts, it is important to address evidence gaps related to how broader societal issues, such as austerity, affect individuals' access to support services. With fewer in-person visits from professionals like doctors, social workers, or occupational therapists, there is less opportunity for them to observe and inquire about the living conditions at home, which could reveal signs of fuel poverty. This lack of professional curiosity, driven by time constraints and limited resources, makes it harder to fully understand the extent of the impact of fuel poverty.

Filling this gap could involve improving data collection on how austerity and reduced in-home visits are contributing to the issue, alongside exploring ways to support frontline workers in identifying and addressing fuel poverty despite these challenges.

Best practices could include integrating fuel poverty awareness into the training of social care professionals, ensuring that even brief visits include a focus on the home’s energy efficiency and its effects on health and wellbeing. However, it’s important to recognise that addressing fuel poverty cannot be done in isolation and needs to consider these wider societal challenges.

Scrutiny of current process

19. Are existing arrangements sufficient to meet our commitments to review and scrutinise Government action on fuel poverty?

This consultation is a positive step forward for action on fuel poverty. However, we need to consider how fuel poverty connects to other health and social issues and consider how existing community support can help households in fuel poverty. Having a wider and more holistic understanding will reduce the current knowledge gap and ensure that support reaches those who need it the most.

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

When updating its fuel poverty strategy, Government should not think of energy efficiency improvements that decrease fuel poverty as separate from related initiatives like the Decent Homes Standard, Net Zero plans, local housing strategies, and Awaab’s law. As stated in our response to question 11, a Warm and Decent Homes fund needs to provide long-term funding for the needed improvements. This support should include full funding for the least energy efficient homes to ensure they are not left behind.

The new strategy must also address constraints in retrofit supply chains.

We also emphasise the necessity of a holistic and collaborative approach that works with other services such as the NHS.

References

(1) DESNEZ (February 2025)
(2) MHCLG (January 2025)
(3) MHCLG (July 2012)
(4) House of Commons (November 2023)
(5) Rightmove (n.d.)
(6) BBC (March 2025)
(7) Levelling up, housing and communities committee (June 2023)
(8) GLA (November 2023)
(9) Citizens Advice (n.d.)
(10) Stay Energy Safe (n.d.)
(11) National Energy Action (2024)