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How Portsmouth City Council contributes to the current Fuel Poverty Strategy (2015)

  • Improving the energy efficiency standards of fuel poor homes

Through various schemes, PCC has delivered energy efficiency measures to over 1,000 households, including first time gas central heating, boiler replacements, loft and cavity wall insulation, energy saving measures such as LED lighting and small water saving measures.

  • Working together to help the fuel poor through partnership and learning

PCC works with external partners to deliver schemes and raise awareness of the issue. Partners include energy efficiency installers, charities, health bodies and water companies. We also host a quarterly Fuel Poverty Working Group.

  • Increasing effective targeting of fuel poor households

PCC provides training internally and externally to help frontline staff identify fuel poor households so that they might be offered assistance.

  • Improving the reach of support for certain low-income households

Through partnerships we are able to offer fully funded energy advice and assistance, as well as the free installation of energy efficiency measures.

  • Tackling the financial burden of energy bills for those on low incomes

We provide onwards referrals to income maximisation services to increase the income of vulnerable households. Through this service we have been able to increase residents' incomes by an average of £3,000 per year where previously unclaimed benefits and assistance are found. We have installed over £700,000 worth of capital measures and have projected lifetime savings of around £900,000.

  • Enhancing and improving the understanding of fuel poverty

We use various media platforms to promote understanding of the issue and to provide information on solutions. We provide advice sessions to residents and train staff and are developing a website to promote the scheme to a wider audience.

Summary of our key points and recommendations

 Portsmouth City Council believes that there is currently not enough support in policy to enable local authorities to provide assistance to the most vulnerable households across England. There are inadequate financial resources available to reach energy efficiency fuel poverty requirements, and little awareness of the issue. 

Addressing fuel poverty is an essential step to reach the 2050 net-zero carbon target - we cannot allow sustainability targets to affect the most vulnerable households. Increased support for retrofitting domestic properties will also contribute to lowering energy use and emissions. We believe current carbon reduction targets cannot be met without increasing support for fuel poverty mitigation measures.

Our recommendations are outlined as below.


Metric for fuel poverty

In order to be able to track progress at a national and local authority level, we would support the metric Low Income Low Energy Efficiency (LILEE). Basing the measurement on the energy efficiency of a building provides a clear target, and including properties in band D within this as 'Low Energy Efficiency' is a future-proof progression that correlates with the future targets well. We support the inclusion of residents in A-C properties as fuel poor when they meet certain vulnerability criteria as we recognise that circumstances can affect the likelihood of living in fuel poverty, regardless of the energy efficiency rating of their home. The change in the metric will reduce the complexity of how fuel poverty is measured. We have concerns over the use of Fuel Poverty Energy Efficiency Rating as payments such as the WHD are only interim solutions, and do not contribute to the reduction of fuel poverty in the long term. We would recommend that BEIS adopt the LILEE measure by looking at EPC data instead.


Targets and Milestones

We support the overarching target of ensuring all households are raised to EPC rating C by 2030, but would suggest that more needs to be done to track progress. We support the inclusion of the milestones, but would like to see revision to the 2025 target, to make it more ambitious or accelerate it. We would suggest that more financial support will be needed to meet these targets.


Guiding Principles to meet targets

The 'Worst First' principle is sensible when considering the limited funds available to support households in fuel poverty. There is limited evidence currently available which shows that this is how fuel poverty is currently being tackled, however, and so we would suggest more tracking of the progress is required. We would also raise the concern that this principle has the potential to remove support for households who fall slightly out of the fuel poor measurement, meaning they could be left to struggle. We would again suggest that more financial support for the eradication of fuel poverty from BEIS could allow for a more fair service to be created so that help is available for all. 

The cost-effectiveness principle needs updating to include a focus on the collaboration of stakeholders to ensure fuel poverty targets are met via innovative and cost-reduced methods. Current communication between local authorities and energy suppliers, for example, could be strengthened to help with the identification of fuel poor households, and to bring down the costs of installing measures. This principle also currently struggles with realising the health benefits a measure might provide, meaning this benefit is not included in measuring how cost effective it is.

We support the use of the National Institute for Health and Care excellence (NICE) guidelines to shape the vulnerability principle. We have updated our own Statement of Intent to reflect these guidelines as we believe they outline the most vulnerable people who are need of support due to their particular risk of being affected by fuel poverty. We support the motion that the Government cannot look solely at the home to measure the risk of fuel poverty.

Whilst we recognise the importance of aligning the fuel poverty strategy with future sustainability strategies, we would caution that those in fuel poverty should not be held responsible for the reduction of carbon emissions as they live in vulnerable situations that might be too expensive to resolve in a low carbon fashion. Reducing the extension of the existing mains gas grid makes sense environmentally, but fails to recommend how these households will be supported with the high costs of electric heating. We would suggest more support for low carbon technologies to be provided to vulnerable households, such as air source heat pumps or solar PV. Encouraging vulnerable households to engage with a flexible energy usage system in order to keep their bills low is a venture that would not be feasible for some households. Engagement with the energy sector is already low, as shown by the amount of households on a standard variable tariff. Residents who require round the clock use of energy, such as those dependant on medical equipment, will not be able to adhere to a flexible use system.

A principle which allows for a focus on hard to treat properties could help improve the energy efficiency for some of the most vulnerable households. As there are high costs associated with the retrofitting of system built properties, many households are left with a lack of funding support which means they can live in some of the least efficient buildings. Further support for the provision of connection to the mains gas network for park homes and properties which are unable to connect to the gas grid would help reach residents who have not been able to receive support previously under the 2015 strategy.



There is a lack of available resources to meet current targets in England. Investment from central Government is vital to support the eradication of fuel poverty.

  • It is essential that support for ECO funding is continued until at least 2028, as this is currently the only source of funding for domestic energy efficiency improvements. Further investment into this pot of money is required in order for England to realistically meet current EPC targets. Consideration should be made to create funding for hard to treat properties and those who cannot currently receive ECO funding.
  • Guidance from central Government is required to push the domestic Minimum Energy Efficiency Standards (MEES). There is currently ambiguity regarding where the responsibility of enforcing MEES lies within a local authority, meaning progress on enforcement is low across the country. With no resources to enforce MEES, it remains unlikely that concerted efforts will be made to tackle non-compliance with MEES within local authorities.
  • Energy networks need to have more of a role towards identifying fuel poor households and offer support. A continuation of the Fuel Poor Network Extension Scheme is recommended. BEIS need to make it clear to Ofgem that the support of distribution network operators for both gas and electricity is required in order to reach targets. For households which are currently not offered assistance due to a constraint on the local network, alternative energy efficiency measures should be funded.
  • The Warm Homes Discount needs to be extended past its current end date of 2021 into the foreseeable future. It should be reformed so that residents who fit into the 'broader group' of eligibility are automatically enrolled to receive the payment. Collaboration with the Department of Work and Pensions would enable the identification of broader group households. We would recommend that more households should be able to receive this payment, and that the amount should not be decreased to allow this.
  • Current income maximisation services should be extended, with requirements to signpost the service so that more households might identify incomes they are eligible for but not claiming.
  • BEIS should review the use of levies on energy bills to fund the above policies. This current approach hits lower-income households hardest, meaning their energy bills are being increased which could contribute to them being identifiable as fuel poor. We would suggest general taxation would reduce this unfair targeting and might provide more of an income to reach targets.
  • Continuation of the energy price caps past the current end date of 2020 should be supported as energy prices are set to rise, putting the most vulnerable at risk.
  • Authorisation should be granted to share patient level data so that targeted support can be provided to those with health conditions which are exacerbated by living in a cold home.
  • We would suggest that further policy needs to be developed so that retrofitted energy efficiency measures are included as a national infrastructure priority. This will allow for comprehensive progress to be made towards meeting both the EPC targets and the Clean Growth Strategy aims.