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Industry Calls on Government to Do More to Prevent Homes From Falling into Fuel Poverty

Industry Calls on Government to Do More to Prevent Homes From Falling into Fuel Poverty

Following the lack of focus on Energy Efficiency in the Government’s Energy Security Strategy yesterday, the National Insulation Association has signed a cross-industry letter sent to HM Treasury today. Issued by the Sustainable Energy Association, the letter calls on the Government to expand the eligibility of the Energy Company Obligation scheme to prevent homes from falling into Fuel Poverty.

View letter:

The Government has provided support for energy efficiency measures since 2013 under the Energy Company Obligation (ECO), which has since seen over 3 million energy efficiency measures installed in more than 2 million homes. However, while the tried and tested scheme targets vulnerable households, support for homes that fall outside this definition are not eligible.

Two million more UK households could in fact be plunged into fuel poverty due to the price cap increase this April according to National Energy Action (NEA), with the cost of living crisis expected to worsen in Autumn.

Backed by leaders across the energy efficiency industry, including the NIA, the letter calls on the Government to strengthen its Energy Security Strategy by expanding the eligibility criteria for ECO.

The proposed solution is an ECO + Scheme, which would run adjacent but separate to ECO to ensure the key support the scheme brings to vulnerable households is not impacted, whilst helping those who will soon be at risk.

It is proposed that the ‘ECO+ Scheme’ would build upon the success of the current ECO scheme, bringing its benefits to the ‘able-to-pay’. It would run adjacent, but separate to, the current iteration of ECO to ensure the key support ECO brings to vulnerable households is not impacted.

A key difference is that whilst energy bill payers fund the current ECO scheme to support action to benefit vulnerable householders, ECO+ would have to be funded utilising taxpayer funding as additional costs could not be placed on energy bill payers at the current time.

British Energy Security Strategy

British Energy Security Strategy

British Energy Security Strategy

The Government has published its Energy Security Strategy today as part of its plans to boost Britain’s energy security following rising global energy prices and volatility in international markets.

Whilst key announcements focus more on additional supply, there are also key aspects that cover energy efficiency and demand reduction. However, the vast majority of the announcement, summarised below, is old news.

Energy Efficiency in Products and Buildings

  • Better labelling and product standards to be introduced so consumers can purchase more energy efficient products within heating, lighting, washing, and cooking.
  • The installation of household’s energy saving measures to be VAT free for the next 5 years. This is estimated to reduce the cost to consumers of insulation, double glazing, installing solar panels and heat pumps saving families £200 off the cost of installation.
  • A dedicated energy advice offering for smaller businesses to be established. This service is to deliver trusted advice on improving energy efficiency and decarbonisation.
  • Clearer energy performance standards across all buildings to be introduced phased in over the long term. This is likely to be linked to the EPC Action Plan.
  • Smart meters in new buildings to be deployed at a more accelerated rate.
  • Doubling of funding available to develop and pilot new green finance products for consumers from £10 million to £20 million.
  • Introduction of scheme under which lenders will work to improve the energy performance of properties.

Heat in Buildings

  • Heat pump manufacturing to be expanded supported by a Heat Pump Investment Accelerator Competition in 2022. This is estimated to be worth up to £30 million to make British heat pumps, which reduce demand for gas.
  • The UK hydrogen ambition to double up to 10GW of low carbon hydrogen production capacity by 2030. While this is to be used for cleaner power and transport, there is potential for fuelling heat.
  • The UK’s current 14GW solar capacity to grow up to five times by 2035. There will be consultation on the rule of solar projects on domestic and commercial rooftops.
  • Low-cost finance from retail lenders to be facilitated to drive rooftop deployment and energy efficiency measures.
  • Performance standards to be designed to make installation of renewables, including solar PV, the presumption in new homes and buildings.
  • From the industry, Neptune energy will invest to support the priorities through increasing production from Duva field in Norway to heat an additional 350,000 homes in the country.
  • £450 million Boiler Upgrade Scheme.
  • Commitment to ‘rebalancing’ the costs placed on energy bills away from electricity to incentivise electrification across the economy and accelerate consumers. This will also ensure heat pumps are comparatively cheap to run over time. BEIS will publish proposals on how to do so in 2022, considering overall system impacts and limiting the impact on bills, particularly for low-income consumers

Government Response to ECO Consultation

Government Response to ECO Consultation

At the beginning of April 2022, after receiving a total of 144 responses, the UK Government published its response to the latest Energy Company Obligation consultation. In this article, we summarise some of the key points.


ECO3 Interim Delivery

Between 1st April and 30th June 2022, measures can be installed to ECO3 rules. Early delivery of ECO4 measures during any gap between ECO regulations is permitted.


Carry-under from the current obligation period is not permitted, but up to 10% of ECO3 delivery may be carried over to ECO4.

Solid Wall Alternative Measures can be carried over but they will not contribute towards the ECO4 Solid Wall Minimum Requirement. Measures delivered into E, F, and G-rated homes can be carried over but will not contribute towards the ECO4 EFG Minimum.

Where dual measures are delivered (insulation and heating), there is the option for the heating measure alone to be elected as carry-over. Replacement of efficient broken electric storage heating (ESH) and boilers carried over will count towards the ECO4 Broken Heating Replacement Cap.

Replacement of inefficient ESH and boiler upgrades (including those broken) can be carried over and fall outside of the ECO4 Broken Heating Replacement Cap. Inefficient heating systems can be replaced with First-Time Central Heating (FTCH) uncapped as all FTCH will also fall outside of the ECO4 Broken Heating Replacement Cap.

These are all subject to the overall 10% carry-over maximum. Carry-under has been deemed unnecessary.


Continuing a Fabric First Approach

The Solid Wall Minimum Requirement will be retained, and this option will be removed from Solid Wall Alternative Measures.

Whilst the consultation discussed SWMR set at 22,000 solid wall insulation measures per year for ECO4, based on updated modelling, the Government has decided to increase SWMR to be set at an equivalent of 90,000 measures for ECO4. This will be alongside the private-tenure EFG minimum equivalent of 150,000 homes.

Unless all eligible fabric measures are already installed to meet the current Building Regulation standards; the home holds a listed status; or is in a conservation area and unable to have insulation installed, then minimum insulation preconditions for all homes receiving any heating measure (including heating controls) will be enforced:

  • All band D homes receiving any heating measure other than First Time Central Heating (FTCH) must have at least one primary insulation measure installed (flat roof, pitched roof, room-in-roof, cavity or solid wall, park homes and floor insulation)
  • All E, F and G-banded homes receiving any heating measure, and band D homes receiving FTCH, must have all exterior facing cavity walls and loft (including rafters) or roof (including flat, pitched and room-in-roof) insulated.


ECO4 Flexible Eligibility

Up to 50% of the obligation can be met under ECO4 Flex delivery (LA and Supplier Flex). Participation will continue to be voluntary for suppliers, local authorities and the devolved administrations.


Eligible Households

There will be a pool of eligible households that BEIS estimates to be at least 3.5 million.


Minimum Requirements

A minimum equivalent upgrade of 150,000 private-tenure band EFG homes will be introduced. There will be minimum requirements for works with all eligible owner-occupier homes having an efficiency rating of D-G. Private rental homes and social housing will need to be E-G.


Partial Project Scores

The Government has decided to implement its proposal to use deflated partial project scores where a project is found to be non-compliant with the minimum requirement (MR) at the point of notification. Those projects will not have met the MR in practice and therefore all the remaining measures in the package will receive partial project scores, while rejected measures receive no score.

Click here to read the Government’s full response document.

The Warm Homes Programme – NIA Consultation

The Warm Homes Programme – NIA Consultation Response

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.

NIA Parliamentary Day – 06 June 2022

On Monday 6th June, the NIA will host three exclusive events in London.

The first, beginning at 15:30, will be our AGM, which will be an exclusive, members-only session. This will be followed immediately at 16:00 by an informal industry policy briefing, which will be open to members and to a list of special invitees. Here, attendees will be able to interact and engage with NIA members and BEIS officials.


Both sessions will take place at the same afternoon venue:

Broadway House, Tothill Street, London, SW1H 9NQ.

Then, between 18:30 and 21:30, we will host a Parliamentary Reception in the prestigious

surroundings of the House of Commons Terrace. Here, attendees will be able meet with NIA members, BEIS officials, industry stakeholders and policy-makers. They will also hear from several speakers, including our key speaker Lord Callanan, Parliamentary Under Secretary of State (Minister for Business, Energy and Corporate Responsibility). He will share his thoughts on the Government’s priorities for energy efficiency and the role that insulation can play in the journey to net zero.


Evening venue:

Terrace Pavilion, House of Commons, London, SW1 0AA.

The events are sponsored by NIA members STO and Sustainable Building Services and further details can be found on the event flyer:


If you have not received your invitation or would like further information on the sponsorship opportunities please email

Instagroup Limited

Cavity wall Insulation, Cavity wall insulation (extraction), Draught-proofing/ Air tightness measures, External Solid Wall Insulation, Hot water cylinder insulation, Internal solid wall insulation (IWI), Loft insulation (between and over joists), Loft Insulation (between/under/over rafters), Park home insulation, Party cavity wall insulation

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