Continuing the Warm Home Discount (WHD) Scheme Consultation

The Trust appreciates the opportunity to participate in this consultation and to highlight its distinctive role in addressing fuel poverty through the Industry Initiatives (II) element of the Warm Home Discount (WHD) scheme.
The Trust fully endorses the ongoing development of the WHD as a vital mechanism for combating fuel poverty and assisting households facing financial hardship. The scheme provides essential support to individuals struggling with high energy costs and limited incomes.
Nevertheless, any extension of the scheme should be accompanied with targeted reform and improvement to enhance its effectiveness, inclusivity, and alignment with other available support measures.
Fuel poverty continues to affect millions of households throughout the UK. Rising energy costs, the imperative for sustainable solutions, and the need to protect vulnerable groups all underscore the importance of coordinated, both short and long-term, interventions.
The conclusion from the Trust’s ‘Towards an end to fuel poverty in Britain’ report (published in November 2024) highlights the need for a comprehensive, collaborative, and long-term approach to effectively tackle fuel poverty in Britain. Two key insights from the report emphasise this point:

Fuel Poverty is Complex and Interconnected: Fuel poverty intersects with various social issues, including mental health, disability, and wider poverty problems. Addressing it requires a holistic approach.
Holistic Support is Effective but Resource-Intensive: Holistic support, though resource-intensive, creates long-term savings and significant social value. It addresses the root causes of fuel poverty and improves overall wellbeing.

Our Knowledge and Experience in Providing Support through WHD Funding

The Trust’s model places it in a unique position to provide evidence-based insights on improving support schemes for households, especially via the Industry Initiative component of the WHD scheme, which constitutes the foundation of our core funding and ultimately underpins our overall impact.
The Trust has extensive experience supporting vulnerable groups. The Oxford Economics analysis of the Trust’s operations in alleviating the impact of fuel poverty, from April 2020 to March 2024, highlighted:

The Trust effectively reaches groups more likely to be at risk of fuel poverty, such as unemployed individuals, those claiming universal credit, and those with long-term illnesses or disabilities. The Trust also prioritises support in the most deprived areas.

Our approach combines immediate relief – such as energy debt write-off grants, and fuel vouchers – with comprehensive advice delivered via 41 core funded projects, including Citizens Advice and independent local charities. Our interventions have made a significant difference, helping bridge the transition from crisis to stability.
The Trust’s Supporting Communities at Risk Programme (SCARP), which funds 166 project and advisor posts, supported 39,716 clients with over 160,000 issues. Across the three nations, the projects delivered support directly to clients living in target geographic areas, or to specific cohorts (through organisations such as Mencap, RNIB, SCOPE) who are most impacted by increases in the cost of living due to illness, disability or other vulnerabilities.
Significantly, among those helped through SCARP, 66% were receiving benefits, 58% lived in fuel poverty, and 54% had disabilities – highlighting the considerable vulnerability within the communities we serve.
During our latest five-year strategic period, we directly assisted more than 350,000 clients through both direct support and partnerships, as well as via online resources.
Over five years, we have learned that scaling up support is effective when partnerships and funding are aligned; holistic assistance produces lasting outcomes; and emergency relief should be complemented by long-term solutions such as home retrofits, fairer billing, and benefits reform.

Our Approach to the Consultation

The Trust’s response to this consultation is shaped not only by analysing our impact but also through extensive engagement, including seven roundtables held in 2024 with grassroots organisations from some of Britain’s most economically challenged communities.
To deepen these conversations, we organised two additional roundtables in April 2025 that brought together representatives from charities, energy suppliers, and industry groups to discuss the roles of charitable organisations, energy providers, and policy in creating a fairer energy system.
Our consultation points and recommendations are based on the evidence and insights gathered from frontline organisations, as detailed in the reports below.

Toward an end to fuel poverty in Britain

Establishes the context of fuel poverty in Britain. It sets out the clear need to tackle this complex crisis in a holistic way, before setting out several recommendations towards eradicating fuel poverty.

Towards a fairer future: A unified approach to ending fuel poverty in Britain

Outlines the experiences and recommendations of charities, community organisations, and industry representatives working directly with those most affected by fuel poverty.

Consultation Response – Executive Summary

Maintain a streamlined, cohesive eligibility framework

The Trust endorses the proposal to consolidate Core Groups into a unified, consistent Core Group. A single, reliable eligibility framework– supported by comprehensive data matching – will ensure consistency for consumers and enable support organisations to plan complementary interventions more effectively.

Preserve the real value of the rebate

The Trust supports the indexing approach, so that the £150 rebate (which is currently inadequate) remains aligned with household energy expenses. The Trust would support an immediate increase to £300.Periodically reviewing the rebate value will help maintain its effectiveness in alleviating affordability challenges.

Advance stability and measurable outcomes

Establishing a stable, outcome-oriented framework for Industry Initiatives will enhance impact and accountability. Decisions on outcomes should be based on, and prioritise, helping people effectively and in the right way. They should be informed by evidence rather than solely data led. Predictable funding and clear evaluation criteria are critical for delivering consistent and efficient results.

Expand support to indirectly billed households

The Trust would stress the necessity of delivery via credible and trusted partners capable of demonstrating efficiency, effectiveness, and value for money. Extending access to households that pay for energy indirectly represents meaningful progress. Delivery through experienced partners will help ensure equitable and effective support distribution.

Strengthen evaluation mechanisms

Robust evaluation processes and transparent outcome reporting are fundamental for assessing impact and informing future improvements. Aggregated evidence regarding household outcomes can significantly contribute to shaping effective policy decisions.

Promote uniformity across England, Scotland, and Wales

Implementing a consistent core framework throughout Great Britain will foster fairness and transparency, while accommodating flexibility for devolved delivery systems.

Ensure long-term scheme certainty

Sustained stability in scheme design is essential for effective planning and continued impact, guaranteeing that households receive timely and dependable support over the years.
To enhance the effectiveness of the scheme, it is essential that energy suppliers and frontline advice organisations are empowered to adopt a long-term perspective, allowing for strategic planning. If energy suppliers were notified of their WHD obligations in advance for the full duration of the scheme, it would enable funders and frontline organisations to plan and secure longer-term funding with greater confidence.

Budget and funding considerations

Operate on a multi-year, secure foundation, increasing stability by committing to an extended scheme beyond 2026, with inflation-adjusted increases and flexible budget allocation. The Trust recommends establishing a five-year funding commitment for the new scheme.

Integrate financial and energy advice

Incorporate short-term rebates with long-term support and guidance within the scheme to transform immediate assistance into sustained resilience.

Industry Initiatives

Retain and expand the Industry Initiatives component of the WHD scheme, accompanied by a proportionate increase in overall funding as the rebate is extended.
Develop collaboratively to better address evolving needs (such as cost of living or energy crises), with energy suppliers and their charity partners, instead of Ofgem or Government alone.
Ring-fence a minimum allocation (for example, 10–15% of the total WHD budget) for Industry Initiatives, ensuring continuity and preventing the reduction of essential frontline services.
Promote multi-year funding agreements and implement streamlined approval processes for established delivery partners to enhance capacity and facilitate effective planning.
Strengthen data-sharing arrangements (in collaboration with DWP, local authorities, and suppliers) to improve targeting and outcome measurement, while upholding consumer privacy protections.

Our Position on the WHD Scheme’s Continuation

The Trust strongly supports the continuation of the WHD scheme as an essential tool for addressing fuel poverty but believes it needs reform and improvement to become more effective, inclusive, and better aligned and integrated with other support services.

Simply continuing the scheme as it is will not achieve the greatest benefits. The WHD must evolve and adapt to today’s energy landscape, data capabilities, and current social demands. In particular, the scheme should:

precisely target eligible households through automated and efficient processes
connect short-term rebates with ongoing and long-term support and advice
be based on a multi-year, long-term, stable approach
be transparent and subject to evaluation using clear performance outcomes.

Based on the Trust’s direct experience helping thousands each year via debt relief, financial advice, and community engagement, this submission recommends that the new scheme should:

improve targeting and access by utilising data sharing and automatic eligibility
continue and expand Industry Initiatives (IIs) within the WHD Scheme
incorporate financial and energy advice so one-off rebates lead to lasting stability
increase predictability by planning for a multi-year scheme that extends past 2026
promote fair funding by ensuring all suppliers participate and are transparent about cost recovery
boost transparency and evaluation to monitor beneficiaries, identify remaining gaps, and measure outcomes.

The Trust strongly supports maintaining and expanding Industry Initiatives (IIs) in the WHD Scheme.

These interventions are vital for reducing fuel poverty and providing holistic support beyond one-off rebates. Trust programme evidence shows that debt relief, energy advice, and financial capability services create lasting benefits for low-income and vulnerable households that rebates alone cannot offer.

The Multiplier Effect of Trust Funding through WHD/Industry Initiatives

The Trust also supports the continuation of the WHD/Industry scheme as its funding creates a powerful multiplier effect that generates greater social and economic value than its initial investment. When focused on fuel poverty, community support, or energy efficiency, each pound not only benefits households directly but also leads to better health, more disposable income, lower public costs, and growth in local supply chains.

Following the Oxford Economics SRoI report, the Trust asked HACT (A social enterprise that assists organisations understand and evaluate their social impact) to assess the social value of our programmes to better understand current impacts and inform future activities.

A January 2025 internal report found that, for WHD/Industry Initiative funding areas:

SCARP created an indicative social value of £133,224,352.
Energy Vouchers created an indicative social value of £118,808,446.
The Individuals and Families Fund created an indicative social value of £32,082,140.
White Goods Fund (Pilot project at time of analysis) has created an indicative social value of £12,590,974.

Demonstrating that WHD/Industry Initiatives funding is an essential policy tool to protect low-income and vulnerable households from fuel poverty.

Response to the Consultation

In this section, we address the primary themes identified in the WHD consultation, followed by a dedicated segment outlining the significance and effectiveness of Industry Initiatives.

Principles for Scheme Design

Target and assist low-income households with high energy needs, not just those meeting arbitrary cost limits.
Broaden eligibility without reducing benefits or unfairly shifting costs to others.
Use simple, automatic enrolment to maximise equity and reduce application barriers.
Adjust rebates in line with energy costs to maintain meaningful support.
Include renters and those without direct energy accounts to prevent exclusion of vulnerable groups.
Continue providing energy advice, debt relief, and non-cash support.
Implement strong monitoring and evaluation to enable timely adjustments.
Coordinate with retrofit and efficiency programmes to ensure long-term energy relief.

Eligibility and Targeting

Removing the ‘high cost to heat’ criteria, which was complex and excluded many in need—especially those with higher energy costs due to disability – was a positive step. Criteria should focus on genuine need alongside expanding automatic entitlement to include all low-income households on means-tested benefits to ensure parity and fairness across Britain.
Improve data sharing protocols among DWP, HMRC, and energy suppliers to facilitate the automatic identification of eligible customers and prompt distribution of rebates.
Ensure consistent processes across England, Scotland, and Wales. Scottish households should have access to equivalent automatic systems to minimise unnecessary application requirements.
Explicitly include off-gas and prepayment households within eligibility frameworks to address potential exclusion affecting rural or digitally marginalised consumers.

Recommendation: Implement a unified UK data-matching system so all eligible households get WHD automatically.

Delivery, Access and Take-Up

Clarify communication: Many households that qualify are still not informed about the scheme. Collaborate with trusted intermediaries – like GP surgeries, local councils, and community energy advice partners – to boost awareness.
Codesign services and communication with communities: Involve charities and their users in the design of support programmes, supplier customer support services and processes, and informational materials. The language used to communicate should be clear and easy to understand.
Require all suppliers to participate: No exemptions should be granted to smaller suppliers, as this leads to less consumer choice and limits access.
Lower digital barriers: Make sure information is accessible via multiple channels and allow offline application options for those who lack digital connectivity.

Recommendation: DESNZ should make it a requirement for suppliers to engage in proactive outreach and awareness efforts as part of their WHD delivery duties, collaborating with advice providers.

Integration with Wider Support and Advice

Rebates alone do not resolve energy hardship. Evidence shows households that get financial relief plus advice on energy and debt are more likely to improve affordability and wellbeing. 84% of Trust grant recipients who received money advice remained out of debt six months later, compared to 53% of those who did not receive money advice.

Suppliers should automatically refer or direct people to accredited advice providers (e.g., Trust funded organisations, Citizens Advice, LEAP etc).
Allow data sharing (with consent) between suppliers and advice organisations for coordinated support.
Link WHD to retrofit and energy efficiency schemes (e.g., ECO4, Great British Insulation Scheme) to help tackle the root causes of high energy costs.

Recommendation: Make integration with advice and energy efficiency schemes a formal requirement of WHD delivery. It is encouraging that, following Ofgem’s recent Debt Relief Scheme consultation, they have responded to concerns by adding a requirement for debt relief advice to be included in the plan.

Rebate Value and Structure

The current £150 rebate is helpful but increasingly inadequate due to rising energy prices and inflation. The Trust would support an immediate increase to £300.
Indexing the rebate to energy costs would maintain its real value.
Pilot monthly or split payments (e.g., £50/month in winter) to better align with household cash flow and prevent self-disconnection.

Recommendation: Raise the existing rebate, conduct an annual review of its value, and adjust it according to inflation and average domestic energy expenses.

Scheme Duration and Certainty

Annual scheme renewals cause instability for households, suppliers, and delivery partners. The Trust recommends at five-year commitment to ensure predictability, support strategic investment, and enable thorough evaluation.
To enhance the effectiveness of the Scheme, it is essential that energy suppliers and frontline advice organisations are empowered to adopt a long-term perspective, allowing for strategic planning. If energy suppliers know their WHD obligations in advance for the entire scheme period, frontline organisations can secure longer-term funding. This enables better strategic planning, staff retention, and a proactive focus on preventing fuel poverty.

Recommendation: Legislate and implement a multi-year WHD framework, amending it by statutory instrument only for significant reforms and commit to five-year funding for the new scheme.

Cost Recovery and Fairness

Recover WHD costs fairly via the price cap, avoiding undue impact on non-beneficiaries.
Work with Ofgem to manage supplier cash flow and make scheme costs clear in retail prices.
Consider a ’social levy smoothing’ approach to avoid sudden bill increases from WHD recovery.

Recommendation: DESNZ and Ofgem should review WHD cost recovery to align with the default tariff cap and social fairness principles.

Monitoring, Evaluation and Transparency

Publish WHD delivery data annually, covering take-up rates, regional spread, demographics, and unclaimed entitlements.
Track outcomes – like reduced energy debt, better financial resilience, and fewer disconnections – instead of just outputs.
Apply evaluation results to improve the scheme and guide future social tariff design.

Recommendation: Establish a public WHD Evaluation Framework collaboratively developed with suppliers, consumer organisations, and charitable partners.

Industry Initiatives

Industry Initiatives are a vital and proven component of the WHD scheme, offering deeper and longer-lasting relief from fuel poverty by helping reduce debt, improving financial resilience, and providing personalised energy advice.

These Initiatives should be protected, with increased funding, and expanded as part of any efforts to enhance or broaden the WHD scheme, as:

While the WHD rebate provides short-term financial help, it fails to address fundamental problems like existing debt, limited understanding of energy issues, and inefficient homes. Without tackling these, fuel poverty will continue.
Evidence from the Trust demonstrates that targeted interventions, delivered within communities, produce measurable and enduring improvements in household stability, wellbeing, and interactions with energy suppliers such as energy debt arrears.

The Effectiveness of Industry Initiatives

From the Trust’s experience and evidence, Industry Initiatives add unique value by offering a flexible, human-centred aspect to the WHD scheme. This flexibility allows trusted local and national partners to help vulnerable and low-income households, including those who can’t access the WHD rebate – such as those without a direct supplier, people living in park homes or on heat networks, those in rural areas using off-grid fuels, or individuals facing complicated debt issues.

The Trust’s network of 41 core projects across Great Britain demonstrates that such support reaches households in and at risk of fuel poverty and long-term financial exclusion. In 2024/25 alone, Trust-funded programmes provided:

Money and energy advice to 39,716 clients, helping them with over 160,000 issues
More than £6.6 million in debt relief and emergency energy vouchers.

The Oxford Economic Report also concluded that:

After support had been received, just under two-thirds (65%) of respondents agreed or strongly agreed that they feel less stressed since receiving support (65%) and more than three-quarters (77%) agreed or strongly agreed that they feel more financially stable and secure.
This impact also translates into improvements in individuals’ sense of wellbeing. At baseline, 44% of respondents agreed or strongly agreed that they were satisfied with their lives (a commonly used measure of wellbeing), which had risen to 74% in follow-up surveys after support had been received.

These outcomes show lasting gains in resilience and wellbeing, in turn helping to stop new arrears, and ease demands on suppliers, local services, and the NHS.

Impact on Fuel Poverty and Energy Vulnerability

Evidence from the Trust’s work during 2024/25 indicates:

73% of clients felt they could manage their energy bills moving forward.
Clients supported by SCARP had more than £9 million of debt written off, with a further £32.5 million of debt managed.
Energy debt grant recipients received an average grant of £1,228.
There were sustained improvements in financial management and engagement with energy suppliers.
Partner organisations and outreach programmes (See Additional Information section for an outline of the Trust’s Outreach Programme) offer trusted, tailored advice that extends beyond the capabilities of suppliers alone.

Reaching Households the Rebate Cannot Reach

Debt relief, money advice, and energy guidance are proven, cost-effective ways to address fuel poverty. Analysis of the Trust’s grants and support shows:

Individuals given a grant and financial advice were less likely to fall back into debt after three and six months (see Debt Relief section below for figures).
This encourages more engagement with suppliers and better repayment habits.
Improved physical and mental health from less financial stress.

Many beneficiaries miss out on WHD rebates due to indirect billing, switching suppliers because of debt, or not holding an active account (e.g., landlord-billed). The Trust’s community partners fill this gap by supporting these excluded households.

Industry Initiatives also aid households not eligible for the automatic rebate. Many people reside in properties that did not qualify for automatic rebate delivery, such as private rental accommodations, and households with prepayment meters. For example, 34% of Trust grant recipients live in housing association or local authority properties. Without the Industry Initiatives channel, certain groups would not receive support through WHD funding.

Debt Relief as a Foundational Intervention

Energy debt serves as both a cause and an effect of fuel poverty. The Trust’s debt relief approach not only addresses outstanding arrears but also facilitates financial rehabilitation, supporting households in re-establishing sustainable payment plans.

Longitudinal data indicates that, following the allocation of debt grants and receiving support,

over 65% of SCARP clients experiencing reduced anxiety and enhanced mental wellbeing.

The data below illustrates the benefits of pairing debt relief with mandatory money and energy advice. Analysis shows that individuals who received a grant along with financial advice were more likely to avoid returning to debt after three and six months.

Debt Write-Off Grants (Winter 2021-2022) – No Money Advice

Grant recipients not in debt 3 months later – 61%
Grant recipients not in debt 6 months later – 53%

Debt Write-off Grants (July 2022 – April 2023) – With Money Advice

Grant recipients not in debt 3 months later – 81%
Grant recipients not in debt 6 months later – 84%

Value for Money and Wider System Benefit

Industry Initiatives combine charity funding, supplier contributions, and local delivery to achieve broad impact with low administrative costs. Independent analysis finds that:

Every £1 invested in advice or debt relief generates £4–£6 of social and economic benefit, including reduced arrears and lower demand on NHS and social services.
The Trust’s grant model provides national coverage through local networks with minimal admin.
Suppliers gain from fewer bad debts and better customer relations.
Community organisation targeting ensures support reaches households most in need.

The Trust’s model uses established and trusted advice networks (geographic and specific) to reach people across Britain while delivering services locally, making it an affordable way for both industry and government to address fuel poverty goals.

Complementing and Integrating National Policy and Local Delivery

Industry Initiatives play an essential role in connecting national and local programmes – examples include ECO4, the Great British Insulation Scheme, the Social Housing Decarbonisation Fund, and various community health or retrofit projects. Trust-funded advice services frequently direct clients toward these initiatives, helping people progress from short-term assistance to lasting gains in energy efficiency.

A number of Trust-supported advice and outreach services not only provide guidance but also serve as providers (through other funders and schemes) for retrofit and health schemes like ECO4, GBIS, SHDF, and Warm Homes Local.
Many Trust partners have established partnerships with local authorities and health organisations to ensure comprehensive support through cross-referrals, such as seen in ’Warmth on Prescription’ pilot programmes.
Additionally, integrating with national databases, such as DWP data sharing pilots, could further improve efforts to target vulnerable households effectively.

Keeping and increasing the Industry Initiatives budget would boost coordination among schemes and help WHD achieve lasting results, aligned with the 2030 fuel poverty target and the ’worst-first’ approach in England’s Fuel Poverty Strategy.

Monitoring and Evaluation

The Trust supports DESNZ’s plans to improve reporting and evaluation. We recommend allocating a dedicated budget for evaluation and using a standard outcomes framework that covers:

households supported, alongside housing tenure
energy debt reduced or prevented
energy savings or bill reductions
referrals to other schemes
customer satisfaction and wellbeing
social return on investment/value.

This approach will build solid evidence for ongoing improvement while keeping the administrative burden proportionate.

Conclusion

In 2020, the Trust was supporting around 21,000 clients per year. This number has risen to over 72,000 clients supported in 2024/25. Demand for debt and advice services has risen since the energy price crisis, but funding has not. Lowering the Industry Funding cap would reduce support for vulnerable groups and hinder fuel poverty reduction goals.

Cutting the cap to fund broader rebates risks undermining essential services that help households escape fuel poverty and offers less in the way of long-term support.

If the WHD rebate expands, increased or sustained funding for Industry Initiatives is essential.

In our experience, Industry Initiatives:

effectively reduce fuel poverty beyond temporary rebate programmes.
reach excluded households, promoting equity in the WHD framework.
Debt relief is both cost-effective and stabilises households, lowering supplier costs.
are cost effective and high impact by utilising charitable resources and local networks or specialists for high-impact public value.
enhance the fuel poverty ecosystem by linking emergency support with a long-term approach to energy efficiency and decarbonisation.

The Trust recommends that to maintain and strengthen Industry Initiatives DESNZ:

Retain and expand the Industry Initiatives component of the WHD scheme, accompanied by a proportionate increase in overall funding as the rebate is extended.
Ring-fence a minimum allocation (for example, 10–15% of the total WHD budget) for Industry Initiatives, ensuring continuity and preventing the reduction of essential frontline services.
Promote multi-year funding agreements and implement streamlined approval processes for established delivery partners to enhance capacity and facilitate effective planning.
Strengthen data-sharing arrangements (in collaboration with DWP, local authorities, and suppliers) to improve targeting and outcome measurement, while upholding consumer privacy protections.

Additional Comments

To better support individuals and households, through our projects, the Trust would like to see the WHD expanding its eligible practical improvement measures.

Practical Improvement Measures

Support households in poverty to build a better future and that this should first and foremost be around creating warmer, healthier homes delivered through providing emergency energy aid, budgeting support, debt write off, benefit checking and helping to make efficiency improvements to the home.

Recommendation: Include a wider range of eligible home items than currently allowed.

Support households in poverty to be able to be more economically stable and/or active (if possible) by providing more and varied sorts of holistic, wrap-around care suited to an individual’s circumstances e.g. childcare, mental health, education, training, coaching, befriending, language assistance.

Recommendation: Include a wider range of client supports than currently allowed.

Support households at risk of poverty to access preventative support to enhance life chances through educational workshops, events and the creation of initiatives that help people to build confidence and make smarter choices around money and energy.

Recommendation: Include a wider range of project types than we have currently.

Overall Conclusion

The Warm Home Discount Scheme remains a critical policy tool for safeguarding low-income and vulnerable households against fuel poverty.

Nevertheless, any extension of the scheme should be accompanied by enhancements that render it more intelligent, equitable, and cohesive. The British Gas Energy Trust is committed to collaborating with DESNZ, Ofgem, energy suppliers, and the advice sector to ensure that subsequent phases of the WHD achieve enduring impact and support resilient households.

The analysis of the Trust’s impact by Oxford Economics utilising a combination of WHD Funding along British Gas Discretionary funding concluded that:

The Trust’s combination of practical help (such as debt grants and fuel vouchers) with holistic, person-centred support has significantly improved the lives of beneficiaries. This approach not only addresses immediate financial needs but also enhances overall wellbeing and stability.

The benefit of this approach is that individuals and households receive support including income maximisation, money and debt management, health referrals etc, but also energy efficiency support to help people reduce their energy use and bills in the future.

Industry Initiatives and its funding constitute a fundamental component of the impact of the Warm Home Discount Scheme, delivering focused, personalised, and lasting assistance that supplements direct financial rebates. The Trust’s experience demonstrates that these measures effectively reduce debt, enhance wellbeing, and empower households to maintain warmth and security in their homes.

It is imperative that DESNZ preserves and strengthens this established mechanism as part of a comprehensive WHD framework, ensuring that financial aid, guidance, and debt relief operate synergistically to address fuel poverty in a fair, efficient, and sustainable manner.