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The Trust’s response to the fuel poverty strategy review for England consultation

The Trust appreciates the chance to respond to this consultation.

Fuel poverty remains a daunting reality for millions of households across the UK. The intersection of escalating energy costs, the pressing need for sustainable energy solutions, and the urgency of protecting vulnerable communities requires focused and immediate action.

The conclusion from the Trust’s recently published report, Toward an end to fuel poverty in Britain 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.

More than 140 organisations contributed to the report findings by participating in a series of seven in-person roundtables. The results indicated that individuals such as people living with disabilities, unpaid carers, rural households, and the digitally excluded remain significantly affected by fuel poverty.

The Trust’s primary concern is to ensure that, the new strategy will alleviate fuel poverty and effectively targets those in need.

In our response, the Trust highlights what we believe are the key areas in response to the consultation.

Retaining the 2030 fuel poverty target

The Trust agrees with the retention of Governments 2030 fuel poverty target as it will maintain government and other stakeholders focus on addressing the issue and measuring progress, in relation to the following key reasons:

Protecting Vulnerable Households

Fuel poverty disproportionately affects low-income households, the elderly, and individuals with health conditions. Retaining the target ensures continued focus on reducing energy costs and improving home energy efficiency for those most in need.

Meeting Net Zero Goals

Improving home energy efficiency cuts carbon emissions and aids the UK in achieving its 2050 net zero target. Eliminating the 2030 goal may hinder efforts to make homes more sustainable.

Potential Long-Term Economic Benefits

Investing in energy efficiency measures, such as home insulation and heat pumps, reduces the burden on households and the NHS (by preventing illnesses linked to cold homes). Ultimately saving money in the long run.

Maintaining the 2030 fuel poverty target is important for social equity, environmental responsibility, and economic stability. To achieve this target effectively, the Government should consider implementing stronger policies and providing additional funding.

Adapting or Implementing the Worst First principle

The households in deepest fuel poverty often live in the worst housing conditions and their properties are often difficult and expensive to treat.

The Worst First principle—prioritising the least energy-efficient, most fuel-poor homes for upgrades—is a logical and fair approach to tackling fuel poverty. To achieve the goal of having the maximum number of homes reach Energy Performance Certificate (EPC) Band C, a balanced strategy is required to ensure no homes are left behind.

This approach could work effectively by adopting the following principles:

Prioritisation

The worst homes (e.g., those in Bands F and G) should receive priority for deep retrofit support.

Homes in Band D and E that require less investment to reach Band C should also be considered, as upgrading them can be quicker and more cost-effective.

A dual-track approach can help maximize the number of homes improved while ensuring that those needing significant upgrades are not overlooked.

Tiered Funding and Support

Government funding could be tiered based on need, ensuring homes with the worst EPC ratings receive proportionally higher investment.

Additional incentives could encourage landlords and homeowners to upgrade Band D and E homes, which are simpler to improve.

A minimum standard requirement (e.g., no homes below EPC Band E by 2025) could ensure progress across all levels.

Addressing Regional and Housing-Type Issues

Homes in rural, off-grid, or solid-wall areas need require more costly upgrades like wall insulation or heat pumps.

Funding should address regional differences so rural and harder-to-treat homes get support.

The Worst First principle can ensure fairness and reach the most vulnerable. A balanced approach combining deep retrofits for the worst homes and scalable interventions for the fuel-poor population can maximise impact and ensure inclusivity and no one is left behind.

Who Should Receive Support

The Trust aim is to ensure that the new fuel poverty strategy alleviates fuel poverty and effectively targets those in need.

The Trust has extensive experience supporting vulnerable groups. An Oxford Economics social return on investment (SRoI) analysis (published in May 2024) 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. ​

The most vulnerable groups who need support include pensioners, individuals with disabilities, families with young children, and others who are especially susceptible to fuel poverty. Targeting households on means-tested benefits is also crucial, but it has limitations in reaching fuel-poor households.

Means-tested benefits can simplify identifying financial need, but households in expensive-to-heat homes who do not qualify for benefits—like pensioners, disabled individuals, or low-income workers—may lose support despite being in fuel poverty.

Recent policy changes have reduced winter fuel payments, affecting over four million elderly individuals who are now at risk of fuel poverty.

In our response to the expansion of the Warm House Discount scheme, we highlighted that while overall the change is expected to support a larger number of fuel-poor households and would increase the overall coverage of fuel poor households from around 30% of total households in fuel poverty to around 45%, it would still mean that 55% of households in fuel poverty would not receive the rebate.

This matter is crucial to the fuel poverty strategy because the expansion of the WHD scheme underscored the necessity of structuring support properly and effectively to improve assistance provided to households experiencing fuel poverty.

The new fuel poverty strategy must address concerns about excluding households not receiving means-tested benefits, particularly those slightly above benefit eligibility.

Forms of support could include:

Direct Financial Assistance: Automatic discounts on energy bills, such as the Warm Home Discount Scheme, provide immediate relief.

Provide automatic discounts on energy bills, winter fuel payments, and emergency credit for prepayment meters. Consider tiered support, offering higher payments during colder months.

Energy Efficiency Improvements: Investments in home insulation can lead to substantial savings.

Improve energy efficiency through grants for insulation, heating upgrades, and renewable energy adoption. Expand community outreach programs to help people apply for support.

Why Combined Money & Energy Advice Matters

In Trust’s experience and confirmed by our data, debt relief, money advice, and energy guidance  are the most effective help to vulnerable customers. For lasting impact, this support addresses the whole situation of individuals or households.

The Trust’s debt relief schemes have a requirement for money & energy advice as in our experience one-off debt relief is not on its own is not a sustainable solution individuals and households.

An analysis of the Trust’s impact by Oxford Economics (see Additional Information for link to the report) published in May 2024 concluded that: ‘A Holistic Support Approach: 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 receiving include 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.

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% at follow-up surveys after support had been received.

Priorities for Fair Energy Market Access

Two key recommendations from The Trust’s ‘Towards an end to fuel poverty in Britain’ were:

Implement a national social energy tariff: Establish a universally accessible social energy tariff, targeted at low-income households and financially vulnerable individuals, to mitigate the immediate financial pressures of fuel costs. This tariff should work alongside existing schemes like the Warm Home Discount, rather than replacing them, to ensure comprehensive support coverage.

End regional pricing variations and simplify energy billing: Standardise energy tariffs across regions to eliminate postcode-based cost disparities. Simplify billing by removing standing charges and using a single unit rate, making energy costs more transparent and manageable, particularly for prepayment customers who are often most vulnerable.

In making energy pricing fair and simple, the Trust would support:

Implementing a universally accessible social energy tariff can mitigate immediate financial pressures on low-income households. ​

Ending regional pricing variations and simplifying energy billing can make energy costs more transparent and manageable. ​

 The Trust CEO was part of the Scottish Government’s Social Tariff Working Group, and we support the urgent need for targeted bill support (as the social tariff is framed in the Groups report) to protect energy consumers from high costs and ensure they can afford their energy needs.

Improved Targeting of Fuel Poor Households

In our response to the expansion of the Warm House Discount scheme, we highlighted that the funding now focuses on income-based eligibility, prioritising those struggling financially rather than those in high-cost-to-heat homes.

As the scheme is now extended to a larger but less-targeted group, as the consultation states: the percentage of recipients that are fuel poor is expected to drop from around 40% to 30%, it will still mean that the vast majority of spend (70%) will be to households not in fuel poverty.

This issue is significant to the fuel poverty strategy because the expansion of the WHD scheme indicated that funding for support must be structured properly and effectively to reach households experiencing fuel poverty.

While means-tested benefits can simplify identifying financial need, households in expensive-to-heat homes who do not qualify for benefits—like pensioners, disabled individuals, or low-income workers—may lose support despite being in fuel poverty. The Trust is concerned that this may overlook some fuel-poor households not qualifying for benefits.

We are in support of an approach, such as the Scottish Government’s Social Tariff Working Group proposals, that targets those most in need.

The new strategy should consider the issue of fuel-poor households who do not receive means-tested benefits and explore simplified approaches, such as the Scottish Government’s Social Tariff Working Group proposals aimed at those most in need.

Data Sharing

A key recommendation from The Trust’s ‘Towards an end to fuel poverty in Britain’ was:

Foster cross-sector collaboration and data sharing: Encourage data-sharing protocols among public, private, and non-profit sectors to improve service delivery, reduce duplication of support, and enable early intervention for households at risk. Cross-sector collaboration can streamline referrals, minimise bureaucracy, and ensure a holistic approach to poverty alleviation.

It is crucial that support for those in need extends beyond eligibility based on benefit receipt, as previously emphasised. We commend the recent efforts to address data challenges, which is critical to better targeting support, now and in the future.

A comprehensive set of metrics should be developed, incorporating elements such as household income, medical need, and rurality. Additional factors might include:

Combine data from benefits, energy suppliers, NHS records, and local authorities to identify vulnerable households.

Use smart meters to detect inefficient energy use or energy poverty.

Partner with charities, energy suppliers, health trusts, GPs, social workers, and schools to find households with children or health conditions.

Map rural areas with poor infrastructure and prioritise off-grid properties for energy upgrades.

In relation to a social tariff (targeted bill support), household income, based on HMRC data, could be shared through an appropriate legal gateway, and could be the key metric in deciding eligibility.

 Supporting Vulnerable Households to Access Advice

Providing individuals experiencing fuel poverty with precise, practical, and prompt advice is crucial for lowering energy expenses and enhancing home efficiency. Additionally, it is vital to integrate this support with financial guidance.

One of the recommendations from The Trust’s ‘Towards an end to fuel poverty in Britain’ was:

Leverage existing community networks for broader outreach: Channel fuel poverty initiatives through community organisations, such as food banks and Citizens Advice, that already serve vulnerable and low-income households. These organisations have established trust within their communities and can deliver support more efficiently than new programmes with no local presence.

The Trust directly contacts vulnerable households through our funded organisations and outreach, prioritising those in high-need areas based on the Index of Multiple Deprivation (IMD). About 40% of our direct grant recipients live in the 20% most deprived areas of England, Scotland, and Wales.

A recent analysis of client data from organisations funded by the Trust, covering the period from 1 April to 31 December 2023, revealed that out of the 185 postcode areas where our Supporting Communities at Risk Project (SCARP) was operational, 121 postcodes (65%) were within IMD levels 1-5, representing the most deprived communities across Britain.

The Trust focuses resources on areas most in need, addressing the root causes of deprivation. Among 64 postcode areas with IMD scores above level 5, we identified specific pockets averaging an IMD level of 2.22, indicating severe deprivation. This allows the Trust to pinpoint needs even in affluent areas.

The Trust’s outreach programmes are instrumental in expanding access to money and energy advice for individuals facing financial difficulties or at risk of fuel poverty.

Our main initiative is the Trust, British Gas & Post Office Pop-Up Programme, which ran from October 2024 to March 2025. This collaborative effort connects people in areas of high deprivation (with over 40 events) with free money and energy advice through partnerships with British Gas Energy Trust-funded organisations, the Post Office, and senior debt and credit advisors from British Gas.

The programme operated in seven locations across England, Scotland, and Wales, spending several consecutive weeks in each area before moving to the next. By targeting deprived communities, it ensures that support reaches those most in need.

The new fuel poverty strategy should consider the methodology of the Trust and its frontline organisations, which focus on providing support in deprived areas and efficiently reaching groups at higher risk of fuel poverty.

Other options for supporting vulnerable households to access advice, include:

For fuel-poor households, money and energy advice should be accessible, proactive, and personalised. Combining digital tools, local outreach, and streamlined processes will ensure effective support.

 Improving Understanding of Fuel Poverty

The Trust works closely with frontline organisations, allowing us to provide authoritative insights into what is effective, what is not, and what is required. Our opinions are substantiated by data and insights gathered from this collaboration and activity.

Our direct engagement with vulnerable households through funded organisations and outreach efforts enables us to identify hard-to-reach households. This approach highlights key areas of potential research and considerations for the new fuel poverty strategy.

The requirement for digital access makes matters worse for many

Digital exclusion affects older and lower-income households, with 3.9 million people over 65 and 2.4 million households from the UK’s lowest socio-economic backgrounds not accessing the internet at home, including some young people.

In organisations funded by the Trust, 69% of clients without internet access have a disability.

People with disabilities are disproportionately in need of support

Oxford Economics found that 53% of those supported by Trust-funded organisations have a long-term illness or disability and many cannot warm their homes. Home energy is critical for those dependent on electronic medical equipment like ventilators and dialysis machines.

Debt, including fuel debt, compounds mental health issues

Individuals experiencing mental health challenges face additional difficulties due to fuel debt, which complicates cost management and the ability to seek assistance, with research indicates that problematic debt increases the likelihood of anxiety and depression.

Twenty-three percent of clients assisted by organisations funded by the Trust suffer from mental health

Older people increasingly live with fuel poverty

Britain’s demographics are changing. Evidence shows older people face increasing challenges, including health issues, care responsibilities, and digital exclusion. Consequently, they self-disconnect from energy supplies to avoid debt, complicating the identification of those needing support.

There is a critical need for further research in this area to fully understand the scale and intersectionality of ethnicity, fuel debt and other social factors.

Ethnic minority households have higher fuel poverty rates than white households, but white households have a larger average fuel poverty gap.

In addressing evidence gaps the main research options are:

Conduct Longitudinal Studies to track fuel poverty and its impact on households over time to provide insights into the causes and persistence of fuel poverty.

Use local-level data to understand regional disparities

 Based on the Trust’s extensive experience and the first-hand insights from frontline agencies assisting individuals in fuel debt, the proposed solutions by these expert organisations, when aligned with data and research, will significantly help address the complex issues associated with fuel poverty in Britain.

Reviewing & Scrutinising Government Action

To ensure accountability, ensuring the strategy and policies remain relevant and effective. Also to keep stakeholders engaged.

Consult with Funders & Frontline Organisations

Engage with Funders like the Trust to leverage their insights and the experiences of frontline organisations we fund, supported by our data and research.

Engage in on-going dialogue and roundtable type discussions with frontline organisations.

Independent Oversight

Review the role and Remit of the Committee on Fuel Poverty to enable it to serve as an independent watchdog for Government progress on fuel poverty strategy.

Consultations

Seek regular input from wider stakeholders.

Annual Reporting

Publish detailed reports on metrics and targets for fuel poverty.

A key part of the new fuel poverty strategy should involve regular collaboration with frontline organisations to gain insights into effective measures and necessary actions to alleviate fuel poverty.

Insights from these expert organisations, supported by data and research, will improve the implementation of the fuel poverty strategy.

Regulatory Stability

As we have stated, the conclusion from the Trust’s report, ‘Towards an end to fuel poverty in Britain’ (published in November 2024) highlights the need for a comprehensive, collaborative, and long-term approach to effectively tackle fuel poverty in Britain.

Recent actions by Ofgem and the Department for Energy Security and Net Zero, mark important steps in addressing persistent fuel poverty. However, practical solutions and strong collaboration among government, industry, and organisations like the Trust are essential.

The Trust is concerned about unstable regulatory and government policies for vulnerable customers. Isolated decisions on individual policies often cause unintended issues for charities and energy suppliers.

For the fuel poverty strategy to be effectively delivered a coordinated policy and support approach is needed to ensure stability and enable better support for vulnerable customers. This will enhance the capacity of the Government, charities and energy suppliers to deliver coherent and sustainable support to vulnerable customers.

Conclusion

Addressing fuel poverty requires recognising its interconnectedness with broader societal challenges. Approaching it holistically will yield the most significant benefits for individuals and communities alike.

As highlighted by the Oxford Economics’ report shows that every £1 spent by the Trust on funding broader money and energy advice service organisations generates £6.50 in social value. It also highlights that “individuals reporting higher levels of wellbeing are known to earn more in later life, thereby benefitting the Exchequer and society at large through higher tax returns, and the higher public spending that this enables. Similarly, a reduction in the prevalence of mental health conditions such as anxiety and depression amongst those receiving grants and/or advice will lower the financial burden on the NHS from treating these conditions, which in the most recent financial year stood at £16.8 billion.”

 The evidence presented in the report demonstrates that holistic support, combined with practical assistance such as debt grants, vouchers, and energy efficiency measures, positively transforms the lives of those supported and generates a social impact that exceeds the initial investment. While resource-intensive, this approach leads to long-term savings and improved wellbeing, making it a crucial component of any effective fuel poverty strategy. We therefore recommend substantial investment in holistic support within the new strategy.

Our report, ‘Towards an End to Fuel Poverty in Britain’, emphasises the importance of collaborating with trusted local charities is crucial to the successful delivery of the new fuel poverty strategy.

The new fuel poverty strategy should be implemented, in the context of the Governments broader poverty strategy, in a manner that effectively mitigates fuel poverty and addresses the cost-of-living crisis while supporting the transition to net zero. Developing a cohesive, long-term plan to eliminate fuel poverty is essential for ensuring a sustainable and equitable future for all households.