Government must go back to the drawing board on energy plans

The Government's controversial energy efficiency plans have never been far from the headlines in the past months, with a new fuel poverty consultation adding yet another layer to the conversation. Mia Rotaru, NRLA Public Affairs Officer, explains why the Government is premature in launching yet another consultation now - and what need to happen instead.

The Government defines fuel poverty in England using the Low-Income Low Energy Efficiency (LILEE) definition. Under the LILEE indicator, a household is fuel poor if: 

• Its income is left below the poverty line after paying the cost to heat and, 

• they live in a property that has a fuel poor energy efficiency rating of D and below.     

The fuel poverty target 

The Government is introducing wide-ranging reforms to energy efficiency, including a revised EPC methodology, a new Minimum Energy Efficiency Strategy and the Home Energy Model (HEM).

Separately, it is also reviewing the fuel poverty strategy since the progress towards the target of upgrading fuel-poor households to a minimum energy efficiency rating of Band C by December 2030 has stalled. 

We appreciate that the proposed measures aim to provide safe and warm homes in England, which is what we all want, however in our response to the consultation, we stress the need for a coherent approach which aligns fuel poverty targets with evolving energy efficiency regulations, such as EPCs, MEES and HEM (to be published in due course).

That is why consulting on the fuel poverty strategy now may be premature.

Without clarity on the updated MEES requirements, it is difficult to assess how landlords will respond, what financial support may be necessary, and how effectively the policy will align with broader energy efficiency goals. 

Measuring fuel poverty 

One of the key challenges for landlords is that fuel poverty assessments focus on tenants' income levels - over which landlords have no control. T

his complicates access to funding schemes that use income-based eligibility criteria.

In our response, we made it clear that fuel poverty policies should: 

• Target the least energy-efficient properties using robust data on local housing conditions and the cost of achieving Band C.
• Ensure funding schemes, like the Warm Homes: Local Grant are transparent and allocated to properties where retrofitting will have the greatest impact. 
• Recognise regional disparities in property conditions, particularly in older housing stock which require higher levels of financial support for retrofitting; something highlighted in the report we published alongside Localis.

A realistic and coordinated approach

It is vital the Government takes a coordinated approach when developing its fuel poverty strategy, ensuring that regulatory changes do not impose disproportionate burdens on landlords.  

As the Renters’ Rights Bill enters the Committee stage in the House of Lords, reforms to energy efficiency policies must be coordinated with other major regulatory changes in the sector.

Policies such as Awaab’s Law and the extension of the Decent Homes Standard (DHS) to the PRS must be implemented in a way that recognises the financial and logistical constraints within the sector.  

To prevent this, the NRLA recommends that the Government: 

• Clarifies MEES and EPC regulations as soon as possible so landlords can plan retrofitting work efficiently

• Ensures retrofitting work carried out since 2020 counts towards the cost cap, to encourage landlords to invest early

• Sets a realistic compliance timeline that allows landlords to apply for grants, organise work, and complete necessary improvements

• Provides transparent funding allocation for the Warm Homes Grant, ensuring landlords and tenants in the most energy-inefficient homes receive the support needed.

More information

To register for our webinar on Navigating regulatory reform: Campaigns update on the Renters’ Rights Bill and Energy Efficiency Standards click here.  

For more information on the NRLA’s ongoing energy efficiency campaign click here.   

For full details of the grant scheme click here.  

If you want to respond to the consultation on Minimum Energy Efficiency Standards (MEES) you can access our guide here.