Tackling Fuel Poverty in Wales – a different road?

On 30th September the Government in Wales published its 'Tackling Fuel Poverty 2020 -2035' consultation in which it outlines its plans to take households out of fuel poverty.

In the foreword Lesley Griffith AC/AM states “It is clear to me further action is needed to lift people living on lower incomes out of poverty in all its forms and to safeguard against poverty in the future. This draft plan sets out clearly what we are seeking to achieve and how we are proposing to proactively support people to secure a better deal from the energy market, provide support to improve their home energy efficiency, support the decarbonisation agenda and make the best use of newer technologies to help maintain a safe and secure home environment.”

The consultation includes useful data relating to fuel poverty in Wales such as:

  • Between 2008 and 2018 the number of households in fuel poverty halved
  • 10% of households are in fuel poverty (i.e. they spend more than 10% of their income on heating, and 2% are in severe fuel poverty and spend more than 20%.)
  • Half the households in fuel poverty are single occupants
  • The biggest problems are in central and west wales

The report makes clear  that fuel poverty has three drivers:

  1. The cost of energy
  2. Household income
  3. The energy efficiency of homes

The area of most interest to Elmhurst Members in Wales is that whilst it is proposed SAP and EPCs will continue to be the basis of the survey, future improvements will focus on energy demand from just heating in the belief that this can be measured after improvements have been made to ensure effectiveness. The proposal aims to achieve a 21%, and not less than a 15%, reduction in energy used for heating in welsh homes.


Para 59. Energy Efficiency – The Standard Assessment Procedure (SAP) is the methodology used by the Government to assess and compare the energy and environmental performance of homes. Its purpose is to provide an accurate and reliable assessment of home energy performance. This assessment process underpins energy and environmental policy initiatives. Using the SAP methodology, homes are given an Energy Performance Certificate (EPC). The SAP methodology will continue to provide the basis of the Welsh Housing Conditions Survey (WHCS).

Para 60.The Welsh Government is proposing future schemes designed to improve home energy efficiency as part of our efforts to tackle fuel poverty should aim to achieve a 21% , and not less than a 15% reduction in energy used for heating. A reduction of KWh achieved will enable more accurate measurements to be taken once housing retrofit has taken place. This in turn will translate into SAP and EPC improvements secured through our continued investment, based on actual measurements and not modelled estimates.

Elmhurst will be studying the proposal carefully but at first reading this does appear to be a move away from the rest of the UK who are using EPC band C as the target, but actually it does align with Elmhurst’s own view of the future and we believe that this will be good news for Elmhurst Members.

Response to proposal

We would make four points:

  1. Energy efficiency can be expressed in three different ways:
    • cost – how much people pay for the energy to power their home
    • energy – how much energy people use to live safety
    • carbon – the amount of carbon that is released to provide that energy.

    And each of these measure are already calculated by SAP and should be given full and equal prominence on the EPC. Refer to Elmhurst article in Feb 2020.

    1. Contrary to the consultation proposal it cannot be assumed that reducing energy (kwh) on its own, will reduce costs and alleviate fuel poverty. In fact, using current assumptions, reducing energy demand by 21% and moving from gas to “low carbon” electric will actually increase costs and move more people into fuel poverty.
    • Measuring energy consumption may appear to be straightforward but will be affected by other variables, such as a changes in the weather, it could be misleading and rarely comparable with modelled estimates. Elmhurst believe it is better to focus on the improvement in the building fabric (known as the Heat Transfer Coefficient) which using temperature data and smart meter data can now be measured to get a fair comparison between homes and a direct comparison with the SAP and PHPP outputs. See article from Wood Knowledge Wales.
    • The final point is that we believe that energy consumption, using each of the three metrics stated above, should be presented for the ‘asset’, the ‘occupant’ and then ‘measured’.
        • The asset is a prediction of energy consumption based upon standard occupancy related to floor area that allows a prospective occupier to compare one property with another in a consistent way. The current EPC is an asset rating and the EPC Rating based on cost, although the certificate does also state energy and carbon too.
        • The occupancy assessment uses the same SAP methodology but alters the demand for heating, hot water and lighting to take account of the needs of the known occupier(s). This is a prediction of actual energy use in terms of cost, energy or carbon.
        • The measured performance closes the loop. It compares the actual energy used with that predicted at the occupancy assessment and provides the true energy efficiency performance of the dwelling in terms of cost, energy or carbon. See Elmhurst article form June 2020.

      This leads us to our only two criticisms of the proposal. It infers that:

      • energy used in heating is the only energy that matters. In our view energy used for lighting and hot water is just as important and, especially as home get built to higher speciation, hot water costs can become the most significant costs.
      • measurement is superior to modelled estimates, which is of course true. What is also obvious is that unless you model improvements, using a methodology such as SAP,  it is not possible to know what improvements might be most effective.

      Summary of Elmhurst's views

      Elmhurst’s Managing Director Martyn Reed summarises our initial views by welcoming the consultation and a fresh look at managing fuel poverty but has some concern about disregarding the EPC cost band too readily. In our view;

      1. All planned retrofit must start with a modelled estimate of improvements and savings
      2. SAP and RdSAP can give you more than an asset rating, using established processes it can also predict energy based on the occupancy of the asset
      3. SAP and RdSAP are more than just cost and we should use their calculations of energy demand and carbon as well
      4. Measurement is needed to “close the loop” and identify where the intended outcomes have not been achieved and understand what to do, e.g. was it the fabric improvement that failed, was it occupant behaviour, was it excessive cold weather etc.

      Consultation response deadline 

      Consultation response are required by 31st December 2020. As always Elmhurst will reply on behalf our members, we will issue a draft response, asking for opinions and incorporate them into our final response to Welsh Government.

      Read and respond to the consultation.

      Article published 13th October

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