Consultation Responses

Response to consultation on the UK Government’s draft Fuel Poverty Strategy for England – September 2019

Fuel Poverty Action’s response to the UK Government’s long-awaited draft Fuel Poverty Strategy for England. We do not engage with the definition of fuel poverty proposed. Instead, we propose a strategy based on high standards for all, as opposed to ever-increasing means-testing; adequate incomes as opposed to cuts in benefits, pensions and wages; support for genuinely renewable energy and community energy programmes; street by street insulation programmes; and tariffs that promise security for those least able to pay. We believe the draft Strategy fails to address the ways in which many specific government policies force up energy prices or bring down incomes and housing standards.

“Sustainable infrastructure” — housing and heating Examination of the London Plan – 29 March 2019

Fuel Poverty Action were glad to be invited to take part in the session on Sustainable Infrastructure, on 29 March 2019.  The discussion took for granted the seriousness of the climate crisis and a determination to decarbonise. Its particular focus was on heating — one of the hardest areas to make green — and within that, the focus was largely on the Mayor’s favoured option: District Heating.

The EiP assembled formidable expertise, hearing from representatives  of the DH industry, architecture, planning, and energy consultancies. Yet there had clearly been no process for engaging grassroots participants, and no expectation that DH users’ experience would be relevant to policy decisions, at the EiP stage, or earlier.  

Response to London Plan Matter M67 – Sustainable Infrastructure – January 2019

Response to BEIS consultation, Heat networks: ensuring sustained investment and protecting consumers -January 2019

Response to consultation on the UK Government green paper – “A new deal for social housing” – November 2018

Evidence to Household, Communities and Local Government  Leasehold Reform Inquiry  -September 2018

Response to Drax Power Station Proposal – August 2018
Drax power station has applied to the Planning Inspectorate for permission to replace its two remaining coal-fired units with much larger ones burning fossil (natural) gas.

Response to new Energy Company Obligation proposalsJuly 2018
The government has published proposals for the ECO (Energy Company Obligation) scheme due to come to force in October. We think that the proposals, by excluding oil, risk the lives of rural residents.

Fuel Poverty Action’s response to the 2018 Draft New London PlanMarch 2018

Minimum Energy Efficiency Standards (MEES) in Private Sector housing: FPA response to BEIS consultation – March 2018

Response to Heat Networks Market Study Statement of Scope January 2018

Response to ‘Housing for the many, Labour’s review of social housing’ – January 2018

In September 2017 the Labour Party announced a call for evidence as part of its social housing review. We produced a response which focuses on the importance of adequate heating and efficiency measures to address Fuel Poverty among social housing tenants.  Recommendations include: increasing minimum energy performance standards with supportive infrastructure investment, re-committing to the Zero Carbon Homes policy, increased regulation of District Heating Networks, and meaningful consultation for residents on regeneration/demolitions.

The Mayor’s draft London Environment Strategy – November 2017

We respect the scope of the Mayor’s draft Environment Strategy and the depth of work that has gone into it. Being of limited resource, we could only comment on a few areas, but appreciated the inclusion of, for instance, air quality, the effects of rising temperatures in the city, and the big questions around supply of electricity and gas on a national level. We instead focused our response on retrofitting for energy efficiency (and how this should be implemented on an area or community basis), district heating and the enforcement of standards, and the specifics of the Mayor’s plans for an Energy for Londoners company. In fact, the day before the consultation closed, we joined Switched on London to Take Back City Hall and demand that Sadiq Khan hold true to his promise for a fully licensed, democratic and affordable public energy company for London, which also invests in renewable infrastructure.

The Mayor’s draft Fuel Poverty Action Plan for London – November 2017

In London, the draft Fuel Poverty Action Plan document estimates 1,300 – 4,000 such deaths between 2011 and 2016 — totally unacceptable tragedies taking place all around us, in a city with great wealth. Many thousands more suffer ill health and lasting damage to their education, work, prospects and relationships. We are therefore very glad to see an action plan on fuel poverty for London. In our response, we found much to welcome, including plans for stronger enforcement in the private rented sector, direct investment in energy efficiency measures, and targeted lobbying of central government, but took issue with, for example, the Mayor’s position on estate regeneration.

Ofgem Consultation on Safeguarding Cap November 2017

In the context of multiple u-turns by the Tory government on the implementation of a universal cap on energy tariffs, Ofgem brought a proposal to institute a limited cap for some ‘vulnerable’ customers, as determined by their receipt of the Warm Homes Discount. With the exception of a core group, the money available to fund this payment for the 2 million households eligible is limited, and distributed on a first-come-first-served basis. More than a million people are therefore arbitrarily excluded from the WHD, and will, as a consequence, also lose out on an absolutely vital cap on their energy tariffs. We argue first that Ofgem should attempt a universal cap despite the difficulties they might face in implementing it, and then that should a limited cap be instituted, it can and should be extended much further than proposed, without delay.

GLA Estate Regeneration Consultation March 2017

Between December 2016 and March 2017, Mayor of London Sadiq Khan put out a Draft Good Practice Guide to Estate Regeneration for consultation with civil society. We wrote a response highlighting the importance of seriously considering heating and energy efficiency in regeneration and refurbishment plans, and citing multiple examples of where both have been overlooked with serious consequences.

Coal phase-out consultationFebruary 2017

In early 2017 the UK Government put out a consultation called “Coal generation in Great Britain: The pathway to a low carbon future”, essentially about the timeline for phasing out the use of coal for electricity production in this country. The Coal Action Network coordinated a series of responses from organisations in the UK, as well as Colombia and Russia, where much of our coal is imported from (and where the conditions of its production are incredibly poor). For our part, we emphasise the role energy efficiency must play in reducing the overall demand for electricity, rather than assuming that all coal-based capacity must be replaced by other forms of generation – an assumption that plays into the Government’s plan to see fracking take off in the UK. We also discuss how the increasing number of homes built with electric heating not only increases demand but simultaneously forces more people into fuel poverty.

City for All LondonersDecember 2016

In December 2016 Sadiq Khan’s office published a “new vision for London” called A City for All Londoners. It outlines changes City Hall plans to make over Khan’s four year term. We produced a response acknowledging some of the positive commitments on energy efficiency pegged out in this document, but also raised three requirements without which fuel poverty can continue unhindered; a public energy company for London, as demanded by the Switched on London campaign; no prepayment meters installed as default in new housing (social or otherwise); and serious consideration of the role of heat networks in decarbonising heat without disadvantaging people on estates where being part of a district heating heat network is the only option: it should instead provide less expensive, cleaner, heat.

CMA Proposal on Prepayment Meter Tariffs November 2016

In October 2016 the Competition and Markets Authority (CMA) announced plans to impose a cap on the price of energy for prepayment meter (PPM) customers, who get a raw deal compared to often more financial secure folks paying by direct debit. A version of this came into force in April 2017, saving PPM customers about £80 on average, and we got on TV to make the point that this was wholly insufficient. We represented as much to the CMA at the time, preparing a response reaffirming the plight of PPM customers, endorsed by 17 other organisations, and including a number of testimonies submitted to us about the real life results of PPMs. We even presented it to them at their offices in Holborn, telling them “Your cap doesn’t fit” and wielding banners reminding them that “Cold Homes Kill!”. The fight continues.

Heat Network Investment Project (HNIP) ConsultationAugust 2016

The HNIP is being undertaken by the Heat Network Development Unit (HNDU) at DBEIS (Department for Business, Energy and Industrial Strategy) as a way to bolster the creation of new heat networks, also known as district heating systems. It includes making £300mn available in the form of grants and credit to actors interesting in building this new infrastructure. Our response argued against the assumptions in which the project is grounded (that the market is supreme and private capital should be responsible for the majority of new projects) and provided detailed evidence of how seriously poorly managed heat networks can affect peoples’ lives, based on our work with residents at the Myatts Field estates in south London. Many social housing tenants there are locked into a 40 year contract with EON, who are failing to deliver on basic aspects of the service. However, we also recognise that heat networks could be a functional means of decarbonising heat provision in the UK, which is a vital step in reducing carbon emissions and combating climate change; this is exactly why they must be done right.