16 Sep 2010
In 2011, the National Energy Retrofit Programme will build upon existing energy saving programmes in both the domestic and non-domestic sectors. This consultation focused on key design considerations. IPH agree with the commitment to deliver a National Energy Retrofit Programme as a sustainable means of securing energy savings and reducing energy poverty and the nations carbon footprint. The IPH response highlighted the significant benefit to health and would support the use of Health Impact Assessment to consider these impacts within the development and evaluation of the Programme.
Access the full IPH response below
Submission to theDepartment of Communications, Energy and Natural Resources – National Energy Retrofit Programme
The Institute of Public Health in Ireland
The Institute of Public Health in Ireland (IPH) is an all-island body which aims to improve health in Ireland, by working to combat health inequalities and influence public policies in favour of health. The Institute promotes co-operation in research, training, information and policy in order to contribute to policies which tackle inequalities in health.
IPH is represented on the Interdepartmental Group on Affordable Energy and has contributed to the development of the National Affordable Energy Strategy.
IPH has a keen interest in fuel poverty and the impact of fuel poverty on health and well-being. Our portfolio of work in the area includes evaluation of fuel poverty initiatives in Northern Ireland and the publication of policy papers and policy updates on fuel poverty and health.
• We welcome the government’s commitment to deliver a National Energy Retrofit Programme as a sustainable means of securing energy savings and reducing energy poverty and the nation’s carbon footprint.
• In addition to the significant environmental and societal benefits identified in the consultation document, we would like to add that there is a significant benefit to health, as detailed in the attached All-Ireland Policy Paper on fuel poverty and health and Update documents. In this regard, we would support the use of Health Impact Assessment as a methodology to consider these impacts within the development and evaluation of the National Retrofit Programme.
• We support the ring-fencing of a percentage of programme funding for addressing energy poverty. We trust that this figure has been reached based on an analysis of the extent and nature of energy poverty, as detailed in the draft Energy Affordability Strategy. We recommend that when the programme is being reviewed in 2013, the impact of the programme on energy poverty, and the proportion of the programme funds dedicated to energy poverty, should be conducted, in consultation with the Interdepartmental Group on Affordable Energy and other stakeholders, including the Energy Poverty Coalition.
• In addition to a target for energy efficiency savings, we would welcome the inclusion of a target for the reduction of energy poverty specific to the National Retrofit Programme.
• We recommend that procedures and networks be fostered and maintained to facilitate co-ordination and cohesion in the implementation of the National Retrofit Programme, the National Energy Efficiency Action Plan and the National Energy Affordable Energy Strategy.
• In addition to supporting the development of green loans in major banks, offering interest-free green loans through the credit-unions or appropriate charitable/community organisations can also benefit low-income customers and those with unattractive credit-ratings. Consideration might be given to ring-fencing a certain proportion of green funds for vulnerable groups, especially the working poor, who may not be eligible for 100% funding.
• We support placing the BER at the centre of the programme. In this regard we would consider that the priority should be on increasing the BER of the lowest scoring properties. As these properties are more likely to be in fuel poverty and the residents are also more likely to be in income poverty, this would be one way of skewing the programme towards low income housing.
• Interaction with the private rented sector in terms of incentivising landlords (i.e. as well as homeowners) will form an important part of tackling energy poverty through this programme. As there is no consideration of this in the consultation document, we would welcome further information on how this might be handled.
• We would suggest that an ongoing programme of evaluation would be preferable to conducting a review several years into the programme. It may be beneficial to consider fostering strategic research alliances with appropriate academic and other relevant institutions to support the research and evaluation element of the programme.
• Specific areas under the programme that we feel should be addressed at the seminars/workshops include (a) identifying mechanisms to source and incentivise energy poor households (b) identifying and promoting the health, financial and social benefits of retrofitting your house (c) the National Retrofit Programme – landlords and tenants.