24 Sep 2010
Fuel Poverty remains a huge concern across the island with growing numbers of people at risk of being unable to heat their homes. Recession is placing more people at risk of being unable to heat their homes. IPH welcomed DSD commitment to review the 2004 Strategy and the emphasis placed on public health impacts in the consultation, recommending that improving the health of fuel-poor householders is explicitly recognised as a key outcome of the new strategy.
Access the full IPH response below
Submission to the Fuel Poverty Strategy Team
Department for Social Development
Warmer Healthier Homes – Consultation on a new Fuel Poverty Strategy for Northern Ireland
Introduction
The Institute of Public Health in Ireland
The remit of the Institute of Public Health in Ireland (IPH) is to promote cooperation for public health between Northern Ireland and the Republic of Ireland in the areas of research and information, capacity building and policy advice. Our approach is to support both Departments of Health and their agencies in both jurisdictions, and maximise the benefits of all-island cooperation to achieve practical benefits for people in Northern Ireland and the Republic of Ireland.
IPH is currently represented on the Interdepartmental Group on Affordable Energy in the Republic of Ireland. Over the past year we have contributed to the development of a draft National Affordable Energy Strategy for the South. More recently we have also contributed to the consultation on the National Energy Retrofitting Scheme.
IPH has a keen interest in fuel poverty and the impact of fuel poverty on health and well-being. Our portfolio of work in this area includes evaluation of fuel poverty initiatives in Northern Ireland and the publication of policy papers and policy updates on fuel poverty and health. In 2009, IPH and University of Ulster developed a joint update report on fuel poverty and health.
Key points
• IPH welcomes the government’s commitment to review the 2004 fuel poverty strategy.
• We are greatly encouraged by the emphasis placed on the public health impacts of fuel poverty in the consultation document. Improving health outcomes should now be recognised as a core outcome from fuel poverty interventions, rather than as an additional or corollary benefit. We recommend that improving the health of fuel- poor householders is explicitly recognised as a key outcome of the new strategy. We especially welcome the commitment and investment made by the Public Health Agency to tackling fuel poverty in 2010/2011.
• Consideration might be given to agreeing a ‘basket’ of health and social indicators related to fuel poverty, including temperature-related mortality, improvements in air quality, referrals for fuel poverty related debt, numbers of disconnections, hospital admissions for cardiovascular and respiratory disease etc. We would welcome regular reporting on these indicators, in the context of the existing routinely published data on the prevalence of fuel poverty derived from the Northern Ireland Housing Conditions Survey. The Interdepartmental Group on Fuel Poverty and Fuel Poverty Advisory Group could consider how to capture information on the health and social impacts of fuel poverty by requesting inclusion of suitable variables within ongoing national surveys such as the NI continuous household survey etc, in consultation with the Central Survey Unit of Northern Ireland Statistics and Research Agency as appropriate.
• We accept that the new strategy must alter the approach to tackling fuel poverty according to available means, both in the light of rising levels of fuel poverty and economic downturn. However, we would encourage the Department to maintain the focus on eradicating fuel poverty in preference to the term ‘alleviate’.
• The short-term priority within the next strategy must be to equip fuel poor householders with the means to keep their homes warm enough this winter, in the context of the threats of unemployment and falls in incomes posed by economic downturn. The medium-term priority within the next strategy must be to reinvigorate efforts to provide householders with accessible, attractive and co-ordinated methods of improving the energy efficiency of their homes. As the levels of fuel poverty may now be near the 40% mark, consideration could be given to bringing all the retrofit schemes under a single national energy retrofitting scheme, similar to that under consultation in the Republic of Ireland, and in conjunction with the Northern Ireland Green New Deal proposals.
• The development of a severity index is welcome, in so far as it can perform at a level that it can effectively target resources to those most in need, at a time when resources are less plentiful. However, further consideration is needed on how to weigh-up the relative importance of the severity of fuel poverty experienced (severity index) and the impact on the household (vulnerability of the household). The interaction of these issues is fundamental if there is a need to target resources to tackling fuel poverty.
• The Cold Weather Payment has now been in operation for a few years and winter 2009/2010 would have necessitated a significant number of these payments. An evaluation of the effectiveness of this programme is therefore timely, including a cost-benefit analysis to determine whether this is in fact the best way to deliver additional help to vulnerable householders in severe cold.
• While the consultation document clearly states that government has no control over the fuel which heats 70% of homes in Northern Ireland, it offers little new direction in terms of how this issue might be tackled. The new strategy should include a detailed examination of the location, levels and severity of fuel poverty within oil-dependent homes. We suggest that simply restructuring payment options and exploring social responsibility with oil suppliers is not a sufficient response. We would welcome a more robust approach to reducing oil dependency and tackling fuel poverty in oil-dependent homes, within the new strategy. As oil-dependent and fuel-poor, as well as income-poor, homes are concentrated in border counties, a joint focused cross-border fuel poverty programme would seem reasonable, coordinating and capitalising on relevant schemes in the Republic of Ireland.
• The approach to improving the thermal comfort in the private rented sector seems vague. There is no clear direction on how fuel poverty experienced by private tenants will be tackled in the future. The proposed implementation date of 2015 for the new fitness standard does not represent an adequate response to the current crisis in fuel poverty in Northern Ireland. Consideration might be given to setting a target for SAP ratings in private rented accommodation, as part of the proposed fitness standard. We would welcome greater clarity on the means offered to incentivise landlords as well as tenants to improve energy efficiency.
