EBR response to One Nation Labour’s Energy Efficiency Green Paper

December 17th, 2014

An end to cold homes: 

One Nation Labour’s plans for energy efficiency


The Energy Bill Revolution campaign welcomes the chance to respond to Labour’s consultation paper on cold homes and energy efficiency.  It contains a number of welcome proposals, including:

  • A focus on all low income households, not just those that are currently fuel poor.
  • A commitment to improve homes treated to Energy Performance Certificate (EPC) Band C.
  • A requirement on landlords to improve homes that they rent out to the same standard.
  • The designation of energy efficiency as a national infrastructure priority.

However, despite these steps forward, the proposals are not as ambitious as they need to be if we are to tackle fuel poverty in a reasonable timescale.  Given the misery cold homes bring, we believe a Labour Government should complete the programme set out in this document far more quickly.  Work for the Energy Bill Revolution has shown it could be achieved in 10 years.

The paper proposes to end the cold homes scandal by bringing all 6 million low income households up to EPC Band C by 2030.  To put this in perspective, the next Parliament begins 15 years after the Warm Home and Energy Conservation Act 2000 became law.  That law was passed with all party support and aimed to end fuel poverty in 15 years.  So, 15 years after passing a law to end cold homes in 15 years, Labour could be promising it will take another 15 years to really end the problem.

Worryingly however, it is not clear even the proposed 2030 date could be met by the policies in the paper.  Around 6 million low income homes in the UK are EPC Band D or worse.  Roughly 1.4m of these are in the Private Rented Sector (PRS), so would be improved by their owners.  The remaining 4.6m homes would be brought up to Band C through a proposed programme assisting 200,000 households a year from 2017.  At this rate it would take until 2040, not 2030, to complete the programme.

Finally, the policy rightly says energy efficiency should be an “infrastructure priority”.  Yet no additional support is committed beyond the current ECO budget (approx. £0.9bn/yr).  Unless resources are reallocated to the project, describing it as a priority is meaningless.

The Energy Bill Revolution believes that the policy should aim to bring all 6 million low income households up to EPC Band C by 2025, with an interim target of ensuring 2 million households are helped in the first Parliament (by 2020).  Our research has found that an extra £3 billion investment would be needed in the next Parliament in order to meet the interim target.  This represents just 3% of expected Government infrastructure spending in that Parliament – a very realistic sum for something Labour accepts is an “infrastructure priority”.  Our research also finds huge economic benefits from the programme, which actually result in net gains to the Treasury.

Below we have summarised our response to the key specific questions contained in the consultation.


Q1: Do you think that other incentives, measures or publicity will be needed in order to raise awareness about potential savings from energy efficiency improvements?

Yes – Ministers must highlight energy efficiency as the key long-term solution to cold homes.  Recent debate has convinced many that the UK has high energy prices when unit costs are low compared to other countries.  UK bills are high because of high levels of fuel usage in inefficient homes.

Q4: How can we best manage the transition from the existing energy efficiency framework to the policies in this Green Paper, in order to minimise disruption to consumers and industry?

The new programme should be run alongside the existing ECO programme, which is expected to run out of steam before the 2017 end date. This would increase investment in energy efficiency for low income households and help 2 million low income households reach EPC Band C by 2020.

Q6: Do you think that low-income households living in properties with an EPC D or lower is a suitable proxy for households in or at risk of fuel poverty?

Yes – it is the condition of the house that is essential.  Incomes vary as people get or lose jobs, so targeting those who are fuel poor at any one moment is difficult.  Improving the worst homes avoids over-complicated targeting and means that future occupants are protected from high fuel prices.

Q10: How can we best use government energy efficiency schemes to bring in other investment and boost economic development and regeneration?

Our research has shown that improving homes has multiple benefits, creating jobs and economic growth; reducing pressure on health services; improving energy security and reducing carbon emissions as well as lower fuel bills and warm, healthy homes for all consumers.  Coordination with Labour’s job policies for the long term unemployed is vital.

Q11: Do you support moving from a single-measures approach to whole house retrofits?

Yes.  Research by ACE has found low income households receiving an average of just 1.2 measures under ECO, when an average of 3.1 measures is needed to reach EPC Band C.  ECO has therefore left people in fuel poverty or just lifted them out of it, only to fall back into it again when prices rise.

Q12: Do you think EPC C is an appropriate target for whole house retrofits?

Yes.  Improving low income households to meet Band C would remove 890,000 households from fuel poverty, whereas a Band D target would only remove around 240,000 homes.  Consideration should be given to ensuring F and G rated properties are treated early in the programme.

Q19: Do you support a new target on landlords to improve all properties in the private rented sector up to EPC C by 2027?

We agree all such homes should reach Band C, however the date should be brought forward to no later than 2025, so that no low income household is living in a home lower than Band C by that date.  We would also like further requirements on some landlords to improve homes to EPC Band C level well in advance of the final date to avoid a last minute rush.

Q21: In what ways could energy efficiency benefit from being a national infrastructure priority?

We welcome the recognition that an efficient housing stock is a vital part of the UK’s infrastructure.  However, energy efficiency will only benefit from being designated a national infrastructure priority if this leads to additional funds being available to increase the speed at which the UK housing stock can be improved.  Unless this happens, calling this programme a priority is meaningless.


For further details, contact Martyn Williams, Head of Parliamentary Campaigns, Energy Bill Revolution

 e:martyn@energybillrevolution.org                          m:O7712 843221


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The Energy Bill Revolution is an alliance campaign coordinated by Transform UK, a programme of the sustainable development organisation E3G. Transform UK works to build alliances to accelerate investment into the low carbon economy in the most socially just way.