Eligibility Criteria for Fuel Poverty Programmes

Introduction

Eligibility criteria function to:

  • direct finite resources to where they are most needed
  • determine what resources to allocate to each case - this might be related to the size of the need, or the difficulties involved, either to the client or the agency, in meeting it
  • decide which cases should have priority - this is usually based on a judgement about susceptibility, the amount of harm which would be caused by delay in meeting the need.

Where energy efficiency is the objective, "need" is assessed through the heating and insulation standards of the dwelling, with SAP rating as a generally accepted measure.

Where fuel poverty alleviation is the objective, additional difficulties arise since fuel poverty is complex and expensive to measure accurately. Consequently a proxy is often used, such as receipt of means-tested benefits.

Requirements for Eligibility Criteria

Eligibility criteria need to be:

  • Valid – that when assessment is done, the criteria measure what they are supposed to measure either directly, or as a proxy. Where a proxy is used, there must be a strong likelihood that it will provide equivalent results to a more sophisticated approach.
  • Reliable – that they give the same result on different occasions
  • Practicable – that they are simple and inexpensive to apply
  • Equitable – that those most likely to be in need, or vulnerable to harm, are also those most likely to meet the criteria.
  • Outcome-efficient – they lead to a significant difference for the investment made, and in this sense eligibility criteria should be firmly linked to the objectives of the scheme.

Therefore, the key questions for fuel poverty work are:

  • Should eligibility be based on the energy efficiency of the home, the household’s means, the household’s susceptibility or a combination?
  • Should there be different eligibilities giving entitlement to different measures (e.g. “hard to heat homes” or “vulnerable households” eligible for larger spends)
  • Should eligibility be “stepped”, for example by being free to low-income households; discounted for middle-income households; and unsubsidised for those on higher incomes.

Existing programmes and the way forward

The two main energy efficiency programmes in England are Warm Front and the Energy Efficiency Commitment. Whilst Warm Front is exclusively directed to disadvantaged private sector householders (using age, disability and low income as eligibility criteria for, generally, 100% grants), Energy Efficiency Commitment funding covers all tenures and income groups with variable levels of grant and subsidy depending on household means. The pilot Warm Zones have generally followed the criteria of the two major schemes although, in one case, a Warm Zone has been able to use supplementary funding to fill in gaps where fuel-poor households did not meet eligibility criteria.

Whilst no existing scheme meets all five of the requirements outlined above it is possible to construct eligibility criteria that are:

  • valid in identifying those in, or at risk of, fuel poverty
  • reliable and practicable in application
  • efficient and equitable in their outcome

The criteria for such a scheme might look like those in the table below. The details are obviously subject to debate, and the model should be regarded not as a recommendation but as an illustration of the issues involved. This type of model would work best under a national integrated scheme with both hard and soft measures components:

Possible scheme eligibility model  % Income to meet required fuel costs [**or benefit]
SAP rating greater than 20%** 10-20%** 7.5-10%** 5-7.4% less than 5%
less than 30enhancedenhancedstandardstandard75% discount
31-45enhancedenhancedstandard75% discount50% discount
46-60standardstandard75% discount50% discount25% discount
Greater than 60standardstandard50% discount25% discountinfo only

Energy Efficiency Measures
Enhanced = As “standard” but higher cost-ceiling package [always offered to “vulnerable” households]. An alternative would be to have a flexible ceiling spend
Standard = offer no-cost flexible energy efficiency packages (plus other measures)
Discount = offer package at a substantial discount, possibly stepped
info only = give information about schemes, and what householder could do at what cost with what benefit

Financial and tariff advice: Always offer if prima facie need identified (eg prepayment meter, eligibility for social tariff, etc) with priority to fuel poor households.

Under-occupancy: Offer package if still in fuel poverty after all measures done and households in under-occupancy.

Energy advice: Always offer targeted energy advice to household, fuel poor or not.

Conclusion

NEA recognises that all existing schemes are making a valuable contribution to fuel poverty elimination. However, evidence (from a number of research projects, and operational data from Warm Front and Warm Zones) shows that their eligibility criteria limit their effectiveness. The forthcoming reviews of Warm Front and the operation of EEC are welcomed, and it is recommended that the opportunity be taken to optimise their focus on households in or at risk of fuel poverty, prioritised to vulnerable groups and enhanced in the case of the homes with the poorest energy efficiency.

Published January 2003