CIH Northern Ireland response to DAERA Climate Action Plan

Agree

Reasoning and alternatives:

CIH Northern Ireland broadly agrees with the proposed policies and proposals aimed at reducing emissions within the energy production and supply sector, recognising the fundamental importance of moving towards a decarbonised energy system. We particularly welcome the strong performance to date in increasing renewable energy generation within Northern Ireland. This commitment to, and progress in, renewables represents the correct path forward for achieving a sustainable energy future and meeting our climate targets.

However, for these policies to be truly effective, several critical considerations must be addressed, drawing upon our expertise in housing:

• Energy security and grid modernisation: While the shift to renewables is vital for emissions reduction, it introduces new challenges related to grid stability and security of supply. (We also note with concern that the proportion of electricity generation from renewables on the NI grid has reduced in recent years, stressing the need for more urgent, sustained action.) Although a significant part of the Great Britain (GB) grid’s baseload is still provided by fossil fuel sources, recent Westminster government decisions confirming significant investment in nuclear power is likely to see an increasing proportion of this baseload provided by nuclear. Without an equivalent, the future security of the island of Ireland’s grid in a highly renewable-dependent system requires clear, detailed planning. The Climate Action Plan notes the need to ensure security of supply; we urge the Executive to provide more explicit detail on strategies for ensuring grid resilience, especially given the increasing electrification of heat and transport. This includes accelerating investment in smart grid technologies, energy storage solutions, and considering the potential for flexible demand management to balance intermittent renewable generation. Learning from international good practices in managing high penetrations of renewables, as well as exploring all viable low-carbon, dispatchable power options, will be essential to ensure a robust and reliable supply for all homes.
• Financial incentives for solar photovoltaic (PV) across all tenures: The uptake of rooftop solar PV can significantly contribute to decentralised energy generation, reduce overall demand on the centralised grid, and provide an important power source when wind generation is low. Furthermore, micro-generation from PV can help to offset the higher annual electricity costs currently associated with the operation of heat pumps, relative to an efficient gas boiler. While incentives exist, the current framework often disproportionately benefits those who can afford the initial capital investment. Policies must be developed to unlock the potential of solar PV across all tenures, including private and social rented homes, by offering specific financial incentives, including mechanisms for micro-generation. Crucially, this funding must address the 'split incentive' problem where the landlord pays the upfront capital cost but the tenant benefits from lower energy bills. This could include innovative financing models, landlord incentives, and streamlined planning processes for installations (as per our response to the call for evidence on a Strategic Planning Policy Statement (SPPS) review concerning the issue of climate change).
• Role of social housing in local energy systems: Social housing providers manage significant portfolios of homes and have the potential to play a crucial role in developing local energy solutions. This could include exploring and implementing district heating networks powered by low-carbon sources, communal solar PV arrays, and smart energy management systems across their estates. These initiatives can contribute to decentralised energy production, reduce reliance on the wider grid, and provide stable, affordable heat and power to communities. Investing in these models also contributes to the ‘enabling the transition to net zero’ and ‘investing in climate action’ objectives of the plan.

In conclusion, we support the proposed policies for reducing emissions in the energy production and supply sector, particularly the strong focus on increasing renewables. To ensure effective delivery, it is imperative to strengthen strategies around grid security and modernisation to guarantee a reliable energy supply for all homes, alongside actively promoting decentralised energy generation, such as solar PV across all tenures with appropriate financial mechanisms, and leveraging the social housing sector's capacity to develop local energy solutions. By addressing these areas, Northern Ireland can accelerate its emissions reduction targets within this vital sector.

Neither agree nor disagree

Reasoning and alternatives:

CIH Northern Ireland supports the intent behind the proposed approach to achieving a just transition in the energy production and supply sector, recognising the critical importance of ensuring that the benefits of energy decarbonisation are shared equitably and that no household is left behind. We welcome the consultation's explicit recognition that the transition must consider its impact on all consumers, especially the most vulnerable, and the Energy Strategy's principle of focusing on affordability and fairness.

Crucially, we note that the most vulnerable in society, including those on lower incomes, are often less able to shift their electricity demand (e.g. to off-peak times) or benefit from being able to invest in or access new technologies like electric vehicles and solar PV. This limited capacity to engage means that without proactive intervention, the costs and burdens of the transition will disproportionately fall on them, while the benefits accrue to others.

To ensure this transition is truly just, fair and effective in practice, we believe the approach needs to be significantly strengthened, particularly concerning the financing model and the depth of commitment to ensuring truly equitable access and affordable supply for all.

• The critical role of progressive funding: While the plan acknowledges the need for affordability and fairness, it does not explicitly articulate a principle of progressive funding for the substantial investments required to decarbonise our energy system. Given that vulnerable households have less capacity to mitigate costs or engage in new market mechanisms, we assert that it is imperative that the costs of this transition are not disproportionately loaded onto standing energy charges, which can unfairly burden consumers on lower incomes. Instead, we strongly advocate for the principle of progressive funding, where the mechanisms for paying for the energy transition are explicitly designed to ensure that those with greater capacity contribute more. As highlighted in our response to the Department for Communities' consultation on the Draft Fuel Poverty Strategy, the introduction of a social energy tariff (or an alternative form of energy bill support) is an important example of such a progressive mechanism. This ensures that the inherent costs associated with the energy transition do not exacerbate fuel poverty for vulnerable households. A social tariff, alongside other targeted financial support measures, could significantly help in delivering a truly just transition, ensuring that the benefits of clean energy, such as improved health outcomes and warmer homes, are accessible and affordable for everyone, regardless of their income.
• Ensuring truly equitable access to benefits: The consultation discusses providing "equal opportunity to embrace this transition", which we welcome. To translate this into tangible outcomes, policies must actively unlock the potential of decentralised energy for all households. This means addressing current frameworks that disproportionately benefit those with upfront capital. Mechanisms such as fostering the uptake of solar PV across all tenures (as detailed in our response to question three) and actively leveraging the social housing sector's unique role in developing local energy solutions (also in question three) are crucial. These approaches ensure that benefits like reduced energy bills and increased energy independence are genuinely accessible to a diverse range of residents, including those in rented accommodation or social housing.
• Guaranteed reliable and affordable supply for all:A foundational element of a just transition is that all households have access to a reliable, secure and affordable energy supply. While the consultation notes the importance of energy infrastructure, the detailed strategies for ensuring grid stability and security of supply (as highlighted in our response to question three) are paramount. Any disruptions or increased underlying costs within the transforming energy system would disproportionately affect vulnerable households. A truly just transition must proactively guarantee the systemic reliability and affordability of the supply itself, beyond just protecting against global price shocks.
• Addressing the skills gap and behavioural change: We strongly agree with the consultation's emphasis on skills audits and the expansion of green skills, as well as the need for shifts in personal behaviours and engagement. These are vital enablers for a just transition, ensuring that local communities benefit from new job opportunities and that residents are supported to understand and effectively use new low-carbon technologies (as discussed further in our response to question 38).

In conclusion, we support the intent behind the proposed approach to achieving a just transition in the energy production and supply sector. However, for this to be fully realised, it is imperative to move beyond general principles to implement concrete policies that prioritise progressive and equitable funding mechanisms, with a social energy tariff (or alternative form of energy bill support) as a cornerstone. Furthermore, ensuring genuinely equitable access to the benefits of decentralised energy across all tenures and guaranteeing a systemically reliable and affordable energy supply for everyone will be essential to truly deliver a just transition that leaves no household behind in Northern Ireland's journey to net zero.

Agree

Reasoning and alternatives:

CIH Northern Ireland broadly agrees with the proposed policies and proposals to reduce emissions from the transport sector. As the second largest contributor to emissions in Northern Ireland, decisive action in this sector is critical for achieving our overall net zero targets. Our agreement is framed from the perspective of how transport policies directly impact the lives of residents, their access to services, and the decarbonisation of our homes and communities.

Key aspects of our agreement and their reasons include:

• Decarbonisation of road transport: We welcome the emphasis on reducing emissions from road transport, which includes the transition to cleaner vehicles. From a housing perspective, a significant part of this transition involves the provision of electric vehicle (EV) charging infrastructure for homes. However, policies must urgently address the specific logistical barriers associated with widespread EV uptake. It is crucial that the availability of charging points, particularly at residential properties, is prioritised and facilitated. This extends beyond public charging networks to ensuring that both new-build and existing homes (especially those in multi-unit dwellings, apartments, social housing estates, or areas with limited off-street or exclusively on-street parking) have readily accessible and affordable charging solutions. Policies should encourage, and where appropriate, mandate the inclusion of EV charging infrastructure in new residential developments and provide robust support for retrofit solutions for existing housing stock to ensure equitable access across all tenures and income levels. Furthermore, the transition to EV fleets will require detailed planning for suitable dedicated depots with adequate grid connection capacity, a point that must be addressed by relevant government and utility planning.
• Integrated land-use planning: As we detailed in our response to the SPPS call for evidence, the planning system has a crucial role to play in reducing transport emissions. We agree with the Climate Action Plan's recognition that the planning system can help to develop policies and places that bring homes and key services closer together. By promoting walkable, mixed-use developments and ensuring that new housing is well-connected to public transport networks, the planning system can significantly reduce the need for car journeys. Encouraging active travel modes not only reduces emissions but also contributes to improved public health and wellbeing within communities. This requires a strong alignment between transport and land-use planning policies.

Agree

We generally agree with proposed policies that seek to reduce emissions across the business and industrial processes sector, particularly where they enable the wider decarbonisation of the energy system, including for home heating.

From a CIH Northern Ireland perspective, our primary interest lies in the support for biomethane injection into the gas network. Northern Ireland has a relatively modern gas network, and for many existing homes connected to this infrastructure, displacing natural gas with biomethane offers a non-disruptive contribution to decarbonising heating, since it is chemically near identical to natural gas.

However, we stress the urgent need for clarity on the subsequent energy prices associated with gas network transformation. We note that natural gas is already significantly more expensive than oil in Northern Ireland, and any changes to the gas network to accommodate biomethane or hydrogen are likely to increase costs further. As long as these potential issues regarding billing changes, the overall affordability of the new gas supply, and the financial impact on consumers are identified and mitigated, biomethane could play a role in ensuring a just transition for residents by minimising upfront costs and disruption to their homes.

We re-emphasise that electrification of heat (e.g. heat pumps) remains the key long-term strategy for residential buildings, and reducing heat demand through insulation and fabric upgrades is foundational to affordable and sustainable heating, regardless of the fuel source. Therefore, any strategy involving biomethane for heating must be coupled with strong policies and funding for comprehensive energy efficiency improvements in homes.

Furthermore, policies should consider how to best allocate limited biomethane supplies to achieve the greatest overall carbon reduction impact across the economy. This could potentially mean prioritising industrial uses like high-temperature processes while heat pumps and other electric solutions are scaled for residential heating.

Finally, while biomethane offers immediate carbon reductions and allows valuable time for other low-carbon technologies to mature, and provides waste management benefits, a robust Northern Ireland-specific policy and financial support scheme, along with strategic planning for network upgrades, will be crucial to incentivise its investment and scale-up production to reliably reach homes.

Agree (with reservations)

CIH Northern Ireland agrees with the proposed policies and proposals aimed at reducing emissions from the residential buildings sector, whilst observing that a lack of progress on retrofit continues to hold back the overall net zero agenda. The residential buildings sector is a critical area for decarbonisation. The proposals outlined in the Draft Climate Action Plan, such as the focus on energy efficiency retrofits, the uptake of low-carbon heating, and the raising of building standards, align with our strategic priorities. 

However, we raise significant concern in relation to the viability and pace of delivery for capital spend, the lack of equitable financial support across all tenures, and the clarity surrounding new build standards and low-carbon heating, which risks undermining affordability.

Key aspects of our agreement and their reasons include:

• Focus on energy efficiency as foundational: We support the policies and proposals to enhance energy efficiency and reduce consumption. Reducing heat demand through insulation and fabric upgrades remains foundational to affordable and sustainable heating. It is essential to ensure financial support for low-carbon heating technologies is accompanied by incentives for building fabric upgrades – including loft, solid/cavity wall and floor insulation, and the critical factor of air tightness measures – to ensure long-term success and efficiency. Continued and increased investment in programmes that take a ‘fabric first’ approach and deliver deep retrofits across all tenures is crucial, and the current pace of progress in this area continues to hinder the achievement of net zero targets.
• Support for existing and proposed schemes: We endorse the continuation and enhancement of existing schemes like the Affordable Warmth Scheme and the Northern Ireland Sustainable Energy Programme (NISEP), and especially welcome the proposal for a new, more ambitious ‘Warm Healthy Homes Scheme’ and an energy efficiency programme incorporating a ‘one stop shop’ approach that simplifies processes and reduces complexity barriers. These are important for improving the energy efficiency of existing homes, particularly for fuel-poor households. Our Fuel Poverty Strategy response emphasised the need for such schemes to be comprehensive, adequately funded, and to adopt a ‘whole house’ approach to ensure maximum impact and lasting benefits.
• Support for heat pumps: We support the proposal for a low carbon heat support programme, and its focus on technologies that offer significant carbon savings and energy efficiency, particularly heat pumps. We believe that all domestic buildings should be eligible for low carbon heating technology support, with a tiered approach based on building efficiency. This ensures everyone can transition away from fossil fuels, regardless of their current housing tenure. Initially, higher levels of support would be directed towards buildings with lower EPC ratings (subject to necessary building fabric upgrades), while offering basic support for all installations. This incentivises energy efficiency upgrades while facilitating broad participation. All buildings will need to transition to low-carbon heating eventually.
• Acknowledging biomethane's potential: We note that biomethane injection into the gas network offers a compatible and non-disruptive contribution towards decarbonising existing gas-connected appliances and processes, offering potential for immediate carbon reductions in some homes. However, it is crucial that any potential issues regarding billing changes and the affordability of biomethane are identified and mitigated.
• Raising building standards: The commitment to further uplifts in Building Regulations for both new and existing homes is critical for future-proofing our homes. We advocate for mandatory energy efficiency standards for all new developments that exceed current minimum requirements, aiming for zero-carbon new developments. This will significantly reduce the environmental impact of new housing and prevent the creation of new ‘hard-to-decarbonise’ homes. We also support the introduction of Minimum Energy Efficiency Standards in the private rented sector – to address the poor housing conditions and high fuel poverty rates often found in this tenure – and we support the Northern Ireland Housing Executive (NIHE) revitalisation agenda to enable investment in NIHE homes. Access to finance to incentivise and/or facilitate upgrades remains crucial.
• Whole-system approach: The implicit recognition that effective policy requires a blend of financial incentives, regulatory standards and supporting infrastructure (e.g. grid upgrades, skilled workforce) is positive. It is vital that residential building policies are integrated within this broader energy system transformation.

Alternatives/additional considerations:

Whilst in agreement, we propose the following areas for further strengthening:

• Challenging the pace and viability of capital investment: We support the need for increased capital investment but challenge the viability of the projected funding increases and the emissions reduction assumptions. Specifically, the plan projects capital spend for new schemes by 2027, but states these schemes will only launch that year. It is not viable that almost £7 million in capital spend and assumed emissions reductions will be delivered within a few months. This spending and the associated carbon savings are more likely to fall into the next carbon budget period. Action is needed now to prepare for this uplift, as the construction and retrofit sector may not be able to deliver this scale of work without immediate preparatory investment in supply chain and skills development.
• Strengthening energy performance assessment and assurance: We believe a critical gap exists in the verification and assurance of a home's actual energy efficiency. The current Energy Performance Certificate (EPC) system, which relies on the SAP assessment, falls short of providing truly reliable data for the purpose of measuring energy performance. We believe that the homebuyer and tenant (social or private) have a right to be properly informed of the true energy efficiency of their home. Therefore, homes should be tested and commissioned as stand-alone units to verify their energy efficiency, including robust air tightness testing. Furthermore, the process for attaining an EPC needs an overhaul to introduce checks and balances, ensuring appropriate levels of training and external oversight.
• Accelerated Building Regulations implementation: It is important that changes to building regulations are timely and correctly implemented to support the journey to net zero. Clarity is needed on the future direction of new build standards given the previous assessment that a gas/solar PV solution was more viable than heat pumps in the last uplift.
• The lack of dedicated retrofit/decarbonisation funding for social landlords: As above, the long-term decarbonisation of a significant portion of homes is reliant on the revitalisation of NIHE and its ability to invest in widespread energy efficiency and heating upgrades across its properties. This requires sustained political will and adequate funding. Furthermore, there needs to be broader investment in energy efficiency funding schemes. We endorse the continuation and enhancement of existing schemes, but challenge the current exclusion of the social housing sector from key funding mechanisms. Housing associations for example are not eligible for schemes like Affordable Warmth, and the exclusion of social housing tenants from NISEP for 2025/26 is inequitable. Social housing tenants are paying Public Service Obligation (PSO) levies into a scheme from which they cannot benefit, which is directly at odds with the principles of a just transition. We urge the NI Executive to look at replicating dedicated grant-based funding, such as the Social Housing Decarbonisation Fund (and equivalents) used in Great Britain and Ireland, to avoid housing associations being forced to rely on non-viable options like commercial loans or unviable rent increases to finance essential upgrades.
• Tenure-neutral policies: While recognising the importance of social housing as a delivery mechanism, policies and funding should be designed to support decarbonisation across all tenures – owner-occupied, private rented and social – ensuring access to support based on the energy efficiency of the home.
• Support for heat pumps should be linked to affordability and fabric: We support the proposal for a low carbon heat support programme. However, the language around heat pump cost savings is potentially misleading and risks increasing fuel poverty.
  
  • Affordability challenge: Due to current energy pricing in NI, a heat pump installed in isolation without significant fabric upgrades and/or solar PV is likely to be more expensive to run than natural gas, and definitely more expensive than oil. With oil prices around c.5p/kWh, natural gas at c.8p/kWh, and electricity at c.31p/kWh, the current price differential acts as a major barrier, especially given that over 60 per cent of NI homes use heating oil.
  • Efficiency challenge: While heat pumps can and do operate with a Coefficient of Performance (COP) of 3-4, comprehensive reviews show that real-world operational COPs often average lower. Without immediate, sustained, and progressive action to reduce the price of electricity (e.g. by moving policy levies into taxation), heat pumps may not be affordable for the lowest-income households.
  • Any heat pump policy must be tiered and conditional: the highest support must be directed towards buildings with the best fabric and the lowest-income households to ensure the lowest running costs.
• Holistic heating solutions for diverse housing stock: While heat pumps are crucial, they may not be the optimal solution for all homes. Consideration also needs to be given to policies to support low-carbon heat networks and other forms of low-carbon heating, especially in high-density urban areas and communal blocks. This should be allied to the pledge in the energy strategy to take forward heat network trials and demonstrators. Further policy development is still needed that focusses on decarbonising existing heat networks and making them more efficient and affordable, as they should not come at the expense of affordability.
• Grid preparedness: A coordinated approach is needed to ensure the electricity grid can accommodate the growing demand for electricity from increased electrification, while minimising the risk of brownouts and blackouts.

In conclusion, while we agree with the overall ambition for energy efficiency and low-carbon heating, effective delivery is contingent on addressing the significant financial and systemic barriers identified. This requires accelerating the actual pace of retrofit rollout, ensuring dedicated and equitable long-term funding, achieving a fair rebalancing of energy costs, and providing clear policy direction on new build and low-carbon heating that puts affordability for the lowest-income residents first.

Agree (with caveats)

CIH Northern Ireland agrees with the proposed approach to achieving a transition that is just and equitable in the residential buildings sector. A just transition is fundamental to our core values, ensuring that the burden of decarbonisation does not disproportionately fall on the most vulnerable people and that everyone can benefit from warm and healthy zero-carbon homes. Our agreement stems from these key aspects:

• Underpinning principle of just transition: We strongly endorse the commitment that any current or proposed intervention will be underpinned by the just transition principle, recognising it as a key consideration for government policy decisions.
• Prioritising vulnerable households and addressing fuel poverty: We welcome the emphasis on supporting low-income households through existing schemes like the Affordable Warmth Scheme and the guiding principles of the DfC Fuel Poverty Strategy. However, as detailed in our response to question nine, the current structure and economics of the NI energy market pose a major challenge to the affordability of low-carbon heating, especially for vulnerable households. The cost of electricity (at c.31p/kWh) is disproportionately high compared to oil (c.5p/kWh) and gas (c.8p/kWh). This means that without comprehensive fabric upgrades and urgent, progressive action to rebalance energy levies and reduce the running cost of electricity, installing a heat pump risks increasing heating bills, which directly undermines the principle of a just transition. Targeted energy bill support, such as discounted electricity tariffs (as discussed in question three), should also be considered to ensure affordability for all.
• Comprehensive scheme design: We endorse the anticipated role of the proposed ‘Warm Healthy Homes Scheme’ in supporting the just transition principle by assisting those most at risk. Improving the energy efficiency of homes or installing renewable generating technologies is key to mitigating potentially higher running costs of low-carbon heating systems compared to fossil fuels. The recognition that investment across building fabric, heating systems and controls is needed, with broad access for all, is also crucial. As discussed in question nine, the funding landscape for social housing must also be addressed.
• Support for understanding and use of technologies: We agree that support is needed to enable everyone to understand, use and maximise the benefits of sometimes unfamiliar technologies, standards and products introduced into their homes. The continued operation of the NIHE residential energy efficiency advice service and the development of an ‘energy one stop shop’ are positive steps towards this.
• Role of social housing providers: We welcome the acknowledgement of housing associations’ ongoing programmes of maintenance and retrofitting to deliver energy efficiency measures. Social housing providers are critical in demonstrating leadership and achieving scale in housing decarbonisation.
• Addressing the skills gap: We strongly support the recognition that delivering emissions reductions requires investment in people, through training and apprenticeships, to strengthen supply chains and address skills imbalances. We welcome the Green Skills Delivery Group's action plan and the funding to support the development and delivery of pilot domestic low-carbon and energy efficiency courses, noting existing initiatives at colleges like South Eastern Regional College and Southern Regional College.

Alternatives/additional considerations:

To further strengthen the just transition approach:

• Rural considerations: The recognition of unique challenges of rural housing stock, particularly the reliance on home heating oil, is vital. Policies must be flexible enough to address the specific needs and infrastructure challenges of rural communities, ensuring they are not left behind.
• Private rented sector (PRS) focus: The PRS has a relatively high prevalence of poor quality housing. Low energy efficiency standards have collectively cost renters significantly. Supporting private landlords, especially small-scale ones, is crucial to help them meet future Minimum Energy Efficiency Standards and avoid disrupting the supply of rental properties. This aligns with the ‘worst first’ principle, as many PRS homes have lower energy efficiency ratings.
• Strong consumer protection framework: We believe that government has a clear responsibility to ensure robust consumer protection measures are in place to safeguard consumers from potential pitfalls like poor installation quality, misleading sales practices and inadequate after-sales service for energy efficiency and low carbon heating interventions. This includes transparent information, informed choice, ongoing support, fair contractual terms and effective redress mechanisms. While MCS certification for heat pump installers is important, government also has a role in designing a comprehensive framework for redress.
• Long-term policy signals for rented housing: A clear commitment to net zero targets from the government is needed, including the introduction of robust minimum energy efficiency standards for rented housing, coupled with appropriate funding and fiscal frameworks for landlords. The Climate Change Committee advises all rented homes need to achieve a good level of energy efficiency in just a few short years.
• Holistic cost barrier recognition: Beyond the cost of the technology, support needs to address other significant cost barriers such as building fabric upgrades, necessary plumbing and electrical upgrades (e.g. replacement radiators for heat pumps), and the cost of professional installation to ensure a truly just transition for all households.
• Limiting support for holiday/second homes: To ensure limited public funds are targeted effectively for carbon reduction and improved comfort for primary residences, properties with limited occupancy such as holiday homes or second homes should not be eligible for support.

In conclusion, we agree with the proposed approach to achieving a just transition in the residential buildings sector. However, the principle is currently undermined by fundamental issues that must be addressed: an incomplete funding model and an affordability gap where heat pump running costs can be uncompetitive with fossil fuels. To truly deliver a just transition, the Executive must act immediately to secure equitable funding across all tenures and implement policies that reduce the price of electricity for all low-carbon heating users.

Agree

CIH Northern Ireland broadly agrees with the actions outlined in the Draft Climate Action Plan to enable the transition to net zero. We welcome the comprehensive recognition of key enablers such as science, innovation, education, skills, infrastructure, planning, behaviour change and communication. These are all vital components for successful decarbonisation across all sectors, particularly within the built environment.

Our agreement is based on the following:

• Holistic recognition of enablers: The Plan correctly identifies the multi-faceted nature of the challenge, acknowledging that a technical shift alone is insufficient. Human capital, robust infrastructure, supportive policy and public engagement are all indispensable.
• Commitment to education and skills: We strongly support the emphasis on education and skills development. For the housing sector, this is paramount. There is an urgent need to train and upskill a sufficient workforce capable of delivering the vast scale of retrofits and installing low-carbon heating systems required across Northern Ireland's diverse housing stock. As highlighted in our previous submissions on issues concerning energy efficiency, ensuring a pipeline of skilled professionals, from planners and surveyors to construction workers and installers, will be critical for achieving the targets for residential buildings.
• Acknowledgement of infrastructure needs: The Plan rightly points to the need for significant investment in enabling physical and digital infrastructure. For the housing sector, this specifically translates to the necessity of upgrading and modernising the electricity grid to accommodate the increased demand from electrified heating (e.g. heat pumps) and electric vehicles. Smart grid technologies and energy storage solutions will be key to managing demand and integrating intermittent renewable energy sources efficiently.
• Crucial role of planning: We welcome the acknowledgement that the planning system can help to develop the policies and places that bring homes and key services closer together. As detailed in our response to the SPPS call for evidence, the planning system is a fundamental enabler. It must explicitly prioritise climate change mitigation and adaptation as a core objective. This includes mandating higher energy efficiency standards for new builds, promoting sustainable transport through integrated land-use and transport planning, facilitating renewable energy installations (like solar PV on homes), ensuring climate resilience in new developments – for example flood risk management using UK Climate Projections 2018 (UKCP18) and Sustainable Drainage Systems (SuDS) – and promoting compact, walkable communities. Without an enabling planning framework, the delivery of climate action will be significantly hindered.
• Tenant/customer engagement and behavioural change: We strongly agree that positive and lasting behaviour changes, and public engagement and effective communications are essential. Housing organisations are uniquely positioned to engage directly with tenants and residents, providing clear, accessible information and practical support on how to adopt new low-carbon technologies (e.g. heat pumps), understand smart meters, and manage their energy consumption efficiently. This support is crucial for ensuring that the benefits of a decarbonised energy supply are fully realised at the household level.

Alternatives/additional considerations:

To further strengthen the enabling actions, we recommend the following:

• Accelerated planning reform: While acknowledged, the urgency of climate change necessitates an acceleration of planning policy reforms (e.g. the SPPS review and subsequent Local Development Plan updates) to ensure climate considerations are embedded at every stage of the development process. Clear guidance and training for planning professionals on delivering climate-positive outcomes are also required.
• Data and monitoring for impact: While building the evidence base is noted, there should be clearer actions on how data collection and monitoring will be used to track the effectiveness of these enabling actions, not just the outputs. This includes understanding the socio-economic impacts on different communities to ensure the 'just transition' is genuinely being achieved.
• Innovation in finance and delivery models: The plan mentions exploring green finance. Actively piloting innovative funding and delivery models, particularly for housing retrofits, could accelerate the pace of change and enable a wider range of projects.

In conclusion, the plan provides a solid foundation for enabling the transition to net zero. By strengthening the actionable detail, accelerating planning reforms, ensuring robust skills development, and fostering deeper cross-departmental collaboration, Northern Ireland can significantly enhance its capacity to deliver on its ambitious climate targets.

To read the full details of Northern Ireland's draft Climate Action Plan 2023-2027 visit the DAERA website.

For more details on our response please contact Justin Cartwright, national director for CIH Northern Ireland: justin.cartwright@cih.org.