CIH Northern Ireland response to Department for Communities consultation on the Warm Healthy Homes Fund

Given the limitations of funding, the Department proposes that households in receipt of the Personal Allowance of Universal Credit (for three consecutive periods) and those in receipt of Pension Credit are eligible for assistance.  In addition, income under a set threshold will also be used as an eligibility criterion. It proposes that the total household income threshold of the new Warm Healthy Homes Fund should be set at the rate of the National Living Wage, which is currently £29,741.40, net of tax and national insurance, and that it should rise annually in line with the National Living Wage.

Under this proposal, the Department proposes to exclude certain disability and health related benefits and allowances from the income threshold, including the winter fuel payment, recognising that these households may have higher energy needs.

1. Do you agree with the proposed approach when assessing eligibility for the Warm Healthy Homes Fund?

Yes.

We support the department’s proposed eligibility criteria for the Warm Healthy Homes Fund. We recognise that no set of eligibility criteria will perfectly identify every household experiencing, or at risk of, fuel poverty. While any income threshold will inevitably mean that some households in need fall just outside the qualifying criteria, we also recognise the importance of targeting limited funding towards those facing the greatest levels of need. On balance, we consider the department’s proposed approach to be fair, proportionate and appropriately targeted.

We particularly welcome the proposed increase to the household income threshold compared with the current Affordable Warmth Scheme. The existing £23,000 threshold no longer reflects the financial realities faced by many households or the significant increases in the cost of living in recent years. We also welcome the inclusion of low-income households who are not in receipt of means-tested benefits but who may still experience fuel poverty and struggle to afford adequate heating.

We support the proposal to disregard certain disability and health-related benefits and allowances when calculating household income. This recognises that these households often face higher energy requirements and additional unavoidable living costs that are not reflected in income alone.

We also strongly support the common-sense proposal to uprate the income threshold annually in line with the National Living Wage.

Finally, we believe the eligibility criteria should be kept under regular review throughout the lifetime of the scheme, with ongoing engagement with organisations supporting households experiencing fuel poverty. This will help ensure the fund continues to reach those most in need and enable any unintended gaps or barriers to eligibility to be identified and addressed.

The Department proposes that household savings should be taken into account in a proportionate way, recognising the need for some savings while ensuring support is targeted at those most in need.

Under this proposal, households may hold up to £6,000 in combined personal savings without this affecting eligibility. Savings above this level would be treated as income using an established approach already applied in other government schemes. The rate at which savings are counted would differ depending on the age of the applicant, with a more generous treatment for those aged 60 and over.

The Department is seeking views on whether this approach to savings is appropriate.

2. Do you agree with the proposed approach to how household savings are treated when assessing eligibility for the Warm Healthy Homes Fund?

Yes.

CIH NI supports the principle of taking household savings into account when assessing eligibility for the Warm Healthy Homes Fund. The inclusion of savings during the assessment period should help ensure that limited funding is directed towards households with the greatest need.

We also recognise that the department’s proposed approach is broadly consistent with the treatment of savings under Universal Credit, where lower levels of savings are disregarded and higher levels are taken into account when assessing entitlement.

However, we would welcome clarification on whether the savings disregard will be reviewed and uprated periodically. As with the proposed annual uprating of the income threshold, the savings limit should be kept under regular review to ensure it remains appropriate over time and does not lose its effectiveness as a result of inflation.

Given the large number of households likely to be eligible for the Warm Healthy Homes Fund and the limited budget available, the Department proposes prioritising applications after eligibility has been confirmed.

To ensure funding is targeted at those most in need, the Department proposes prioritising properties with the lowest energy efficiency. Applications would therefore be prioritised based on the Energy Performance Certificate (EPC) rating of the property, with priority given to homes rated EPC E or below, as these households are more likely to experience severe fuel poverty.

All eligible properties would require a home assessment to confirm the EPC rating. Home assessments would be carried out on a first come, first served basis; however, due to budget constraints, not all eligible properties may ultimately receive support.

The Department is seeking views on whether this is an appropriate approach to prioritisation.

3. Do you agree that the Department should prioritise Warm Healthy Homes Fund applications based on the energy rating of the property?

No.

CIH NI supports the “worst first” principle – ensuring that support is directed first to the coldest, least efficient homes and the most at-risk households. On this basis, property energy ratings have an important role to play in prioritisation.

However, we caution against using EPC ratings as the sole or primary basis for prioritising households for the Warm Healthy Homes Fund. A true “worst first” approach cannot look at building fabric in isolation. While EPC ratings should play a role in the prioritisation process once household eligibility has been established, they should be considered alongside other indicators of need rather than used in isolation.

A more person-centred, multi-factor approach is required to reflect the complex nature of fuel poverty. Although the energy efficiency of a property is an important consideration, EPC ratings alone cannot adequately identify those in greatest need. They do not account for wider factors that influence a household’s experience of fuel poverty, including health conditions, disability, age, or higher energy requirements.

We also recognise the limitations of the current EPC methodology. While EPC ratings remain the primary measure of domestic energy efficiency in Northern Ireland and provide a useful starting point for identifying less energy-efficient homes, they are based on assumptions about factors such as fuel prices, which can quickly become outdated. They also do not accurately measure the thermal performance of a building’s fabric and, as a result, may not reflect the actual energy performance of a property in practice.

Until a more robust measure of building performance is available, EPC ratings should continue to inform assessments of property need under a “worst first” approach. However, they should be used alongside broader indicators of household vulnerability to ensure that the Warm Healthy Homes Fund is targeted towards those households experiencing the greatest need.

If you answered no, do you think that the Department should prioritise applications based on another reason?

CIH NI recommends adopting a blended, person-centred and “worst first” approach to prioritisation that combines EPC ratings with broader indicators of household vulnerability. This would provide a more holistic assessment of need and help ensure that support is directed towards those households most affected by fuel poverty.

We recommend building on the existing vulnerability matrix used within the Northern Ireland Sustainable Energy Programme (NISEP). Applying a similar scoring matrix to the Warm Healthy Homes Fund would enable applications to be assessed against both:

1. Property-related factors (“worst fabric”) – such as energy efficiency, heating system type, and the presence of damp and mould
2. Household circumstances (“worst impact”) – including age, the presence of dependent children, health conditions and disability.

We also support the inclusion of professional judgement by the fund’s managing agent, exercised within a clear, transparent, and consistent framework, to take account of exceptional household circumstances where appropriate. This would provide flexibility to respond to cases (such as urgent medical needs or severe winter heating breakdown) that may not be fully reflected through a scoring-based assessment alone.

The Department proposes that Private Rented Sector landlords may access fully funded cavity and loft insulation, draught proofing, and ventilation, provided their tenant meets Warm Healthy Homes Fund eligibility criteria. 

4. Do you agree with this proposal?

Yes.

Should additional measures be included such as replacement windows, solar photovoltaic (PV) systems and electrical energy (battery) storage? 

Do you agree with this addition?

Yes.

CIH NI supports the proposal to allow private rented sector (PRS) landlords to access fully funded measures such as cavity wall insulation, loft insulation, draught-proofing and ventilation, where the tenant meets the Warm Healthy Homes Fund eligibility criteria. We also welcome the inclusion of additional measures, including replacement windows, solar photovoltaic (PV) systems and battery storage, which can further improve a property's energy efficiency and enhance the effectiveness of low-carbon heating systems.

Fuel poverty is particularly prevalent within the private rented sector, and tenants should not be disadvantaged because of their housing tenure. This is especially important given the absence of Minimum Energy Efficiency Standards (MEES) for privately rented homes in Northern Ireland. Until such standards are introduced, allowing eligible PRS properties to access the fund represents a practical and necessary means of improving the energy efficiency of homes occupied by low-income tenants.

Publicly funded improvements should also be accompanied by appropriate tenant protections. Safeguards should be introduced to minimise the risk of rent increases or evictions following energy efficiency upgrades, ensuring that the benefits of the scheme are retained by the households it is intended to support.

In the longer term, CIH NI continues to support the introduction of Minimum Energy Efficiency Standards for the private rented sector. MEES would establish a clear baseline for property standards and ensure landlords take appropriate responsibility for improving the energy efficiency of their properties, reducing reliance on public funding to address poor-quality housing.

The Department proposes setting a grant limit of £35,000 for the Warm Healthy Homes Fund that will allow for a fabric first, whole house approach including Air Source Heat Pump, solar photovoltaic (PV) systems and electrical energy (battery) storage.

This will be increased to £45,000 to support those ‘hard-to-treat’ properties i.e. those of Non-Traditional Construction, Solid Wall Construction or have Environmental Constraints.

Up to £500 will be included within the grant limit for properties that require some general maintenance or remedial works before energy efficiency measures can be installed. It is anticipated that not all properties will require the full grant limit. 

5. Do you agree with this proposal?

Yes.

CIH NI supports the proposed grant limits, including the £35,000 standard cap, the £45,000 allowance for hard-to-treat properties and the inclusion of a £500 grant for general maintenance or remedial works. We strongly welcome the scale of investment proposed, as this level of funding is necessary to deliver meaningful whole-house energy efficiency improvements and make a significant contribution towards tackling fuel poverty.

We particularly welcome the higher grant allowance for hard-to-treat properties. Some older housing stock/homes in rural areas may require greater investment due to factors such as construction type and increased installation costs associated with logistics and limited contractor availability. Recognising these additional costs will be essential to ensuring a fair and just transition, particularly for households living in more challenging properties.

We also welcome the proposed £500 grant for general maintenance or remedial works, which could help remove practical barriers that may otherwise prevent eligible households from participating in the scheme.

It will be important that households receive clear and timely information about the practical implications of the works. This should include details of any preparation required before installation, as well as any reinstatement, repairs or redecoration that may be needed afterwards. The department should also consider how additional support can be provided to households that may require assistance with practical tasks, particularly older people and people with disabilities, such as clearing spaces before works begin and restoring affected areas once installations are complete.

The department should also provide further clarity on how the scheme will support households where temporary relocation is required while works are being carried out. The consultation does not currently set out what assistance would be available in these circumstances, including whether temporary accommodation would be provided and how any associated costs would be met. Clear arrangements will be needed to ensure that households are not disadvantaged or deterred from accessing support due to the disruption caused by essential improvement works.

The Department proposes that an applicant may apply only once to the Warm Healthy Homes Fund and that the Home Assessment will determine what support that property would benefit from.   

6. Do you agree with this proposal?

No.

CIH NI does not support the proposal that applicants should only be permitted to apply to the fund once. While we recognise that there may be administrative considerations in limiting applications, a blanket one-application approach is overly restrictive and does not adequately reflect the changing circumstances and practical realities faced by households.

In some cases, it may not be feasible or appropriate for all recommended measures to be completed during a single period of works. This may be due to the scale and complexity of improvements required, household circumstances or the need to minimise disruption for vulnerable residents.

Furthermore, a strict limit fails to account for the specific dynamics of the private rented sector (PRS). The PRS contains some of the highest unfitness levels in Northern Ireland’s housing stock, making it a critical sector for targeted energy efficiency interventions. However, it is also transient, with tenants frequently moving between properties. Under a rigid one-application-per-applicant rule, a vulnerable tenant who previously accessed support would be barred from applying again if they move into another cold, energy-inefficient home. This risks leaving private renters trapped in fuel poverty simply due to the nature of their housing tenure.

We therefore recommend that the department considers allowing exceptions to the one-application rule in clearly defined circumstances. This would provide necessary flexibility while maintaining appropriate controls and ensuring that households can access the full range of support required to improve energy efficiency and reduce fuel poverty.

To ensure that energy efficiency measures delivered through the Warm Healthy Homes Fund are installed safely, consistently and to a high standard, the Department proposes that registered contractors working on the scheme should be assigned to householders and that they must hold appropriate, measure specific accreditations.

7. The Department proposes that a list of registered contractors would be provided to households to deliver the works identified by the Home Assessment, ensuring ease of access and a streamlined service for applicants. Do you agree with this proposal?

Yes.

CIH NI agrees with the proposal to provide households with a list of registered contractors to deliver the works identified by the Home Assessment. This is important for consumer protection and confidence. There is a critical need for correct installation, rigorous standards, strong consumer protection and ensuring optimal performance. This is essential across any heating type, but innovative solutions may be more unfamiliar to existing installers. Any installations will therefore need to be undertaken by experienced, competent professionals who understand the manufacturer instructions and importance of aftercare.

Providing households with a register of approved contractors would help streamline the application process by removing the need for applicants to identify and assess contractors themselves or determine whether they meet the fund’s eligibility requirements. This would represent a significant enhancement to the current Affordable Warmth Scheme, which does not offer a comparable facility.

The process for developing and maintaining the contractor register should be transparent, fair and inclusive. The public procurement process should be designed to ensure that both larger organisations and smaller local businesses have a meaningful opportunity to participate. The scheme has the potential to create valuable opportunities for local contractors while supporting the growth of the skilled workforce required to deliver energy efficiency improvements across Northern Ireland.

The department and managing agent should also implement robust and consistent arrangements for monitoring contractors included on the register. This should ensure that all works are delivered to the required standards and that appropriate measures are taken where performance issues or non-compliance are identified. This may include the suspension or removal of contractors from the register where there is evidence of poor performance or failure to meet the required standards.

Accessibility should remain a key consideration throughout the rollout of the scheme, including the way in which information about registered contractors is provided to households. Details should be made available in accessible formats and through appropriate communication channels to ensure that all households can understand their options and make informed choices.

To work on the Warm Healthy Homes Fund, a contractor must be VAT-registered, be registered with the Managing Agent to work on the Warm Healthy Homes Fund, and be accredited to a relevant trade body, including:

• Gas Safe (must be gas safe registered to install gas appliances)
• NICEIC (Electrical work)
• British Board of Agrément (BBA) (Loft, cavity wall, solid wall)
• Solid Wall Insulation Guarantee Agency (SWIGA) (Solid wall)
• National Insulation Association (NIA) (Loft, cavity wall)
• Cavity Insulation Guarantee Agency (CIGA) (cavity wall).
• Microgeneration Certification Scheme (MCS) (small-scale renewable energy systems)
• Installation Assurance Authority – (single compliance platform).

The proposed approach reflects current practice across government funded energy efficiency schemes and is intended to provide assurance on quality, consumer protection and technical competence. As the Fund develops, it is proposed that contractor standards would align with those used in other government schemes, which may include a transition to PAS 2030 and PAS 2035 standards or similar.

8. Do you think that industry is ready to adopt or move to the principles of PAS 2030/ 2035?

No.

We recognise that much of the Northern Ireland industry is not currently equipped to fully adopt PAS 2035. However, we believe the sector should begin moving towards its adoption. Given the scale of public investment involved in the Warm Healthy Homes Fund and the nature of the works being undertaken in people’s homes, it is appropriate that the scheme operates to high and consistent standards.

The current capacity challenges should not, however, be used as a reason to delay the Warm Healthy Homes Fund. Providing a clear market signal through the availability of grant funding is likely to encourage the industry to respond by developing the necessary capacity and capability. A phased transition period may be appropriate to allow the sector sufficient time to prepare. The department should also consider measures to support training and capacity building, including affordable training opportunities for key roles such as retrofit coordinators.

There is a clear need to further develop local capacity. While it may be tempting to defer the adoption of PAS 2035 on the basis that the industry is not yet fully prepared, doing so risks missing a significant opportunity to establish a more robust and effective approach to retrofit. A whole-house approach is essential to achieving the best possible outcomes for households, and PAS 2035 provides an established framework for supporting this.

Failure to move towards PAS 2035 risks limiting the effectiveness of individual interventions and undermining the long-term benefits of the fund and wider retrofit ambitions. It is therefore important that the current capacity constraints are addressed through a planned transition rather than used as a basis for delaying progress.

We recommend that the department works closely with the Department for the Economy and the industry to develop an appropriate solution and agree a clear, proportionate transition pathway towards PAS 2035. This should include consideration of the time, training and resources required to build local capacity and ensure the sector is equipped to deliver high-quality, whole-house retrofit.

9. Are there any other alternative standards or accreditations that may be applied to contractors working on all government energy efficiency schemes?

Yes.

The proposed accreditation framework is comprehensive. However, we believe it should also include the Oil Firing Technical Association (OFTEC) for contractors installing or replacing oil heating systems. While we strongly support the installation of the most energy-efficient and decarbonisation-focused heating system wherever technically feasible, we recognise that this may not always be appropriate or possible due to the characteristics of a property. Where an existing oil heating system therefore needs to be replaced, it is important that the fund has access to suitably qualified and accredited contractors holding the relevant OFTEC certification.

We also encourage the department to consider the additional training and support required by those who will have direct contact with households. For example, mandatory energy awareness training should be considered for frontline staff employed by the fund’s managing agent.

In addition, training in behaviour change would help contractors and advisers support households in adapting to new technologies and making the best use of the measures installed.

Ensuring that both contractors and frontline staff have appropriate technical, energy awareness and behavioural change training will be important in delivering a high-quality customer experience and ensuring households are able to maximise the benefits of the fund’s investment.

It is proposed that initial aftercare advice will be available to all applicants. This will be a routine follow up between 6 and 12 weeks after installation to ensure that equipment is being used correctly and effectively. It is anticipated that the Managing Agent will instigate the aftercare by telephone to establish if a follow up visit is required. Should a visit be needed then the contractor who completed the works should visit the property to address any concerns or issues. 

10. Do you think that the proposed aftercare arrangements are sufficient?

No.

CIH NI considers the proposed aftercare arrangements to be insufficient. We are also concerned that there are inadequate measures in place to support households before and throughout the installation process.

Prior to works commencing, we recommend that households receive clear information about the practical implications of the works. The department should also consider how additional support can be provided to households that may require assistance with practical tasks, particularly older people and people with disabilities, such as clearing spaces before works begin and restoring affected areas once installations are complete. Clarity is also needed on how the scheme will support households where temporary relocation is required while works are being carried out.

Effective communication and signposting for the fund is essential. Households may require assistance to understand the measures available to them, complete applications, select and engage contractors, and understand what to expect throughout the installation process. The department must also ensure that digitally excluded households can access appropriate support. We recommend establishing a freephone service through which households can raise questions or concerns at any stage of the process.

In terms of aftercare, a single follow-up telephone call six to twelve weeks after installation is unlikely to provide sufficient support, particularly where new technologies such as air source heat pumps (ASHPs), solar PV and battery storage have been installed. The performance, usability and suitability of some technologies, particularly ASHPs, can only be properly assessed across different levels of heating demand and over multiple seasons. We therefore recommend a more comprehensive aftercare model, including quarterly check-ins throughout the first year following installation, similar to the approach previously used under the Northern Ireland Sustainable Energy Programme (NISEP).

The managing agent should establish a dedicated aftercare team to act as the main point of contact for households and landlords. This team should be responsible for answering routine queries, escalating technical issues to contractors and coordinating appropriate responses. Households should also receive a clear, accessible handover pack from contractors for each technology installed.

The managing agent should work with experienced voluntary and community organisations to provide, or signpost households towards, high-quality energy advice and other appropriate support. Integrating voluntary and community sector partners into scheme delivery would strengthen the customer experience, increase engagement and contribute to better long-term outcomes.

Aftercare should be focused on household outcomes rather than simply establishing whether equipment is operational. Follow-up should include practical questions about whether the home is warm, comfortable and affordable to heat, as well as whether households understand how to use the technologies installed.

In an evaluation of the Warm Homes Fund in England, it was found that “the most common negative experience raised by interviewees was a lack of adequate advice about how to effectively use and operate their new heating system.” ASHPs were again noted as a common issue, with beneficiaries sometimes not offered appropriate advice about how low-temperature heating systems function. This is an outcome the fund should strive to avoid, to build trust with households and ensure the long-term success of the scheme.

11. Please comment on any potential equality implications you feel may arise from the issues/proposals discussed in this consultation

We have further comments, echoing the views of our partners in the Fuel Poverty Coalition.

Equality of access and outcomes should be monitored throughout the lifetime of the scheme. The department should collect and monitor appropriate data to establish who is aware of the fund, who applies, who receives support and what outcomes are achieved. This should help identify whether particular groups face barriers to accessing the scheme or are unintentionally underrepresented. Monitoring should also consider uptake and outcomes by location, including the identification of any specific practical barriers faced by households in rural areas. These findings, alongside wider monitoring of the fund as it is rolled out, should be reported transparently through the Warm Healthy Homes Strategy’s annual progress reports and the annual ministerial statement on fuel poverty.

Accessibility should be embedded at every stage of the customer journey. Information and communications should be accessible to people with a range of communication needs. The department and managing agent should work with organisations with relevant expertise to ensure that the scheme’s design, communications, staff training and delivery are accessible in practice.

CIH NI also supports the Fuel Poverty Coalition’s recommendation that the department reconsider its Section 75 screening decision and undertake a full Equality Impact Assessment (EQIA) of the fund. Many of the equality issues identified by our colleagues in the FPC relate not only to eligibility, but also to the practical delivery of the fund.

A full EQIA would provide a more comprehensive assessment of how Section 75 groups may experience the scheme across the entire customer journey. It would help identify potential barriers to participation, inform the design of accessible communications and customer support and identify appropriate training needs for the managing agent and frontline staff. This would complement the department’s commitment to monitor the scheme and help ensure that equality considerations continue to inform delivery as the fund develops.

If you want to learn more about this consultation response, please contact Georgia Knapp, policy and public affairs manager, Northern Ireland at georgia.knapp@cih.org.