Memorandum submitted by the Fuel Poverty
Advisory Group (CCB 10)
INTRODUCTION
This is the response to the consultation from
the Fuel Poverty Advisory Group. The Group has some similarities
to the proposed Climate Change Committee, although there are also
differences. We are submitting evidence on two sets of issues.
The first is the impact on fuel poverty of the proposed Climate
Change Bill and the relationship between the two statutory targets—climate
change budgets and targets and fuel poverty targets. The second
issue is our experience of the fuel poverty statutory target.
The Climate Change Bill is introducing targets for Climate Change.
It seems sensible to draw on the lessons from the Government Fuel
Poverty targets over the last six years.
Referring to the Committee's terms of reference,
this note thus deals with some of the implications of carbon budgets
and targets, domestic climate change issues, monitoring, accountability,
enforcement, sanctions, reporting procedures and the Climate Change
Committee.
FUEL POVERTY
ADVISORY GROUP
(FPAG)
The Fuel Poverty Advisory Group is a Group consisting
of representatives of external organisations, set up by the Government
to provide advice on the practical measures needed to meet the
Government's targets of eradicating fuel poverty in England. The
Group was established broadly at the same time as the statutory
targets were put in place. A wide range of organisations is represented
on the Group—from Energy Companies to fuel poverty NGOs
and broader consumer and housing groups and experts. The membership
and terms of reference of the Group are set out in Annex A.
CLIMATE CHANGE
BILL AND
FUEL POVERTY
We recognise the importance of combating climate
change and hence of the Bill. We also appreciate that there are
both important synergies and some tensions between the climate
change and the fuel poverty targets. We have noted the clauses
relating to social considerations and fuel poverty:
— In Clause 5, 2(e), Page 3 the
Secretary of State and the Committee on Climate Change in coming
to any decision and in considering advice must take into account,
amongst a list of matters, "Social circumstances and in particular
the likely impact of the decision on fuel poverty".
— In Schedule 1, 1(3)(h) the Secretary
of State in appointing the Climate Change Committee must have
regard to the desirability of securing that the Committee has
experience in, or knowledge of (among a list of things) "climate
change policy and in particular the social impacts of such policy".
It is, however, our view that:
— there are not enough safeguards
in the Bill on fuel poverty; and
— the Government will have two
separate sets of related Statutory Targets—Climate Change
and Fuel Poverty—without recognising adequately the interaction
between the two.
It there seems to us to be sensible that in
Clause 5 discussed above there should be more explicit reference,
not just to the impact on fuel poverty, but to the impact on the
fuel poverty targets. Specifically the Secretary of State, in
coming to a decision and the Climate Change Committee in considering
its advice, should take account of the impact of the decision
and advice on the ability to meet the statutory fuel poverty targets.
There should also be a requirement for the Secretary of State
and the Climate Change Committee to report explicitly on this.
The Secretary of State and the Climate Change Committee might
in doing this be asked to take account of the views of FPAG.
Similarly it does seem to us that consumer and
low income group interests are likely to be under-represented
on the Climate Change Committee. Experience and knowledge in these
areas should be a separate requirement and should not be a subset
of knowledge of climate change policy.
EXPERIENCE OF
THE FUEL
POVERTY TARGETS
AND FPAG
The Government has a statutory duty to end fuel
poverty. The exact targets differ between the different administrations,
but in England the duty is end fuel poverty for vulnerable households
and non-vulnerable households living in social housing as far
as reasonably practical by 2010 and to do the same for all households
by 2016. The establishment of the Fuel Poverty Advisory Group
for England was announced at around the same time as the Fuel
Poverty Strategy to meet the targets, was published in November
2001, and the Group started its work in April 2002. Defra and
DTI Ministers choose the organisations to be represented on the
Group and appoint the Chair.
As noted, our job is to advise the Government
on the practical measures needed to meet the targets. FPAG publishes
an annual report and our 2006 report, published in April 2007,
is attached as Annex 2.[5]
The Government also publishes an Annual Progress Report on Fuel
Poverty.
There are some analogies to the proposals for
the Climate Change Bill. There is a statutory target, annual reporting
and an external group. There are also differences as there is
no direct reporting to Parliament and the process is less formalised.
The Fuel Poverty Advisory Group focuses on the measures needed
while the Climate Change Committee's main task relates to the
carbon budgets.
Our views on the impact of the statutory fuel
poverty target and of the Fuel Poverty Advisory Group are as follows:
— The statutory target has made
a difference—there have been more resources for fuel poverty
and more helpful measures than would have been the case in the
absence of a target. The target has helped to provide focus and
drive.
— However, the 2010 statutory
target now looks extremely difficult to achieve and the shortfall
could be considerable. Admittedly the circumstances have been
difficult as a result of rising energy prices—but this still
raises issues about the best way of securing effective targets,
as there will always be difficult circumstances on the road to
tough targets. It is not clear what the sanctions for failing
to meet the targets are. It seems therefore likely that the targets
and arrangements put in place will prove to have been insufficient
to secure achievement of the targets.
— When the targets and strategy
were established there were no estimates of the resources required
to meet the target. FPAG has secured, with help from DTI and Defra
Officials, that the costs have now been estimated and this has
been helpful in securing extra resources for the Fuel Poverty
Programmes.
— FPAG has made a large number
of recommendations. As expected a number have been accepted and
some have not. Defra and DTI have the main responsibility for
the targets and they have to a degree focussed on the issues.
Some other Government Departments have been helpful, especially
in recent months, but in broad terms the existence of a statutory
target has made a small, but not a major, difference to the actions
of certain key departments. Similarly Ofgem has, on some issues,
been helpful but the statutory target has not made as much difference
to Ofgem's activities as perhaps might have been expected. The
issues of binding other Departments and Agencies across Government
into the Climate Change targets will thus be an extremely important
one.
In summary the target and the associated arrangements
have been helpful and have unquestionably resulted in more progress
than would have been made in their absence. But It is likely—sadly—that
they will not be anything like adequate to secure the objective.
Finally FPAG would be very happy to provide
further information and to give evidence in person.
5 Not printed.Witnesses: Mr Peter Lehmann,
Chair and Mr John Chesshire, Vice Chair, Fuel Poverty
Advisory Group, gave evidence. Back
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