Welsh Government’s new WHQS is to be applauded, but its modelling does not go far enough to end fuel poverty. To prevent people from falling through the gaps, we must combine ambitious targets with more accurate measurements of the home, says Andy Sutton, Chief Innovation Officer at Sero.
The ambitious proposals found in the newest Welsh Housing Quality Standard (WHQS) have now been consulted on, and the Welsh Government is now considering feedback. They set out a strategy to achieve two urgent milestones — eliminating fuel poverty and decarbonising social homes in Wales.
It is hard to disagree with the intent. These goals are important, the former increasingly so as fuel costs and energy bills soar. As things are we are likely to see more people fall through the gaps into fuel poverty, not fewer. So are these ambitious goals actually achievable?
Insights based on good science and real delivery are required if we are to deliver these goals, but the proposed standard currently falls short in this regard. Welsh Government’s plan makes their ambitions challenging and expensive, but unless the proposals change, it will inevitably fail.
Why? Because due to a significant minority of homes falling outside the “bell curve” distribution assumptions in the complex, desk-modelled system used for assessing this risk, it means these homes will still be left in fuel poverty by 2033. This model will also forecast a typical home’s carbon emissions at around a single tonne/CO2eq per year. This is not the “net zero” intended in Welsh Government’s plans.
To succeed, results should be measured, not modelled, meaning the measurements used are perfectly aligned to the objectives sought. To eliminate fuel poverty, success must be in pounds and pence.
For carbon, CO2eq per year. Smart meters are already being rolled throughout social homes — allowing the measurement of both for each individual home. This technology represents real-time reporting of results and will soon be more widespread in social homes than EPCs. We expect them to have nearcomplete coverage in the next few years.
Space to innovate
If the Welsh Government truly aims to eliminate fuel poverty, they should set a price limit on tenants’ heating and hot water bills — no doubt index linked. For carbon, set 0kgCO2eq per year. And, importantly, these limits should be evidenced by measurements for every home, not modelled average forecasts.
Here is where the Welsh Government needs to step back and let the landlords’ come forward with their own expertise. In terms of delivery, the WHQS contains unnecessary interim targets and prescriptions akin to micromanagement that represent unnecessary challenges for social housing providers.
Whilst it’s reasonable to require the landlords to regularly share their plans and progress towards these objectives, give landlords the freedom to outline their own route to address the challenges they face in their own portfolio. Allow them the space to innovate to tackle the inevitable grant funding gap, hard-to-treat homes and resident engagement issues that may emerge. If we all share lessons learned we can tackle these issues collectively.
The energy crisis that concerns landlords and tenants may show this approach in action. With caps on heating and hot water costs, landlords can intervene in far broader ways — bill switching, subsidies, building fabric improvements, boiler flow temperature adjustments, and more — and see the success of said interventions in the measurements provided.
Through this approach, we will be able to discover success in the heating and hot water bill of each and every family.
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