Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes

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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
Torfaen Council
Affordable Warmth Strategy
        2012-2017

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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
Contents
Introduction                                              Page 3

1. UK Response                                            Page 3

1.1 UK Fuel Poverty Strategy 2001                         Page 3
1.2 Energy Act 2010                                       Page 4
1.3 Home Energy Saving Programme                          Page 4
1.4 Energy Bill 2010/11                                   Page 4
1.5 Green Deal                                            Page 5
1.6 Warm Homes Discount Scheme                            Page 6
1.7 Renewable Heat Incentives (RHI)                       Page 6
1.8 Feed In Tariff (FIT)                                  Page 6

2. Welsh Response                                         Page 8

2.1 Fuel Poverty Strategy 2010                            Page 8
2.2 NEST Fuel Poverty Scheme                              Page 8
2.3 Arbed                                                 Page 8
2.4 Ynni’r Fro                                            Page 9
2.5 Keep Well this Winter                                 Page 9
2.6 Local Authority and Housing Association
Support Programme (LAHAS)                                 Page 9

3. Strategic Context                                      Page 10

4. Fuel Poverty                                           Page 11

4.1 What is Affordable Warmth?                            Page 11
4.2 Who is affected by Fuel Poverty?                      Page 11
4.3 What are the causes of Fuel Poverty?                  Page 11
4.4 What are the effects of Fuel Poverty?                 Page 12
4.5 How can we reduce Fuel Poverty?                       Page 13

5. Fuel Poverty in Torfaen                                Page 14

5.1 The level of Fuel Poverty in Torfaen                  Page 14
5.2 The energy performance of housing stock               Page 14
5.3 Energy characteristics of Torfaen housing stock       Page 15
5.4 Developing a picture of Fuel Poverty across Torfaen   Page 15
5.5 Most vulnerable wards in Torfaen                      Page 17
5.6 Priority Ranking Table                                Page 18

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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
6. Aims and Objectives                                                    Page 19

1. To provide Fuel Poverty advice
2. To make warmth more affordable by maximising incomes
   and lowering fuel costs
3. To develop housing policy for all housing tenures to include
   energy efficiency and to deliver affordable warmth for the long term
4. Decrease incidents of cold related illness
5. To co-ordinate delivery of an effective affordable warmth strategy
6. To improve the energy efficiency of homes in Torfaen

7. How we intend to address Fuel Poverty                                  Page 20

7.1 Publicity                                                             Page 20
7.2 Private Rented Sector Project                                         Page 20
7.3 Arbed 2                                                               Page 21
7.4 NEST                                                                  Page 21
7.5 Encourage Community Initiatives                                       Page 21
7.6 Green Deal                                                            Page 22
7.7 Renewable Heat Incentives (RHI)                                       Page 22
7.8 Feed In Tariffs (FIT)                                                 Page 22
7.9 Powering up Communities First                                         Page 22

Appendices

Appendix 1 – Grants and Funding                                           Page 23

Appendix 2 – Action Plan                                                  Page 26

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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
Affordable Warmth Strategy – October 2011

Introduction

Achieving affordable warmth is a national priority, reflected in the Welsh Government’s,
Fuel Poverty Strategy (2010). The Fuel Poverty strategy sets out the Welsh Government’s
commitment to reduce fuel poverty in Wales and to take action that will ensure that by
2018, no household is living in fuel poverty.

Fuel poverty can impact on people’s lives in many different ways, but especially on their
health. In 2007, there were approximately four million households in the UK experiencing
fuel poverty1, 240,000 of which are in Wales.2 Every winter, between 25,000 and
30,000 deaths in the UK are linked to the cold weather.3

Torfaen recognises that it has a key role to play in tackling fuel poverty locally and achieving
affordable warmth for all. Through the development of this strategy, Torfaen will set out
how it will address fuel poverty in the borough and work towards achieving the Welsh
Government’s target of eradicating fuel poverty by 2018.

1. UK Response

1.1 UK Fuel Poverty Strategy 2001

In 2001, the UK Government published a Fuel Poverty strategy which outlined its intentions
for eradicating fuel poverty in vulnerable households by 2010, and for all households by
2016. This commitment was later reaffirmed through measures set out in the 2003 and
2007 Energy White Papers.

The strategy focuses primarily on measures to improve energy efficiency and reduce the
fuel costs for fuel poor households. It targets three main factors that lead to fuel poverty;
household energy efficiency, fuel prices and household income. The strategy acknowledges
that no single approach will be sufficient to solve fuel poverty and that a variety of
programmes and measures are required. Since the strategy’s publication, the Department of
Energy and Climate Change has produced annual reports detailing the progress being made
to achieve the targets set out in the strategy.

Whilst separate targets exist in each of the Devolved Administrations, the primary aim is to
ensure that by 2018 no household in the UK is living in fuel poverty.

1
  http://www.decc.gov.uk/en/content/cms/funding/fuel_poverty/strategy/strategy.aspx [Accessed 10.06.11]
2
  Fuel Poverty Strategy 2010, Welsh Assembly Government
3
  http://www.nhs.uk/livewell/winterhealth/pages/keepwarmkeepwell.aspx [Accessed 14.04.11]
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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
1.2 Energy Act 2010

This Act enables the UK Government to compel energy suppliers to provide more support
with the cost of energy bills to fuel poor and vulnerable households. Through mandatory
price support, the Energy Act hopes to create a reduction in the cost of energy bills. The Act
also clarifies and increases the powers of Ofgem as regulator, to enable it to address issues
around the exploitation of electricity distribution and to impose fines on companies.

1.3 Home Energy Saving Programme

In 2008, the UK Government announced a new programme of measures to help UK
householders make their homes more energy efficient and therefore reduce their energy
bills. The Home Energy Saving Programme consists of two types of funding; CERT and CESP.

The Carbon Emissions Reduction Target (CERT)

CERT is the requirement placed on domestic energy suppliers by the UK Government, to
reduce the amount of CO2 being used through the promotion of low carbon energy
solutions to households. CERT aims to:

       Assist the UK to meet the targets set out under the Kyoto protocol of cutting
       greenhouse gas emissions by 12.5% below the 1990 levels by 2012.

       Meet the requirements of the Climate Change Act 2008 to cut green house gas
       emissions by 80% below the 1990 levels by 2050.

The additional benefits that CERT will bring are a decrease in energy demand leading to a
reduction in energy bills and fuel poverty. The scheme will also generate jobs and help to
enhance the UK’s supply of energy.

Community Energy Saving Programme (CESP)

CESP targets households on low incomes and through a “whole house” approach, seeks to
improve the energy efficiency standards of properties and reduce fuel bills. The programme
is delivered through the development of community-based partnerships between Local
Authorities, community groups and energy companies, on a house-by-house, street-by-
street approach. This partnership working allows CESP to be implemented in a way that is
best suited to individual areas and coordinated with other local and national initiatives.

1.4 Energy Bill 2010/11

The Energy Bill is designed to improve energy efficiency in homes and businesses through
the provision of a national programme of energy efficiency measures. The Bill will help to
guarantee low carbon energy supplies and fair competition in the energy markets. It has
three principal objectives:

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Torfaen Council Affordable Warmth Strategy 2012-2017 - Torfaen Homes
Tackling barriers to investment in energy efficiency
       Enhancing energy security
       Enabling investment in low carbon energy supplies.

The flagship policy in the Bill is the 'Green Deal', a scheme which funds householders,
private landlords and businesses to make energy efficiency improvements. The funding is
then repaid through the household energy bill. The introduction of the Energy Bill will also
repeal the Home Energy Conservation Act (HECA), which has now been superseded.4

1.5 Green Deal

The Energy Bill 2010 includes provision for a ‘Green Deal’ which will enable energy
customers to get energy efficiency improvements carried out to their homes without having
to pay for them upfront. Instead, the capital required for the works will be provided by
businesses who recover the money via the energy bill. This system also ensures that if the
customer moves home, the financial obligation doesn’t move with them, but becomes the
responsibility of the next bill payer. So unlike conventional loans, the bill-payer is not liable
for the full capital cost of the measures, only the charges due whilst they remain at the
property.

Under the new Energy Company Obligation (ECO), energy companies will be required to
focus their assistance on low income and vulnerable households, as well as those in hard to
treat properties who cannot achieve financial savings without a measure of support. This
will help them manage their bills for the long term and heat their homes more affordably.
The ECO will replace CERT and CESP when the Green Deal becomes available.

To qualify for the Green Deal, expected savings in typical properties consuming a normal
amount of energy must be equal to or greater than the cost of the measure.

The scheme is due to be launched in late 2012.

1.6 Warm Homes Discount Scheme

The Warm Home Discount Scheme replaces the voluntary agreement that existed between
the Government and energy suppliers on social price support. In the voluntary agreement,
energy suppliers agreed to spend a certain amount of money each year on helping specific
groups of people, such as the elderly and those on low incomes, with the cost of their
energy, through measures such as lower tariffs and energy bill rebates.

Using the powers provided by the Energy Act 2010, the Government established the Warm
Home Discount scheme which runs from 1 April 2011 until March 2015. The scheme will
offer a rebate on electricity bills for customers in two distinct groups. The first group (Core
Group) will consist of older pensioner households on low-incomes who are in receipt of a
4
 Summary impact assessment for the Energy Bill 2010/11 [Accessed 20.05.11]
http://www.decc.gov.uk/assets/decc/legislation/energybill/1014-energy-bill-2010-ia-green-deal.pdf

                                                                                                5
subset of pension credit, and the second group (Broader Group), which it will be left to the
energy suppliers to define, but may include low income families and those with long-term
illnesses and disabilities. Both groups will be granted a rebate of £120 in Year 1, £130 in Year
2, £135 in Year 3 and £140 in Year 4 off their electricity bills. There is no need to apply as the
Department of Work and Pensions will contact the person if they are eligible for the
discount.

1.7 Renewable Heat Incentives (RHI)

The Renewable Heat Incentive (RHI) is a Government scheme which aims to promote and
encourage the uptake of renewable heat installations by providing long-term financial
support to householders. Through encouraging the uptake of renewable heat, the
Government hopes to revolutionize the way heat is generated and used in buildings and
homes.

The first phase of the RHI tariff has been targeted at non-domestic sectors, while domestic
households are currently eligible for Renewable Heat Premium Payments, which provide an
upfront subsidy towards the cost of renewable heating systems. A second phase of RHI
support is set to be introduced in 2012 to coincide with the introduction of the Green Deal
for Homes and will be targeted to include domestic households. RHI tariff support will be
delivered in the form of payments made over a number of years, rather than as an upfront
payment. People in receipt of the Renewable Heat Premium Payments will be able to apply
for the long term RHI tariff support once the scheme is introduced in 2012, along with
anybody who has installed an eligible installation since 15th July 2009.
[NB: The Government has not yet published its proposals for how the Renewable Heat Incentive will
work in the domestic sector, so there is no guarantee at this stage that anyone who is eligible for an
Renewable Heat Premium Payment grant will also be eligible for the Renewable Heat Incentive.]

Increasing renewable heat is vital to meeting the UK’s renewable energy targets, reducing
carbon emissions, ensuring energy security and helping to build a low carbon economy. The
Renewable Heat Incentive (RHI) is the first financial support scheme for renewable heat of
its kind in the world, and will help accelerate deployment by providing a financial incentive
to install renewable heating in place of fossil fuels.

1.8 Feed In Tariffs

Under powers provided in the Energy Act 2008, the Department of Energy and Climate
Change (DECC) introduced a system of Feed-In Tariffs (FITs) to incentivize small scale (less
than 5MW), low-carbon electricity generation. The FITs scheme guarantees a minimum
payment for all electricity generated by the system, as well as a separate payment for the
electricity exported to grid. The Feed-in Tariff is made up of two types of payments:

Generation tariff - a set rate paid per kWh of electricity generated. The rate is dependent
on the type and size of technology installed.

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Export tariff - energy suppliers will also pay 3.1p per kWh that is exported to the electricity
grid (i.e. not used onsite).

In addition, householders will make savings on their energy bills by using the free electricity
generated onsite. The tariffs available and the process for receiving them vary, depending
on when the technology was installed, and whether the system and the installer were
certificated under the Microgeneration Certification Scheme (MCS).

This scheme is currently under review and may be subject to change in the future.

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2. Welsh Response

2.1 Fuel Poverty Strategy 2010

The Welsh Government has set out its own priorities for addressing fuel poverty in Wales
through the publication of its Fuel Poverty Strategy. The strategy sets out 3 key objectives:

      Social – reduce the impact of fuel poverty on householders in Wales and, as far as
      reasonably practicable, eradicate fuel poverty.
      Economic – create green jobs and business opportunities for the people of Wales.
      Environmental – reduce the greenhouse gas emissions in the domestic sector,
      contributing to the Welsh Government’s target to reduce greenhouse gas emissions
      by 3% per year in areas of devolved competence.

To achieve its target of eradicating fuel poverty by 2018, the Welsh Government will seek to
use all available measures to reduce the number of households currently living in fuel
poverty in Wales.

2.2 NEST Fuel Poverty Scheme

NEST, which replaces the previous HEES scheme (Home Energy Efficiency Scheme), was
established by the Welsh Government, British Gas and the Energy Saving Trust, to provide
advice and support to vulnerable households from one co-ordinated point. The scheme
offers a range of information on energy efficiency, benefit entitlement, energy tariffs,
money management and support in accessing energy efficiency improvements. NEST will
help people to improve the energy efficiency of their homes and as a result, reduce their
energy bills.

British Gas’ team of experts will visit eligible properties to conduct a ‘Whole House
Assessment’ before suggesting, agreeing and installing a range of measures suitable for that
home and its occupants.

2.3 Arbed

Arbed is the Welsh Government’s Strategic Energy Performance Investment Programme,
which co-ordinates investment to improve the energy efficiency of Welsh homes. The
programme is designed to maximize the different environmental, social and economic
benefits of energy efficiency and help to deliver the One Wales commitments to reduce
climate change, eradicate fuel poverty and boost economic development and regeneration
in Wales.

The first phase of Arbed involved social housing provider’s fitting homes with innovative
measures such as solid wall insulation, solar panels and heat pumps. These £30m
improvements took place between 2010 and 2011.

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The Welsh Government has now received funding from the European Regional
Development Fund (ERDF) to carry out a second phase of Arbed. Funding has been secured
through cross-departmental working and will be delivered alongside Local Authorities, with
support from Community Housing Cymru and Welsh housing associations. The programme
will help improve the energy performance of at least 4,000 homes over 3 years in some of
Wales’ most deprived communities including hard to treat homes.

2.4 Ynni’r Fro

The Welsh Government’s Ynni’r Fro Programme uses European Structural Funds to support
and encourage the development of community scale renewable energy schemes in Wales.
The benefits of community scale renewable energy are lower costs and the opportunity to
deliver cheaper energy with a greater reduction of CO2 emissions.

2.5 Keep Well this Winter

Organised by the Welsh Government, this scheme brings together a range of initiatives into
one concerted programme aimed at tackling health inequalities. The campaign provides
information and support to people aged 65 and over to help them keep well through the
winter. Strategic partners include; Age Concern Cymru, Care & Repair Cymru, Food
Standards Agency Wales, Energy Saving Trust (Wales), EAGA Partnership, NHS Direct Wales,
National Public Health Service, RNIB Cymru, Wales Fire Services, and Wales Pension Service.

2.6 Local Authority and Housing Association Support Programme (LAHAS)
The Welsh Government has funded this scheme, currently managed by the Energy Saving
Trust, to provide support, advice and information to Local Authorities and Housing
Associations.

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3. Strategic Context

                                NATIONAL
       Fuel Poverty Strategy 2010
       National Housing Strategy – Improving Lives and Communities (2010)
       Financial Inclusion Strategy - Taking Everyone Into Account (2009)
       One Wales: One Planet – The Sustainable Development Scheme of the
       Welsh Assembly
       A Low Carbon Revolution
       Climate Change Strategy 2010
       National Energy Efficiency and Savings Plan (2011)
       Warm Homes and Energy Conservation Act 2000 – A Fuel Poverty
       Commitment for Wales (2003)
       Keep Well this Winter

                                 REGIONAL
       South East Wales Energy Partnership
       Turning Heads – A Strategy for the Heads of the Valleys 2020

                                  LOCAL
     Local Housing Strategy
     Torfaen Energy Partnership (TEP)
     Housing Renewal Policy and Strategy
     Private Sector Stock Condition Survey
     Health, Social Care and Wellbeing Strategy
     Supporting People Operational Plan
     Strategy for Older People
     Torfaen County Borough Council Corporate Plan                     10
     Torfaen County Borough Council Community Strategy
     Anti Poverty Group
     Torfaen Regeneration Strategy
     Torfaen Children and Young People’s Plan
4. Fuel Poverty

4.1 What is Affordable Warmth?

Living in a cold home is not just an unpleasant experience; inadequately heated houses can
have serious health implications, particularly for the old, the very young, people with a
disability, and can even be a factor in premature death. At the same time, cold homes are
likely to be poorly insulated, meaning more fuel is burnt to maintain warmth, adding
unnecessarily to the UK’s carbon emissions. Tackling fuel poverty has real benefits, both by
improving people’s well-being and helping to reduce our contribution to climate change.

Fuel poverty occurs when a household needs to spend 10% or more of its income on heating
their property to an adequate temperature. Many factors contribute to fuel poverty
including low incomes, rising fuel prices, inadequate insulation, inefficient heating systems,
and a lack of information.

Affordable warmth is where an adequate standard of warmth can be achieved for a fuel cost
of no more than 10% of income.

4.2 Who is affected by Fuel Poverty?

Vulnerable groups on low incomes are often the most affected by fuel poverty. There are
often higher levels of fuel poverty among people over the age of 60, people who are
disabled or long-term sick, households with children and households on a low income.

4.3 What are the causes of Fuel Poverty?

Income
Low income households will have similar expenses to those on higher incomes, but they
often have to prioritise other needs above fuel.

Cost of fuel
Low income households are less likely to be able to pay energy bills on a monthly or
quarterly basis and so use pre-payment meters. These can cost significantly more than
someone paying by direct debit, a system that often brings a discount from the suppliers. 5

The cost of fuel has risen significantly since 2000 and is likely to continue rising (see table1).
Gas and electricity suppliers blame rising wholesale costs for energy, as well as
environmental taxes and mounting distribution costs. In September 2011, energy price rises
pushed a further 569,600 households into fuel poverty. For every 1% increase in gas and
electricity bills, a further 40,000 households are believed to fall into fuel poverty.

5
 http://www.energysavingtrust.org.uk/Easy-ways-to-stop-wasting-energy/Stop-wasting-energy-and-cut-your-
bills [Accessed 14.04.11]
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Table 1

Inefficient properties
Properties that are poorly insulated and have less energy efficient heating systems will cost
more to heat. Solid walled and off-gas properties are considered to be the least efficient.
The size of the property will also increase the cost of heating the property.

Time spent at home
Vulnerable groups such as older people, the unemployed, disabled or long term sick and
single parent families will tend to spend more time in their properties than other groups.
They will spend more money heating their homes but are often the groups who have the
lowest incomes.

Lack of information
There are a number of schemes available to help people tackle fuel poverty and improve the
energy efficiency of their properties. However, there is often a lack of knowledge about
what help is currently available.

4.4 What are the effects of Fuel Poverty?

Fuel poverty has a significant impact on the health, social and economic well-being of
households and puts increased pressure on public sector services such as the NHS, through
the increased demand for resources.

Health
The links between fuel poverty, poor housing and ill health are well established. Fuel poor
householders are often more susceptible to respiratory and cardiovascular illnesses, with
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cold and damp properties exacerbating underlying problems. Fuel poverty contributes to
the number of excess winter deaths, with more deaths occurring in the winter months than
at other times of the year. Cold homes can aggravate conditions such as rheumatism and
arthritis, increasing the risk of falls and other household accidents. In their report, ‘The Cost
of Poor Housing in Wales’ Shelter Cymru and the Building Research Establishment (BRE)
Trust calculated that it costs the NHS in Wales, £67 million a year from treating accidents
and incidents caused by problems with the home, including excessive cold, damp and
mould.6

Quality of life and social exclusion
If a large part of a person’s income is needed to heat their property, this will directly impact
on their quality of life, with less income being available to spend on other basic essentials.
Where there are high concentrations of fuel poverty, the wider community and local
economy can suffer significantly. If properties are poorly heated, households may also be
reluctant to invite people to their homes, leading to social isolation.

Education
Fuel poverty can affect education, with children missing school through illness, or struggling
to study in cold and poorly insulated homes. When ‘The Cost of Poor Housing in Wales’
report took into consideration factors such as children’s poor educational attainment and
reduced life chances, they estimated the cost to society to be around £168m a year. 7

Deterioration of housing stock
Energy inefficient properties are more likely to suffer from damp and structural problems,
which over time will lead to a deterioration of property conditions.

Climate change
Fuel poverty is closely linked to climate change, with high levels of fuel consumption (as a
result of an energy inefficient property) leading to an increase in carbon emissions, that
directly contributes to climate change.

4.5 How can we reduce Fuel Poverty?

There are two key steps to prevent and reduce fuel poverty:

    1) Ensuring that people are paying the lowest price for their energy
    2) Encouraging residents to live a more energy efficient lifestyle through:
              a) Improving the energy efficiency rating of homes
              b) Changing behaviour of individuals to reduce the amount of energy they
              use

6
  http://www.sheltercymru.org.uk/media/press-release-display.aspx?Parentid=4&year=2011&newsid=26
[Accessed 14.04.11]
7
  http://www.sheltercymru.org.uk/media/press-release-display.aspx?Parentid=4&year=2011&newsid=26
[Accessed 14.04.11]
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5. Fuel Poverty in Torfaen

5.1 The level of Fuel Poverty in Torfaen

Torfaen has a population of nearly 91,000 residents and approximately 40,000 residential
properties. The 2011 Private Sector Stock Condition Survey revealed that there are an
estimated 2,500 (8.6%) households living in fuel poverty in Torfaen. The highest rate of fuel
poverty is found in the private rented sector, where 10% of households are in fuel poverty,
compared with 8% in the owner occupied sector.

Fuel poverty is almost always associated with residents who are on the lowest incomes. Of
all the households in fuel poverty, only 800 (31%) households were found to be in fuel
poverty where household incomes are above £10,000 per annum. The remaining 69% were
found in households where income is below £10,000 per annum.

Fuel poverty is usually associated with dwellings where one or more resident is in receipt of
a means tested benefit (Benefits being an indicative of low income). In Torfaen, fuel poverty
is found in 1,300 households (10%) where a benefit is received, compared with 1,200 (8%)
of dwellings where occupiers do not claim benefits.

5.2 The energy performance of housing stock

Social housing equates to approximately 10,000 properties in Torfaen. These are managed
by Registered Social Landlords (RSLs) including Bron Afon Community Housing, Melin
Homes, Charter Housing, Hafod and Linc Cymru. Social housing stock must meet the Welsh
Housing Quality Standard (WHQS), which includes a requirement for homes to have an
efficient heating system and be adequately insulated. The RSL’s are actively undertaking a
programme of works to achieve this standard by 2012. In addition they are delivering
exemplar projects in energy efficiency by installing renewable energy sources in their stock.

The remaining 30,000 properties within Torfaen lie in the private sector. In 2009, Warm
Wales, a regulated community interest company, worked in partnership with Torfaen Council to
utilise Carbon Emission Reduction Target (CERT) and Community Energy Savings Programme
(CESP) funding to deliver an Affordable Warmth project. The project complemented the
work being undertaken within the social housing sector, by installing measures to assist in
reducing fuel poverty for the most deprived and vulnerable resident’s private sector houses.
Properties that were ranked in the top quintile of deprivation in Wales according to the
Welsh Index of Multiple Deprivation (WIMD 2008) were targeted in the program. 3,000
private properties were offered support, advice and improved home insulation from Warm
Wales advisors.

There is still much work to be done to improve the condition of all private sector households
to reach an energy efficient standard. In addition, there is a need to specifically address the
domestic private rented sector, which is generally of a lower quality and poorer energy
performance than that of other tenures. In order to address these issues it is crucial to
develop a data evidence base and work closely with other service areas including

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environmental health, social services, the local health board and RSLs to identify the level of
fuel poverty within Torfaen.

5.3 Energy characteristic of Torfaen housing stock

A SAP rating is the Standard Assessment Procedure that defines the energy efficiency of a
dwelling. A low SAP rating indicates that the property is inefficient and it is therefore likely
that the residents live in fuel poverty. The target SAP for all dwellings is a minimum of 65
described under the Home Energy Conservation Act (HECA) 1995.

Data collected by Torfaen Council indicates that the average SAP rating of private residential
properties in Torfaen is 50 and of Housing Association properties is 66. This compares to an
average Welsh SAP rating of 50 based on the findings of the Living in Wales 2008.

Torfaen Council undertook a Private Stock Condition Survey in May 2011, using results
based on a sample survey of 900 dwellings covering private sector tenures. To work towards
achieving the target SAP rating of 65, the survey recommended that 11,700 (40.3%) of
private sector dwellings should receive increased loft insulation, with 18,800 (64.8%)
requiring cylinder insulation improvements. In addition 7,100 (24.5%) would benefit from a
boiler replacement and 7,100 (24.5%) from increased wall insulation. The cost of energy
improvements to all 2,500 properties in fuel poverty is estimated at £4.1 million. The cost of
carrying out all works to all dwellings where the residents are not in fuel poverty but where
potentially improvements could be made is 22.8 million. This represents an average
expenditure of approximately £800 per dwelling in 28,000 properties.

Increases in SAP rating are usually associated with a reduction in dwelling age; the most
modern stock has the highest SAP. This pattern is seen in Torfaen; the lowest mean SAP is
for pre-1919 properties at 48 and the highest is in post 1990 properties at 71. The majority
of pre-1919 properties are located in the Afon Lwyd Valley, Blaenavon and Pontypool and
the South of the borough holds mainly post-1945 built properties.

5.4 Developing a picture of Fuel Poverty across Torfaen

Identifying the demographics of those households experiencing fuel poverty is invaluable for
targeting assistance at those most in need. By gathering data from existing sources we are
able to approximately determine the level of fuel poverty at ward level. Map 1 has been
produced by the Welsh Government and identifies the areas which have a high proportion
of residents living in fuel poverty based on indicators from the 2001 Census and the 2004
‘Living in Wales’ survey. In the 10 wards highlighted in red at least 10% of residents within
these areas are believed to be living in fuel poverty.

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In addition we can develop a picture of the level of fuel poverty by compiling data received
from:

   -   Welsh Government’s Home Energy Efficiency Scheme 2005-2010 (replaced by Nest
       in 2011)
   -   Warm Wales program (2009-2010)
   -   Private Sector Stock Condition Survey (PSSCS) (2011)
   -   RSL stock condition survey data
   -   Torfaen Home Energy Efficiency Survey (2011-ongoing)
   -   Benefit information- those in receipt of benefits are likely to live in fuel poverty
   -   Age population data- households with children or elderly over 70 are more likely to
       live in fuel poverty
   -   Front line workers and service providers who engage with residents who may live in
       fuel poverty (environmental health, housing, social care officers, local health board,
       etc.)

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Most vulnerable wards in Torfaen

A ranking exercise has taken place using data collated from the above sources to rank wards
in order of vulnerability. The ranking considers the ward’s Fuel Poverty Indicator produced
by Welsh Government and supporting indicators of fuel poverty gathered by Torfaen County
Borough Council:

   -   Properties with a low SAP rating
   -   Residents on a low income
   -   Older persons over 70 years of ages
   -   Hard to treat properties (properties which cannot easily accommodate staple energy
       efficiency measures including solid walled houses and houses situated of the main
       gas grid).

Developing a picture of the level of fuel poverty in Torfaen is an ongoing task and the
rankings may change over time. Continuing to collate all available data will facilitate the
development of a robust cross-tenure evidence base to identify all households living in fuel
poverty. Accurate data will also allow for concrete targets and performance indicators on
progress to be developed.

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Priority ranking of wards most vulnerable to Fuel Poverty in Torfaen

         The following ranking has been formed from collating the WAG fuel poverty indicator with data assembled by Torfaen Council and mapped on GIS, including:
         Average SAP ratings, number of benefit claimants, number of persons aged over 70, and the number of hard to treat properties.

                                                                                                            Average SAP                                                                                  % of
                                        Total               % Private              Fuel Poverty                                    Average SAP
                                                                                                              Private                                     % of Benefit                                properties
Rank              Ward                Residential          Residential           Indicator for all                                   Housing                                     % Over 70
                                                                                                             Properties                                    Claimants              (Hometrack)          which are
                                      Properties           Properties                tenures                                       Association
                                           (ONS)                (ONS)            (Welsh Government)
                                                                                                          (HEES, Warm Wales
                                                                                                                                   (Bron Afon/HEES)
                                                                                                                                                              (NOMIS)                               ‘hard to treat’**
                                                                                                            & PSSCS data)                                                                                  (HEES)
1        Snatchwood                         859                 70%                14.8-16.1%                      45                      70                 26.4%                 13.9%                   55%
2        Blaenavon                         2552                 70%                16.2-17.9 %                     47                      70                 23.8%                 13.8%                   66%
3        Pontnewynydd                       644                 86%                14.8-16.1%                      40                      68                 23.1%                 11.4%                   57%
4        Brynwern                           829                 70%                14.8-16.1%                      46                      76                 25.9%                 12.6%                   36%
5        Panteg                            2851                 84%                16.2-17.9%                      55                      67                 14.5%                 13.5%                   43%
6        Wainfelin                          954                 87%                14.8-16.1%                      47                                         19.3%                  9.8%                   67%
7        Pontypool                          754                 80%                13.5-14.7%                      53                      72                  21%                  14.4%                   57%
8        Abersychan                        2761                 71%                16.2-17.9%                      59                      69                 24.9%                 11.5%                   42%
9        Llantarnam                        2061                 72%                 8.4-14.7%                      56                      69                 21.2%                 19.2%                   24%
10       St. Dials                         1705                 61%                 10-14.7%                       55                      67                 25.6%                 12.2%                   12%
11       Cwmynyscoy                         532                 72%                12.4-13.4%                      49                      75                 31.7%                 12.1%                   40%
12       Pontnewydd                        2652                 65%                 10-13.4%                       52                      64                 24.8%                 14.1%                   19%
13       St. Cadocs and                     617                 65%                 10-11.1%                       43                      61                 16.6%                 12.7%                   20%
         Penygarn
14       Trevethin                         1440                 52%                   10-11.1%                     47                      69                 33.7%                 6.7%                    13%
15       Croesyceiliog                      805                 84%                   10-11.1%                     57                      66                 11.6%                 24.7%                   11%
         South
16       Llanyrafon North                   912                 82%                  10-11.1%                      53                      65                 15.5%                 18.7%                    7%
17       Croesyceiliog                     1528                 78%                  8.4-11.1%                     57                      64                 17.2%                 16.7%                   10%
         North
18       Llanyrafon South                  1067                 94%                  2.8-11.1%                   57                     77                    10.4%                 16.6%                   16%
19       Upper Cwmbran                     2237                 62%                   8.4-9.9%                   55                     67                    24.1%                 8.2%                     8%
20       New Inn                           2658                 87%                  2.8-11.1%                   59                     73                    12.6%                  13%                     8%
21       Fairwater                         2146                 74%                   2.8-9.9%                   61                     67                    18.4%                 7.2%                     6%
22       Greenmeadow                       1530                 65%                   2.8-8.3%                   56                     69                    19.9%                 3.7%                     6%
23       Two Locks                         2579                 75%                   2.8-8.3%                   55                     62                     16%                  8.3%                    10%
24       Coed Eva                           899                 75%                   2.8-8.3%                   58                     68                    15.4%                   6%                     5%
                                                                                                            Average = 50           Average = 66

The above rankings take into consideration data collected from houses across tenure

* Residents who are in receipt of a means tested benefit or over 70 years of age are more likely to live in fuel poverty. Benefits in the above table include those who are of working age and claiming one or
                                                                                                                                                                                                            18more of
the following benefits: bereavement benefit, carer's allowance, disability living allowance, ESA and incapacity benefit, severe disablement allowance, income support, job seeker's allowance, and widow's benefit. Not
including: child tax credit, state pension credit, council tax benefit, and housing benefit

** Hard to treat households is a term used to define households that cannot accommodate staple energy efficiency measures, such as, solid walled houses or houses which are off the main gas grid. These houses
are often inhabited with fuel poor residents.
6. Aims and Objectives

  1. To provide Fuel Poverty advice
     The provision of good quality advice and information will be essential in tackling fuel
     poverty in Torfaen. Raising awareness of fuel poverty and identifying the most
     effective ways of addressing it, will ensure that residents are empowered to make
     the necessary changes to improve the energy efficiency of their homes.

  2. To make warmth more affordable by maximising incomes and lowering fuel costs
     Frontline staff should work with fuel poor households to ensure that they are
     accessing the benefits and support to which they are entitled and are directed to any
     additional sources of financial assistance to which they may be eligible.

  3. To develop housing policy for all housing tenures to include energy efficiency and
     to deliver affordable warmth for the long term
     Ensuring that a property is affordably warm or that the household has the means of
     achieving affordable warmth should form an integral part of any housing policy and
     should be reflected in many wider corporate agendas.

  4. Decrease incidents of cold related illness
     Housing will continue to build up a robust evidence base of fuel poverty in Torfaen
     and will seek to develop and maintain links with key partners, especially health and
     energy professionals, to target assistance to residents who are suffering from ill
     health as a result of fuel poverty.

  5. To co-ordinate delivery of an effective affordable warmth strategy
     To ensure that this strategy is properly implemented and monitored, the delivery will
     be overseen by the Strategic Housing Forum (SHF) via the Torfaen Energy
     Partnership and the Affordable Warmth Strategy officer sub-group. The Torfaen
     Energy Partnership will meet regularly to devise an annual operational plan that
     partners can sign up to. This will be reviewed on a 6 monthly basis and the Subgroup
     will be responsible for overseeing the implementation of the Strategy, ensuring that
     effective action is being taken to progress towards eradicating fuel poverty in the
     Borough. The Subgroup will monitor the work of all key partners and report to the
     Torfaen Energy Partnership. There will also be a quarterly update on progress made
     to the SHF.

  6. To improve the energy efficiency of Homes in Torfaen
     To continue to identify ways in which residents of Torfaen can be assisted to
     improve the energy efficiency of their properties and reduce the risk of fuel poverty.

                                                                                          19
7. How we intend to address Fuel Poverty

Fuel Poverty is an issue that affects many people in Wales and cuts across a number of
service areas including housing, health, wellbeing, regeneration and education. To address
fuel poverty will require joint working across departments and organisations to provide a
comprehensive and holistic approach to achieving affordable warmth in Torfaen.

Through the development of a robust evidence base, Torfaen Council will be able to identify
areas of fuel poverty and prioritise those areas where intervention is most needed. In
partnership with different schemes, Torfaen will target resources to the most fuel poor
households in Torfaen.

7.1 Publicity

Through the development of a robust evidence base, Torfaen will be able to identify areas
of fuel poverty and publicise schemes that are currently available to the public and
encourage them to improve the energy efficiency of their property.

        Torfaen Homes Website – www.torfaenhomes.co.uk
        Energy Efficiency Leaflets
        Providing front line staff with information on fuel poverty advice including support
        on income maximisation and the various grants and funding available
        (See appendix 1)

7.2 Private Rented Sector Project

This project, managed by the Energy Saving Trust, will work with Local Authorities to trial a
strategy for encouraging private landlords to make improvements to their properties.
Through the development of a package offering a range of services, the project aims to
address private sector accommodation in areas where such funding is not available and
achieve its vision enabling everyone to lead a low carbon lifestyle. The project will:

    -   Identify the level of fuel poverty in Torfaen, particularly in the private rented sector
    -   Raise awareness through publicity material to reduce fuel poverty, (from September
        2011 through winter months)
    -   Improve the condition of properties in the private rented sector through targeting
        landlords and tenants,
    -   Work in partnership and consult with a range of key stakeholders (e.g.
        Environmental Health, Lettings Agents, 3rd sector agencies)
    -   Provide training for front line staff
    -   Publicise available funding opportunities

Details about the work of the Energy Saving Trust can be accessed at: www.est.org.uk
Sarah Evans is the Project Officer for this project in Torfaen and can be contacted on 029
2047 5985 or emailed at s.evans@est.org.uk

                                                                                               20
7.3 Arbed 2

Torfaen Housing Services are currently working with partners (Energy Saving Trust and local
RSL’s) to develop 2 schemes within the Borough. The schemes are being developed using a
robust evidence base to ensure the worst areas are targeted based on the Assembly
Government’s set criteria.

Although there is no guarantee that Torfaen will be successful in the bidding process, as the
Welsh Government has estimated that between 10 -15 schemes will be successful each
year, Torfaen Council will do its best to bring inward investment into the Borough. If we are
successful then improvements to homes such as external wall insulation will be carried out
on the selected properties within the worst affected communities.

7.4 NEST
The Nest programme is designed to help people who are struggling to pay their energy bills.
The scheme offers a range of free home improvements to help people heat their homes
more efficiently and stay warm without facing huge energy bills. Nest takes a ‘whole house’
approach to determining what energy improvements would be most suitable:
   -   Loft and cavity wall insulation
   -   Solid wall insulation
   -   Draft proofing
   -   Boiler replacement
To qualify, an applicant must be in receipt of a means tested benefit, their property must
have an energy efficiency rating of F or G and be privately owned or privately rented.
Potential applicants will talk through a Home Energy Check survey with their Nest advisor to
establish the energy efficiency rating of their property.

As well as support in accessing energy efficiency improvements, Nest can also assist people
to access guidance on benefit entitlement, energy tariffs and money management.

Householders can contact Nest on their free phone number - 0800 512 012.

7.5 Encourage Community Initiatives

Continue to identify opportunities for promoting energy efficiency within local communities.

                                                                                          21
7.6 Green Deal

For the most comprehensive information about the progress of the proposed Green Deal,
contact the Department of Energy and Climate Change.

Department of Energy & Climate Change
3 Whitehall Place
London
SW1A 2AW
Tel: 0300 060 4000 (standard national rate)
Email: correspondence@decc.gsi.gov.uk

7.7 Renewable Heat Incentive

For more details about the Renewable Heat Incentives, contact the Department of Energy
and Climate Change (See above).

7.8 Feed in Tariffs

For impartial, comprehensive information about Feed In Tariffs, contact the Energy Saving
Trust on 0800 512 012.

7.9 Powering up Communities First
The Powering Up Communities First programme engages households across Torfaen,
installing solar panels in areas of low income to improve energy efficiency standards and
reduce fuel bills. The programme also delivers workshops in the community and one to one
sessions to householders to show how they can save money through changing behaviours.
This will enable them to reduce their energy use, putting pounds in their pockets and reduce
their CO2 emissions.

Powering Up Communities First will also signpost householders to other Torfaen energy
schemes where they can obtain grants and link to other initiatives. Householders can
contact the Powering Up Communities First team at:

Melin
Ty’r Efail
Lower Mill Field
Pontypool
Torfaen
NP4 0XJ
Tel: 01495 745910 Ex2214
Email allison.cawley@melinhomes.co.uk

                                                                                            22
Appendix 1 - Grants and Funding currently available to support for residents

Grant/Funding    What is it?                             Who is eligible?            Suitable for           How can you apply?
Nest/Nyth        Nest is the Welsh Government’s          Householders must;          Any householder        Call the Energy Saving Trust
                 flagship scheme to combat fuel          Own or privately rent       receiving a means      advice line on 0800 512 012 or
                 poverty. The fully funded grant can     their home,                 tested benefit, who    visit: www.nestwales.org.uk
                 be used to install energy efficient     Be in receipt of a means    would gain from
                 measures in homes to improve            tested benefit,             energy efficient
                 comfort, create healthier homes and     Live in an energy           installations.
                 reduce fuel bills.                      inefficient property with
                                                         a rating of F or G.
CERT             The Carbon Emissions Reduction          People on means tested      Any householder        To find a suitable CERT scheme,
                 Target (CERT) is a statutory            benefits.                   receiving a means      call the Energy Saving Trust on
                 obligation on energy suppliers to                                   tested benefit, who    0800 512 012.
                 reduce CO2 emissions in the                                         would gain from
                 domestic sector. Eligible measures                                  energy efficient
                 include; cavity wall, solid wall and                                installations.
                 loft insulation, glazing, heating
                 systems, lighting and appliances, and
                 micro generation and community
                 heating.
Social Tariffs   Social Tariffs are available through    In general, the             Households on          You can contact your energy
                 all major energy suppliers and they     householder must be an      means tested           supplier directly or call the Energy
                 can provide discounts on energy         existing energy supplier    benefits who are       Saving Trust on 0800 512 012 to
                 bills, usually between 10-15%.          customer, and be in         struggling to afford   be referred onto a social tariff
                                                         receipt of means tested     their fuel bills.      scheme and gain income
                                                         benefits.                                          maximisation support and advise.
Energy           Grants to help households in need,      Grants for debts will       Anyone who is in       British Gas:
Supplier Trust   meet the cost of arrears on energy      usually be made in          debt with their        www.britishgasenergytrust.org.uk
                                                                                                                                              23
Funds            and other household bills.                exceptional                energy supplier and     Npower:
                                                           circumstances where the    struggling to pay       www.npowerenergytrust.org.uk
                                                           individual can show that   their bills.            Eon: 0800 051 1480
                                                           clearing the debt will                             EDF: www.edfenergytrust.org.uk
                                                           enable them to budget
                                                           better for their current
                                                           bills.
Fuel Direct      Fuel Direct allows an individual to       Individuals with unpaid    Anyone who is in        The individual will need to
                 pay energy suppliers directly from        fuel or water bills, who   receipt of certain      contact the Department of Works
                 their benefits. It covers their current   are in receipt of Income   benefits and            and Pensions or their local
                 fuel use and makes a contribution         Support, Pension Credit,   struggling to budget    Jobcentre Plus and advise their
                 towards clearing their unpaid bill.       Employment and Support     for their fuel bills.   energy supplier.
                                                           Allowance, or Income
                                                           based Jobseekers
                                                           Allowance.
Welsh Water      Welsh Water Assist provides               If any member of the       Anyone household in You can request an application
Customer         financial assistance to low income        household receives any     receipt of certain    form on the Welsh Water website
Assistant Fund   households with either large families     of the following:          benefits, which uses or call 0800 051 0145.
                 or a medical condition that requires      Income Support             a high amount of
                 high water use, by capping their          Income based Jobseekers    water due to medical
                 charges at £114 a year for water and      Allowance                  or family conditions.
                 £114 a year for sewerage.                 Council Tax benefit
                                                           Pension Credit
                                                           Income related
                                                           Employment and Support
                                                           Allowance
                                                           Housing Benefit
                                                           Child Tax Credit
                                                           Working Tax Credit

                                                                                                                                           24
Cold Water      A Winter Fuel Payment is an annual        Winter Fuel Payments        All households who   Those of retirement age should
and Winter      tax-free payment made to older            are automatically paid to   are of retirement    automatically receive a winter
Fuel Payments   people to help towards their winter       residents who are of        age.                 fuel payment or a cold weather
                heating costs. Payments are usually       retirement age.                                  payment. However, if there are
                made in November and December.            To qualifying for                                any issues, it is best to contact
                A Cold Weather Payment helps              payments in 2011/2012,                           the Department of Work and
                towards extra heating costs between       you will need to be born                         Pensions www.dwp.gov.uk
                1 November and 31 March.                  on or before 5 January
                As soon as the average temperature        1951.
                for a particular area is recorded as 0°
                Celsius over seven consecutive days,
                a payment of £25 is automatically
                paid to eligible people living in that
                area.

                                                                                                                                               25
Appendix 2 - Torfaen Affordable Warmth Strategy – Action Plan
Aim 1 – To provide fuel poverty advice
Objective

1.1 Provide up to date and targeted advice on fuel poverty in the home where required.

   Lead                 Activity                     Half Yearly Progress                End of Year Progress
  Agency /
  Partners

TCBC           Design & maintain a
Housing        webpage to provide
               advice on fuel poverty and
               energy efficiency.

TCBC           Establish an ongoing PR
Housing        campaign (e.g. Energy
               Advice leaflet) targeting
               specific groups

RSLs /         Include more information
Strategic      around energy awareness
Housing        in tenants handbooks /
Forum (SHF)    Webpages / Publications

Torfaen        Ensure information is
Energy         disseminated through
Partnership    other agencies and
(TEP) / Anti
                                                                                                                26
Poverty       support workers.
Group

Objective

1.2 Give support to advice workers

Energy Team   Develop specialist briefing
              sheets e.g. for support
              workers.

Energy Team   Identify training needs of
              advice workers.

Energy Team   Source and explore
              relevant fuel poverty
              training to those who
              require it.

Objective

1.3 Promote Energy Awareness

TEP / Anti    Promote awareness of
Poverty       energy efficiency and fuel
Group         poverty among target
              groups including:

                     Elderly
                     School Children
                     Communities First

                                            27
Aim 2 - To make warmth more affordable by maximising incomes and lowering fuel costs
Objective

2.1 Ensure household income is maximised

Lead Agency              Activity          Half Yearly Progress   End of Year Progress
 / Partners

   TCBC           Publicise Grants and
  Housing         funding opportunities.

 TEP / Anti       Demonstrate the
  Poverty         benefits of energy
  Group           efficiency measures.

Frontline staff   Provide information
                  and advice about
                  prices and payment
                  methods and support
                  for those experiencing
                  difficulties.

                                                                                         28
Aim 3 – To develop housing policy for all housing tenures to include energy efficiency and to deliver
affordable warmth for the long term
Objective

3.1 - Identify fuel poor households

   Lead                    Activity              Half Yearly Progress          End of Year Progress
  Agency /
  Partners

               Analyse Housing stock
               energy efficiency data and
   TCBC        link with social and health
  Housing      indicators to identify those in
               fuel poverty.

TEP / SHF /    Incorporate affordable
  TCBC         warmth questions in to
 Housing       outcome assessments.

               E.g. Tenant satisfaction
               surveys / Renewal
               Assessments

   RSLs        Housing Associations to
               identify tenants living in fuel
               poverty.

                                                                                                        29
Objective

3.2 - Develop Energy Efficiency Priority Areas

    TEP        Develop mechanism for
               identifying areas

    TEP        Focus energy awareness
               raising on identified areas

    TEP        Secure funds to install
               energy efficiency measures
               in homes in these areas.

Objective

3.3 - Identify energy efficiency rating of properties

    RSLs       RSL’s to provide energy
               rating information at change
               of tenancy.

    RSLs       RSL’s to carry out energy
               ratings when relevant works
               have been carried out.

   TCBC        Source data of private sector
  Housing      energy ratings.

                                                        30
Aim 4 – Decrease incidence of cold related illness
Objective

4.1 - Ensure that health professionals link the health benefits of warm, dry homes with energy efficiency and affordable warmth

  Lead                 Activity                     Half Yearly Progress                           End of Year Progress
 Agency /
 Partners

              Collate research of the
              health benefits that
              energy efficiency
              measures and potential
              savings to
TEP / TCBC
Housing       health authorities of
              providing warm dry
              homes.

TEP / TCBC    Expand distribution list
Housing       for information about the
              links between poor
              housing and poor health
              to all relevant health
              professionals.

Energy Team   Provide support to health
              professionals to provide
              fuel poverty advice.

                                                                                                                                  31
Objective

4.2 - Identify those most at risk from cold related illnesses and ways of targeting them with preventative advice/ measures.

TEP            Discuss with partners
               best methods of
               targeting

TEP            Use indicators from
               health partners

TEP / TCBC     Link indicators with
Housing        data on energy
               efficiency of housing

               stock and social
               inclusion indicators.

                                                                                                                               32
Aim 5 – To co-ordinate delivery of an effective affordable warmth strategy
Objective

5.1 - Co-ordinate implementation of the strategy

   Lead               Activity                     Half Yearly Progress   End of Year Progress
  Agency /
  Partners

 TEP / Anti    Gain commitment from
  Poverty      other agencies to
  Group        undertake
               implementation by
               promoting the strategy
               and its benefits

   TCBC        Identify appropriate
  Housing      base line information
               and set targets

Objective

5.2 - Monitor, evaluate and review the strategy

   TCBC        Evaluate progress
  Housing      towards targets.

                                                                                                 33
TEP / Anti   Review the strategy in
  Poverty     light of developments
  Group       in fuel poverty and
              related issues at a
              national level.

   TCBC       Refine strategy as
  Housing     necessary.

    TEP       Share Best Practice
              with other
              organisations by
              means of the TEP and
              SEWEP networking
              groups.

Objective

5.3 - Ensure ongoing financial resources for the strategy implementation

    TEP       Keep abreast of all
              funding / Grant
              sources.

    TEP       Develop bids to make
              use of what funding is
              available.

    TEP       Keep affordable
              warmth strategy high
              on the political agenda.

                                                                           34
Aim 6 – To Improve the Energy Efficiency of Homes in Torfaen
Objective

6.1 – Deliver energy efficiency measures

   Lead              Activity              Half Yearly Progress   End of Year Progress
  Agency /
  Partners

RSL’s / TEP /
   TCBC
  Housing

                                                                                         35
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