Equality and Social Justice Committee

Welcome back to the Equality and Social Justice Committee meeting, where we're looking at fuel poverty and the Warm Homes programme. I'm delighted to welcome Ben Saltmarsh and Jack Wilkinson-Dix; Ben Saltmarsh from NEA and Jack Wilkinson-Dix from the Energy Saving Trust. Both of you are experts in this field, so you're very welcome indeed. Sarah Murphy is going to start off the questions. Sarah.

Thank you, Chair. Thank you, both, for being here today. This is a very vital and timely inquiry that we're conducting, and, again, thank you very much for submitting the evidence that you have. I'm going to start with a very broad question: what is your assessment of the extent to which the current Warm Homes programme has contributed to actually tackling fuel poverty in Wales? If I can come to you first, Ben.

Yes, that's absolutely fine. Thank you, Sarah. It's an absolutely critical time, as you say, not least, obviously, with soaring energy prices right now as well, and perhaps we can touch on that a little later. But, as you say, in relation to the question that you've just asked, I understand that, since its launch, the Warm Homes programme has invested something like £394 million into improving the energy efficiency of something like 67,100 homes in Wales, and, yes, that should make those homes less likely to be in fuel poverty. I think, for its recent beneficiaries, that should, hopefully, make the current crisis easier to bear than it might otherwise have been as well. Public Health Wales estimate, as you may well know, that, for every £1 you spend investing in making a vulnerable person's home warmer, then you would see a resulting £4 in health benefit. So, that £394 million could well see significant savings to the NHS in Wales too, which is something to be praised.

However, I think, perhaps in three areas, it's important to note that, whilst very welcome, in terms of scale, targeting and the measures of the current programme, there are mixed views and some concern. So, in terms of the scale, I think it's widely acknowledged now that the current schemes have not been sufficient to address the scale of fuel poverty in Wales by 2018 estimates, let alone 2022 estimates. I think the Minister for Environment, Energy and Rural Affairs in 2019, as part of the Climate Change, Environment and Rural Affairs Committee's inquiry into fuel poverty, at that time said that if those 2018 estimates were to be believed, then the funding of the Warm Homes programme would need to be more than doubled, and the future generations commissioner has also just called on the Welsh Government to do the same, as well as for additional funding from UK Government. So, it's quite clear that the likely scale of fuel poverty now will require much larger numbers of households to be lifted out of fuel poverty every year than has hitherto been the case.

I think, in terms of targeting, there are mixed views on its impact on reducing fuel poverty and some serious questions have been raised too as to how effective those schemes have been in targeting those in fuel poverty and in greatest need of support. I think the Climate Change, Environment and Rural Affairs Committee—which I might just stop saying and just say CCERA, if that's okay, after this point—noted in 2019 that it would be very hard to be precise about the impact. For Arbed it's very unclear, not least because the annual reports simply don't state whether you were in fuel poverty before or after the intervention, and, for Nest, while it does so, I think the majority of those who've received measures in most recent years have not been in fuel poverty: 57 per cent, I think, in 2018-19; something like 63 per cent, 64 per cent, in 2019-20; and just under 50 per cent in 2020-21. So, that's obviously very important to note too.

And so too, I think, in terms of measures, the vast majority of measures, as you may have heard elsewhere, that have been installed, especially under Nest, but, I think, more broadly too, have been replacement boilers and central heating systems. That, while welcome for households, has been to the detriment of really meaningful fabric upgrades that would make a permanent solution to lower bills, and many long-term benefits. And, I think, we were concerned by the scheme manager's response in 2019 too that those measures—fabric upgrades—were seen as additional and secondary. So, I think I would probably highlight those things in starting.

Thank you so much. That's a brilliant, comprehensive, quick answer to get us—[Inaudible.] Thank you. Jack, can I come to you next, please?

Yes, of course. Just to pick up on something Ben said there that I think is really important, the scale of the challenge that we're facing now is really unprecedented. You have to go back 50 years before we see price rises that are of the same magnitude, and there are lots of factors that suggest that this could be worse than the crises we saw back in the 1970s. So, the issue around scale is really important, and we need to think, when it comes to the future of the next programme, about what the funding package is like to help address that challenge.

So, before I answer some of the questions around delivery, I think it's just important for me to just spell out what the Energy Saving Trust's role is within the different programmes of the Warm Homes programme. So, we are subcontracted by British Gas to deliver the advice portion of Nest, and so that includes things like marketing, signposting to other services, benefit entitlement checks, and that first eligibility confirmation. Anyone who's then successful is then passed on to British Gas, who deliver the measures and stay in contact with households from that point onwards. And then, as for Arbed, we were involved in the delivery organisation, but we didn't deliver any measures ourselves. So, I'm more than happy to try and answer some of the delivery questions, but I might have to come back in writing with some of those details, because I don't personally work on delivery.

So, anyway, back to your point, I think that both schemes have helped thousands of households improve their energy efficiency and lower their bills. There are lots of challenges because of, perhaps, the way that the scheme was designed: the caps, the level of caps, the ability for people to access support more than once have meant that more heating systems have been installed than energy efficiency measures, perhaps. But I think that both schemes have delivered against what the programmes were designed for.

Thank you. Thank you, both, so much. I'm going to pass back to the Chair now, as my colleagues are going to drill down into what you said. Thank you.

Thanks. We'll move across to Jane Dodds.

Thank you very much. Good afternoon.

Good afternoon to you both.

You've touched a little bit on the evidence and the data already. May I ask you what kind of data and evidence will be important for us to gather with regard to a future programme, please? What's important for us to focus on in future if there were to be a new programme to replace the Warm Homes programme, such as with Arbed and Nest? Thank you very much. Ben first of all.

Ben first. Thank you.

We're, unlike the Energy Saving Trust, not involved in the direct delivery of the programme, so we can only really reflect on the publicly available information that we're aware of from the likes of the annual reports and others' recent analysis, for example, like the Audit Wales recent report into the Warm Homes programme, too. I think it's probably fair to say that the annual reports of both Nest and Arbed seem only to highlight high-level outputs, if you like, and, as I said earlier, in terms of the impact that's Arbed's having, even at a high level, that was unclear as to its impact on reducing fuel poverty. And whilst Nest does, obviously, the majority of those that have been supported in recent years haven't been in fuel poverty.

I think CCERA highlighted some serious concerns over a lack of a robust monitoring and evaluation framework, without which it said it was impossible to be able to measure the scale of the impact, which is absolutely crucial and fundamental given that this is, obviously, the Welsh Government's key delivery mechanism to tackle fuel poverty in Wales. And, ultimately, what we're really talking about here, as Jack was saying, is that this is an unprecedented issue right now, and we're talking about, we would estimate, come April, something like an estimated 280,000 homes to be in fuel poverty as the price cap goes up by 54 per cent. I know we're very familiar with those figures at the moment, but it's easy to kind of become numb to them if you say them too often. But we really mustn't, because this is a huge, huge scale, and that's 100,000 further households since October, when the price cap rose last, and an 80 per cent increase on Welsh Government's 2018 estimates. As I've said elsewhere, and as some of you may know, what we're really talking about are fuel-poor households where home isn't really a home—it's not a place of rest or comfort; it's a place that you have to endure, bear and try to survive, or avoid, as long as possible; a place where, during the day, you go without energy entirely, or camp in one room because that's all you can afford to heat, and at night you put yourself and your children, or other members of your household, to bed against walls and underneath ceilings that are full of black mould. So, I think those outlets are very important, and it's surely very important to us, obviously, if you're in fuel poverty before or after the intervention, but it's very important too that we look to get much more robust monitoring and evaluation that would speak to some of the outcomes of those interventions also.

I think the only other thing, perhaps, that I'm able to highlight from what we're aware currently is that the Audit Wales report also highlighted significant concerns with Welsh Government's monitoring of contracting arrangements, including that they need to be tightened and more tightly managed. I think we mentioned in our evidence that we'd expect those issues to be addressed at any forthcoming, future iteration, but also that it's very important that formal arrangements are put in place for any redress or issues that might become apparent, so that they're remedied for households. But just by way of a couple of examples, just looking at the notes here, I think there are steep differences in the way the Welsh Government paid the two scheme managers for the same energy efficiency measures in pre-defined property types. There were contractual issues about scheme managers claiming full payment for when they only actually ended up fitting one or two light bulbs or aerators, and generally a lack of what should have been, in Audit Wales's words, readily available management information. So, whilst I'm not privy to what that information is, it seems like there are issues there that need to be reviewed.

Jack, if you'd like to come in—I think Jane's having difficulties.

Again, I'm not privy to a great deal more information than Ben is around some of those contracting points raised by Audit Wales. I think that the data that would be really useful at the moment would be to have updated fuel poverty estimates. I think that that's something that we're really lacking, and I think a really important point is that, while the percentage of people who are supported through Nest who are registered as fuel poor, as Ben said, is around 50 per cent, I think it's really important to point out that the vast majority of the other 50 per cent are people who are on low incomes, who are vulnerable, who are likely in sections of society that, especially after these price rises, will be at even more risk of being in fuel poverty. I think we have to be careful to not suggest that, because the other 50 per cent of people that were supported through the Warm Homes programme weren't technically in fuel poverty at that moment, they weren't deserving of support, especially now that prices are rising as fast as they are.

So, having updated fuel poverty estimates would be really beneficial. Hopefully, we see those before the end of the consultation on the Warm Homes programme, and something that I'll get a chance to talk about when we're talking about the future scheme is a greater degree of hand holding and in-home support and in-home advice. It would be really useful to see the findings of the in-home advice pilot and to better understand which groups in society are at risk of being vulnerable to being in fuel poverty. There is a lot of academic work out there that looks at certain circumstances that households might be in—whether they're a single-parent household, whether they are able to claim benefits, whether they're an asylum seeker, et cetera—which put households at greater risk of being in fuel poverty. We have wondered whether the future scheme could look at expanding the health conditions pilot and how that operates, and use that information about who is at risk and who is vulnerable to look at less prescriptive eligibility criteria.

Jane, were you planning or wanting to come back? No. Okay. I just want to press you, Mr Wilkinson-Dix, because you were the central co-ordination point for the Nest scheme, and half owners in the 50:50 joint venture in Arbed. So, I'm just struggling to understand why you weren't able to have a better handle on some of the anomalies that are highlighted by the auditor general's report.

Well, because, really, the central co-ordinator for the Nest scheme is British Gas as the managing agent, and I understand that you are planning to speak to British Gas and they'll be able to talk to you in greater detail about Nest. As for Arbed, I can get back to you in writing. I wasn't involved in Arbed myself, or in delivery in general, but I'm more than happy to come back with more detail, more written evidence.

Thank you. That would be extremely useful, because I think it's important that we learn from the past.

Of course.

Okay. Sioned Williams, would you like to come in at this point?

Thank you, Chair, and this question is specifically for Ben. Your evidence—NEA's evidence—notes the calls that you made for interim fuel poverty targets, and they, of course, weren't included in the Welsh Government's latest fuel poverty action plan. So, I just wanted to ask why you believe that having those interim targets was so important. What should those targets be, and what will the impact of not having these interim targets be?

Thank you for raising that, Sioned. As you say, the Welsh Government's tackling fuel poverty plan has three non-statutory targets, all to be achieved by 2035. And then, as you rightly say, there are no interim objectives, no interim targets against which progress can be measured in-between now and then. And that was a key omission, in our view, but also in the view of many other respondents to the consultation at that time, including the End Fuel Poverty Coalition Cymru, of which the Energy Saving Trust are a part, and the cross-party group on fuel poverty and energy efficiency, and, I think something, if I remember correctly, that the Welsh Government noted in its consultation outcome report that respondents had made quite a compelling case for. I think, put simply, to answer your question, non-statutory targets that were 15 years away, that spanned three Senedd terms, with no interim milestones, are quite unlikely to drive the sustained and necessary actions that are required to tackle fuel poverty in Wales. And I think also it's worth highlighting, for sure, that interim targets are actually a statutory requirement under the Warm Homes and Energy Conservation Act 2000 as well.

The Welsh Government, to its credit, has since committed to the fuel poverty advisory panel that's been set up as one of the actions under that tackling fuel poverty plan, and that it will look to include interim targets as a matter of urgency, and I think it's something it's due to consult on after the publication of those updated fuel poverty projections that Jack referred to earlier, which are due in the spring. And helping upgrade, obviously, the energy efficiency of fuel-poor homes, especially for those worst affected first, those on the lowest incomes living in the least efficient homes, is directly in the control of the Welsh Government and needs to be a clear priority. So, for that reason, we and the End Fuel Poverty Coalition at the time, suggested that it was imperative that Welsh Government commits to an interim target that's based on and bakes in improving the energy efficiency of fuel-poor homes by a certain set date. So, I think we suggested that it should at least match the requirement in England to reach EPC band C by 2030; if not, EPC band A by 2030, as recommended by the Wales decarbonising homes advisory group in the Jofeh report. We also, at the time, suggested that they could bring forward the target to eliminate severe fuel poverty for those who'd be needing to spend more than 20 per cent of their income in order to adequately heat their home earlier to 2028. So, essentially, what we're asking for there is to embed the very welcome worst-first and fabric-first overarching policy goals into the actions and the targets that Welsh Government have set.

Thank you. Thank you, Chair.

Thank you. Could we move to Ken Skates now?

Thank you, Chair. We've asked this same question to a number of people who have given evidence, and it concerns the current programme and whether it reflects the needs of rural households that are fuel poor. What's your view on this? And do you think there should be specific support made available to meet the challenges of those who live in rural areas and suffer from fuel poverty?

Who would you like to come in first?

It's to both, but perhaps Jack first.

Yes, of course. I suppose the first thing to say is that the existing programme does, in a roundabout way, seek to offer more funding to rural households, in that you can access a higher funding cap if you're in a home that is at a lower EPC band, and if it's off gas. Because rural properties tend to be of lower efficiency and are more likely to be off gas, some rural households are able to benefit from those higher caps. Obviously, that is a bit of a roundabout way of supporting rural households with higher funding. Going forwards, I think it's entirely possible to set up a scheme that has extra funding for rural households, that recognises that they are more difficult to treat, often, that they are unique properties, in many cases solid wall and off gas. I think that when we talk about in-home advice and more bespoke advice, it's these kinds of properties that would be benefiting from that kind of in-home advice, potentially.

And then, just finally—I believe that this has been brought up in previous sessions—a lot of the costs related to rural households are not actually the measures that are being installed; it's the fact that supply chains aren't as strong in rural areas. There is a lack of skills in some rural areas. And so there is a bigger piece around boosting skills right across Wales that will help to bring down costs in rural areas.

Building on from that, and then linking back to the previous answer as well around interim targets, the other benefit, of course, is that that that will give confidence to those supply chains that this investment will be available year in, year out, as Jack has just highlighted there.

I think, Ken, in answer to your question, just to take a step back as well, we at NEA really firmly and strongly support that worst-first, whole-house approach that was the original intention of the Warm Homes programme, to look at heat and look at the fabric of those homes. I think, from the way the programme has evolved, it seems that it's perhaps increasingly falling short of its original whole-house intended approach, and that's to the detriment of improving the energy efficiency or the fabric of those beneficiaries' homes, particularly in terms of Nest, but I think to some extent in terms of Arbed also. It's very clear from the Audit Wales reporting that both have relied very heavily on boiler replacements and central heating installations.

In Nest, I think we're talking something like 94 per cent in one year and then 95 per cent in 2020-21 of all measures were for central heating boiler replacements, leaving about 5 per cent for standard installation, of which that standard installation is made up of loft insulation and then something like 0.1 per cent of draught proofing. So, we're really talking to the detriment of other very meaningful fabric upgrades, like cavity wall insulation or solid-wall insulation—those measures that I alluded to at the very beginning that provide those really long-term meaningful benefits and a permanent solution to lower bills, by reducing the amount we need to heat that home in the first place by reducing their demand and making them much warmer for less. That's not only to the detriment across the programme as a whole, but I think that's particularly to the detriment of rural, off-gas households, particularly off-gas solid-wall households.

We know already that Wales has the largest proportion of inefficient solid-wall properties, with higher numbers in rural areas. I think the highest estimated percentage of fuel poverty in 2018 by the Welsh Government's most recent estimates were in central and western areas—Gwynedd at 23 per cent, Ceredigion at 21 per cent. That's compared to a national average of 12 per cent—obviously, figures that may well be much higher now. And many rural households, of course, are not connected to the mains gas grid and rely, often, on more expensive fuels like oil and LPG, which are already seeing significant rises in prices, and they don't benefit from the same protections as gas and electricity.

Then, when you add to that those compounding challenges of needing to purchase that fuel upfront, when you have to pay a premium to be able to travel, you've got digital exclusion or connectivity issues, and often social or spatial isolation, I think that really highlights—and this will go back to something the Climate Change, Environment and Rural Affairs Committee found in 2019 too—that that meaningful, tailored provision, aimed specifically at addressing the distinct challenge in rural areas, is really much required. And I think when you again look back at the 2019-20 figures, something like 0.5 per cent of off-gas measures that were installed through Nest were for insulation, which would suggest that fewer than 10 off-gas households received solid-wall insulation—fewer than 10—despite there being 65,000 off-gas solid-wall properties in fuel poverty at that time. So, that's what I mean when we come back to the judgment of the fabric upgrades and the specific challenges for rural areas.

Thanks, both; really, really intriguing answers. I'm going to just move on to talk specifically about Nest and the eligibility criteria for support. Do you think that the use of these EPC ratings and means-tested benefits is the right approach? Do you think that perhaps the Nest scheme's eligibility criteria has limited its impact?

Would you like me to go first?

Yes, please.

I think that when the Nest scheme was first conceived more than 10 years ago, at that time, means-tested benefits were a useful and workable proxy for people being in fuel poverty. At that point, about 68 per cent, I believe, of people who were in fuel poverty were on means-tested benefits. In the intervening years, that situation has changed so that now, around 70 per cent of people who are in fuel poverty are not on any means-tested benefits.

Clearly, whilst still being a useful thing to consider as part of eligibility criteria, it's obviously not telling us the whole picture any more. There are lots of people who, if we just look at means-tested benefits, will end up slipping through the cracks. Something that we would like to see, and I've sort of alluded to it and mentioned it already in my answers—. One of the great successes of the Nest scheme has been the health conditions pilot, and that's now accounting for about 25 per cent of all people who are supported through Nest with measures. That has allowed a greater flexibility of eligibility, so people with health conditions are now able to access the scheme at a slightly lower threshold than they would otherwise be able to.

Taking that model and applying it to other household circumstances that could mean they're at risk of being in fuel poverty would be really beneficial. I think that in general, a slightly less prescriptive approach would be beneficial, looking at an income threshold, but perhaps looking at what the purchasing power of a given household is, so considering how many dependents they have, what the local housing costs are, having it not be that there's a line in the sand and below that point you're not supported, above that point you are. I think that would be really useful, to just be more aware of the nuances and complexities that individual households have.

Thanks, Jack. Anything to add, Ben?

I think we would echo that very welcome expansion of the Nest scheme eligibility criteria beyond those just in receipt of means-tested benefits to also target those on a relatively low income, either because they then have a health condition that was exacerbated by the cold—a physical or mental health condition—or they're over the age of 75. And as Jack said—I think I've just heard him say it there—that accounts for 25 per cent of all referrals, and I believe in previous evidence to this committee, Warm Wales, for example, suggested perhaps that that actually accounts for a far higher proportion of the numbers of households they go on to support to access it.

I know it's been a very, very welcome development, and in our minds, we really support the Warm Homes programme's intentions to support those that are worst affected first, so those on the lowest incomes, living in the least efficient homes. We're really pleased to see that principle made explicit in the tackling fuel poverty plan, and it's also something that's been echoed in the net zero Wales plan also. For us, the next programme must focus on lifting households out of fuel poverty, supporting the worst first, as I've just described, and should be designed to include low-income households that are living in or at risk of fuel poverty, irrespective of whether they're on means-tested benefits. So, including those that are, and that includes those in and out of work, but also that relative low income, is something that's been very welcome indeed.

I think I would probably conclude there, other than to perhaps say—. Sorry. Perhaps as part of the 2018 estimates, it is worth noting that the majority of those in fuel poverty at the time were not in receipt of means-tested benefits; something like 69 per cent. So, perhaps it's done a complete flip from what Jack mentioned at the beginning—did you say, Jack, something like 68 per cent at the beginning were on means-tested benefits, and we've gone to the opposite now, where about 69 per cent aren't?

Thanks, Ben. I'm just going to ask a question of Jack, if that's okay, and it's just regarding referrals experiencing barriers to receiving support from Nest, or having difficulty engaging fully. Is it monitored? Is it being monitored? What's your assessment?

As I mentioned, once someone has passed the initial eligibility check through the advice centre, British Gas then walk that household through the remainder of the process, through installation and post install. I'm not aware of what the monitoring is there. I can look to find out and write back, I just don't have that to hand at the moment. We've looked at the previous session and the evidence that was given, and I think that one thing that is really important to point out in the success of the Nest scheme is this partnership working and these referral pathways. The fact that we do have these relationships, not just with local authorities and with debt advice, but also with third sector organisations like Warm Wales, has been really beneficial. It means that there is support available for households that need more hand holding. Nest was not designed and was not set up to offer that hand-holding support. Some of it is able to be provided through that partnership working, but when we're thinking about what the future programme should look like, having that actually form part of the delivery programme would be really beneficial, so that you can support people from start to finish, post install as well, so that they have advice on how to use their home and their new heating system as well.

Actually, Jack, any further information that you might be able to extract would be really helpful regarding monitoring. And also confirmation of whether there's been an evaluation at all of the Nest helpline, and if so, what the findings are. I don't expect you to have that information to hand, but that would be very helpful.

In terms of people's customer satisfaction of the Nest advice line, it ranks in the mid to high 90s and has done for at least the last five years. In the Nest annual report, which was compiled by British Gas, they've got a customer satisfaction of 99 per cent, I think. Of course, those are people that have gone through the entire process, so there's potential there that people that have fallen out of the scheme haven't been able to maintain that engagement throughout. With a scheme of this scale, that is unfortunately going to happen in some instances. People aren't going to get the support that they perhaps needed and that we would like to see them have. That's definitely something that we need to—all of us, not just EST, but in general—ensure, that the next programme supports those people who are most vulnerable with that kind of hold-holding support.

Okay. Thanks, Jack. Thanks, Ben. Back to you, Chair.

Thank you. Tom Giffard.

Thanks, Chair. Can I just ask about Arbed, which, obviously, ended in November, and what concerns, if any, you have about the gap between that scheme ending and any new scheme coming into place?

I can go first on this. We have and have had some concerns there. We understand and we're aware that, obviously, as you say, Arbed closed in November, and prior to that, I think it experienced some significant delays and underdelivery issues, meaning that, I think, significantly fewer households were supported than perhaps intended. We do, however, champion the merits of an area-based programme, and perhaps that's something that we can come to. But in terms of the gap, off the top of my head, which is dangerous, I think the planned capital investment in the Warm Homes programme going forward in Welsh Government's draft budget was about £100 million up to 2024-25. I think that was set at something like £30 million in the first year, £35 million and then £35 million again. It's £27 million this current year, or the year to come, so that's grown by £3 million, and then indicatively I think something like £8 million the year after. Perhaps that would appear to suggest that we haven't lost Arbed's contribution in terms of funding into the Warm Homes programme going forward, given that it's now closed, but, as I say, instead it's grown slightly. If that's true, that's welcome. But, clearly, that's not a doubling of investment, as per the recommendation and acknowledgment that the previous Minister made, as well as the future generations commissioner.

Anything from you, Jack?

Just to say that, clearly, having a gap in provision and not having an area-based scheme for this period of time is not ideal, especially with prices rising as high as they have and are expected to. What I would really make clear is that Nest is still operating and will continue to operate until the new scheme comes on line. And so any household that is struggling to pay their bills can access support through Nest and they absolutely should do if they are struggling.

I agree with everything that Ben said there. I just hope that we spend this next period of time, just over a year between now and the beginning of the next programme, thinking about how an area-based scheme can best work alongside a demand-led approach and be part of the next Warm Homes programme. We've got lots of things that we could be doing to the scheme to make it deliver for even more people. I definitely think that we're not alone in thinking that an area-based approach is worth while continuing.

Okay, thanks. And thinking about that replacement scheme or that next scheme, you've talked a little bit about the area-based approach, but if you want to elaborate at all on the advantages of having an area-based approach—. But what I really wanted to understand was whether the cost of enabling works should be factored into the next maintenance programme, so things like rewiring, redecorating, maintenance. And, secondly, ultimately what we're looking to do with these sorts of things is to go into people's homes and fiddle around with them, so what partners should we be engaging in order to get households to engage to do that, because it might be a bit of an undertaking? So, whoever wants to answer those.

I'll give that a stab, Tom, if that's okay, and then if I forget—because I'm keen to try to answer each of those questions, I think. In terms of the area-based approach, we put in our evidence, as you'll see—and we can perhaps refer to the merits of continuing with an area-based approach alongside a demand-led scheme—things like economies of scale, so having local installers being able to work street by street, rather than just pepper-potting different properties and areas, meaning the money can go further. The neighbourhood impacts of actually visibly seeing your next-door neighbour or somebody across the street from you taking up an upgrade and then you being encouraged to be able to do the same, as well as, obviously, putting more money back into people's pockets locally and that having more local economic benefits—.

In addition to that, I think something that's been coming out of conversations of late also is that it may well also help encourage local authorities to be able to leverage in their own funding to make improvements to social housing alongside a national demand-led scheme. So, I think, perhaps in answer to your question about the variety of partners that we should be looking to work with, it's imperative—and I think that this builds on something that Jack was saying earlier—that all of those individuals and organisations work very closely together, so local authorities, registered social landlords, who will also, of course, have been working on their own Welsh housing quality standard and potentially optimised retrofit programmes too, alongside the third sector and others.

And then I think your other part of the question related to rewiring and enabling works, which is something that we and others have flagged also. So, yes, in answer to that, we do think they should be routinely funded; I think that's a view that's shared by others too and was part of their submissions to the previous inquiry in 2019. Like you said, as an example, that could mean rewiring, because if the changes to a home mean that you sometimes have to do that for safety reasons, otherwise that's going to be prohibitive, you're essentially saying, 'You could have this, but you can't because you can't afford to rewire your home, and you can't do it if we can't rewire your home, so you can't have it', so you're just left, then, between a rock and a hard place. That also could well include servicing and maintenance, redecorating and paint work, or even just help to be able to clear your loft or your room or something that would otherwise be prohibitive.

And I understand that you've already received some kind of anecdotal evidence about issues around communication and proactive follow-up, where people have not known the installation date until they've done some of that work even if they have been able to do it, and then have sat there with their two-bed property, for example, with one of those bedrooms piled up in the other bedroom and then found that the installation is not going to be until six months' time or something and then left not knowing whether they need to then move that all back in again and move it out again, or not. So, I think, obviously, that's worth reflecting on, but absolutely, yes, we think that those things should be routinely funded too.

And then, for myself, I echo everything Ben said there about area-based schemes, the economies of scale and being able to have greater buy-in from local communities. Something that we have wondered whether it could be a useful addition to a future scheme would be having some kind of tapered grant or low-interest or low-cost financing for households that are in a target area that might not otherwise be eligible for a scheme, so that you could do a full terrace of houses. It wouldn't be the odd one left out because they wouldn't be eligible for the scheme, typically. So, that's something that we think will be worth considering.

On enabling works, we also, in our evidence to the Climate Change, Environment and Rural Affairs Committee, called for enabling works to be funded. I think that's so important, that that's not the barrier to people accessing support. It would be an awful state of affairs if someone who needs to have enabling works done to their property, enabling works that actually would improve their energy efficiency and the comfort of their home, in many cases, are not able to have that work done and so can't participate in the Warm Homes programme. So, that's really important. We hope that that will form part of the new scheme, and that is the signalling that we've been getting.

And then who to work with—I won't go over the people who Ben mentioned, but I think there could be something worth while in looking at local area energy planning. So, this work is ongoing at the moment, and identifying areas that could benefit from an area-based approach, as part of these local area energy plans, could be really beneficial. And so that work involves not just local authorities but utilities and distribution network operators and things as well. I think making it all stitched more coherently together would be really beneficial.

And one last one from me on this: when drawing up that successor scheme, do you think immediate need should be the thing that trumps everything else? And if so, how do you identify the definition of immediate need—what does immediate need mean? And you've both talked up the advantages, I guess, of an area-based approach. Would an immediate-need approach clash with that, or how do you deliver that in a way that it doesn't?

If I take that one, Ben. So, on the immediate need point, I think that there's a distinction to be made in terms of addressing the immediate energy efficiency improvement need and addressing immediate need more in general. So, Nest in particular—that's what I can talk most to—as you know, isn't really designed to offer immediate energy efficiency improvements; it's a centralised scheme. It does support people with energy efficiency improvements, but it isn't able to do that at the moment that someone calls. But what it is able to do is to tackle one of the other three pillars of fuel poverty, which is income. So, while Nest does involve installing measures, offering free measures, it also is really crucially about those benefit-entitlement checks, income maximisation, debt advice, signalling tariff switching to people. It's all of that stuff that tackles people's income and maximises their income immediately, while energy efficiency measures and a plan for installing energy efficiency measures are put into place. So, I think that that is a model that does work. I mean, I absolutely take the point that was made in a previous session, that there is great benefit in giving people low-cost but high-impact measures like draught-proofing, like heavy curtains. But for that to work for every household that contacts Nest, we need to really strengthen that partnership working so that local practitioners can support those households. Because as it currently exists, Nest is not geared up to deliver those kinds of measures immediately.

And then, in terms of whether an area-based scheme clashes with addressing the immediate need, I suppose, as I've just been saying, there's the income maximisation, which can address the immediate need. I think that it would be hard to conceive of an area-based scheme that could address immediate need through installing energy efficiency measures, because you do have to have that buy-in from the community, and the very last thing we'd want is for people to feel that they're having measures forced on them and their community. You have to get the buy-in.

Ben, you wanted to come in.

Yes. I think, just to build on that, from our point of view at NEA, the future programme should be accessible to all those who are in need of its support. I think we built on that earlier—you should ensure that measures require no financial contributions from fuel-poor households, routinely fund the cost of enabling works, and it should be promoted and delivered alongside independent holistic advice and support. And some of that touches on the immediate need, and I'm pleased to hear, as Jack just said, and we'd support, obviously, the importance of the advice provision that sits alongside that. So, that can be anything from, as Jack said, income maximisation through to how to use your heating system and controls. Obviously, the way that we heat and power our homes going forward may look quite different, the way that we even buy energy or use energy may be quite different, so that's going to become increasingly important. I think, as Jack said earlier too, that might well mean that we need to have that hand-holding and support available before the intervention to long after that intervention work has been carried out, and so too debt advice as well—fuel debt advice in particular.

Because of the current crisis, I'm afraid that we have a debt mountain looming and that an awful lot of households will be in either deeper arrears or in arrears with their supply. If energy prices continue to rise, then you are essentially faced with a stark choice of either falling into debt and heating your home, or not heating your home and going without, neither of which are nice choices, to say the least. There are specific protections and support that are available within industry that you wouldn't necessarily always be aware of as a generalist debt adviser, for example, so licence conditions that suppliers have to follow to take into account a household's circumstances and their ability to pay, and so those things are very important when negotiation negotiating for the repayment arrangements and the like. So, that's very important too. There's also the immediate need of emergency relief, currently, and we're really pleased to see the likes of the winter fuel support scheme developments that have also just come to pass and there's the discretionary assistance fund that now also helps to top up oil and LPG for off-gas rural households and for Gypsy and Travellers as well. So, it's very important that the scheme and anybody working on it are aware of all of those things, and take the opportunity to maximise that. But I would also just conclude by saying that improving the energy efficiency and fabric of people's homes is an immediate need. We have to start doing this.

Thank you very much indeed, Tom. Can I pass on to Sioned Williams now?

Thank you, Chair. I was looking at the evidence, which mentioned that the majority of those who live in fuel poverty are renting privately, so how can we encourage private sector landlords to tackle fuel poverty without leading to the risk of higher rents? Ben, do you want to go first?

Sure. That's a very important question. The minimum standard of energy efficiency currently for a private rented sector property in England and Wales is an EPC band E. The UK Government has consulted on raising that minimum to an EPC band C, I think, by 2028. It would be earlier for new tenancies, it was proposed, and then all existing tenancies, as well as new tenancies, by 2028, with landlords having to spend a minimum of a yet to be determined-type amount to reach that standard. Though that is something they've consulted on; it's not something they've actually responded yet to. But such a change in standards would be a very positive step in ensuring that the private rented sector and landlords are adequately tackling fuel poverty, but I think, as always, with things like this and regulation, regulation is only ever part of the picture, and it's only ever as good, in some ways, as the enforcement that then sits alongside that, and that sits with local authorities, and so it's very, very important that local authorities, obviously, have the capacity to be able to then do so.

It's proportionate, we feel, that landlords have an incentive in this space, as well, to upgrade their properties. Correct me if I'm wrong, but I believe that the current Nest programme would also, obviously, enable those in privately rented accommodation to be able to have those upgrades at no cost, and that is quite an incentive and would continue to be quite an incentive if that were the case going forward, whereas the stick to this, if you like, is also the housing health and safety rating system that's also enforced by local authorities if they're able to do so. If they identify that a property has what I think is known as excess cold, if it doesn't have thermal insulation and the heating system to be able to become economically heated at reasonable temperatures, then if that category 1 excess cold hazard is identified, they are then duty-bound to enforce it and put that right, and the landlord would be liable for the full cost of those works—no exemptions, no cost caps, they'd be liable for the full cost of those works.

So, it's important, I think, that all of this is joined up so you've got a carrot and stick, if you like, in order to be able to make the most of this, and that, of course, then landlords are aware, under the licensing schemes, of what other wider assistance is available and other organisations that can support those tenants and so on and so forth.

Thank you. Jack, do you want to come in?

Yes, of course. So, as Ben was saying, the stick is these minimum energy efficiency standards. We don't know at the moment how stringent those will be, what the ratcheting up will be and what the cost caps are going to be to meet those. So, these are all really significant unanswered questions at the moment because that will determine how much of an incentive or a stick it is for landlords.

Just picking up on Ben's point around the enforcement of standards, I think that's going to be where that policy of minimum energy efficiency standards either succeeds or fails. We have minimum standards for other aspects of renting, and those are not enforced very well anywhere. In our written evidence to this committee, we understand that the UK BEIS department have funded three local authorities to enforce minimum energy efficiency standards with a dedicated team, which is really positive, but obviously that's only positive for those local authorities; elsewhere, the standards are likely to be not being enforced to the same extent or not being enforced equally. So, there's an enforcement point.

In terms of the incentive for landlords, obviously there will be the cost caps. Something that operates in Scotland, which, as I say, we helped to deliver but has been really effective, is the Scottish interest-free loans for the private rented sector. So, this is an interest-free loan of up to £38,500, and that's split between energy efficiency measures, renewable generation and storage, and this is available for landlords who are registered and have passed various checks, and it's interest free as long as the landlord has fewer than six properties, but six or more and it's charged at 3.5 per cent interest, and it also is not available for second homes or holiday homes, and tenants have to be in properties or soon to be in properties to access it. So, currently that kind of scheme is not being considered, as far as I'm aware, by Welsh Government, but that has proven effective in Scotland.

And then, just something that came up at the end of last year that we thought was very interesting, and we haven't heard a great deal about it, and, again, we mention this in our written evidence, was the climate change Minister's announcement in the Siambr around the private sector leasing scheme, where the minimum energy efficiency standard uplift, energy efficiency and climate change were all mentioned in reference to this scheme, as being a supportive argument in favour of that scheme. The policy documents that accompanied that announcement didn't mention those considerations. So, it's an interesting programme; it will be interesting to see to what extent that is taken forward, because you can imagine that that could form something of a backstop for landlords that were unable or unwilling to improve their homes up to a minimum energy efficiency standard.

Thank you very much. Thank you, Chair.

Thank you very much. Okay, I just want to finish up with a few slightly technical questions, but really important in how we shape the future programme. Before I ask you how we are going to identify these worst-first homes, I wonder if I can just ask you about the extent to which the EPCs and/or the environmental levies on electricity have influenced both Nest and Arbed's focus on these gas boiler replacements, given some of the work that's been done on behalf of BEIS to have a completely different approach to EPC certificates. Are you able to give us your views on that, please?

Yes. Shall I take that one first, Ben?

Yes. I'm happy for you to go first.

So, there are well understood and often talked about issues with EPCs and I know that, as part of the new Welsh housing quality standards, some of those are being considered at the moment because EPC A as a target is a challenge; it's very, very hard and potentially impossible to get to an EPC A just using energy efficiency measures—you have to have some kind of renewable generation. Now, that's obviously not possible for all houses because they live under a tree or their house doesn't face south, or whatever. So, there are challenges there, in terms of whether the ambition is for energy efficiency or whether it's a more holistic measure that's looking at renewable generation as well. So, some of this will be addressed when SAP calculations, which underpin EPCs, are updated, and the likelihood is that they will transition away from considering renewable generation and put more of an emphasis on low-carbon heating. But this is in the future. This isn't an imminent change. So, there are certainly challenges in using EPCs alone there.

I think you mentioned the levies placed on electricity. So, that is a real challenge that is really holding back the installation of low-carbon electric heating in general. So, the levies on electricity account for around 20 per cent of the electricity bill that we all pay. If these were moved off of electricity—and our view is that they should be moved on to general taxation, because this is more progressive than moving them on to gas—you would immediately see the cost of heat pumps and electricity for heating come right down, which would make them cost competitive with gas in almost all circumstances.

Even without levies, with gas prices as high as they are and expected to stay high, possibly for the medium term, it's already the case that, in many instances, in real heat-pump use and real gas use heat pumps are cheaper than many gas boilers. So, the Regulatory Assistance Project has just published some data on this, looking at the impact of the April price rise and not even considering the October price increase that we might see. So, it would be very beneficial to move levies off of electricity. It's something that the UK Government are committed to. But even without that happening, we're already seeing heat pumps being much more competitive in terms of running costs compared to gas boilers.

Okay, that's good news, but how did we get the EPC rating so wrong? Was it because we were all obsessed by cleaning up the electricity generation scheme of coal-fired powers stations? How come we didn't already know that gas was also loading the world with carbon?

I think the issue is that the EPC is a reflection of cost. It's designed to give an indication of costs, and so, with the energy system, the energy architecture that we had, and particularly when EPCs were first formulated, it didn't make a great deal of sense, in most instances, to install a heat pump without other energy efficiency measures. And so the EPC reflects that, whereas the overall cost for a household, obviously, comes down if you're selling electricity back to the grid by having solar panels installed.

Okay. All right. Ben, do you want to come in on this point?

Yes, sure, thank you, Jenny. I think, just to say, I'm not a technical expert in this space, by any means, but I think it is important just to come back to something Jack said there and the purpose of the energy performance certificate in the first instance because, as Jack said there, they're designed to include and provide an indication of how much it will cost to heat and provide hot water and lighting to your property. And that can be very useful—that estimated cost to households rather than the amount that you would use in kilowatt hours, which would be far less understandable and, ultimately, it's a comparison tool. So, in order to compare, you have to make some standardised assumptions, and it does so around occupancy and a heating pattern as an example.

So, it doesn't actually include the amount you use, but if it did, there would be some significant pitfalls, particularly for fuel-poor households, because—and I think this is the same reason why we at National Energy Action also had some strong concerns with Welsh Government's draft proposals as to how it may measure the future success of the programme going forward, about a reduction in kilowatt hours rather than an improvement in the energy efficiency of that property—firstly, fuel-poor households often ration their energy use, as we've said earlier, and go without heating to the detriment of their health and well-being. So, if your ambition is to reduce their consumption further, the perverse outcome there is that you could be encouraging households to reduce their consumption even further still, and that would have even more devastating consequences for their health and well-being. But secondly, even if that were not true, you could also still see some very positive outcomes being deemed a failure because, when you improve the energy efficiency of fuel-poor households' homes you don't always necessarily—you will sometimes, for sure, but you don't always necessarily—see a reduction in their consumption. I may have been spending x amount today underheating my home, but you have now made it, thankfully, much warmer and efficient for me, and I may still go on to spend x amount again today, but I now am able to adequately heat it. If that were then deemed a failure because you haven't achieved a reduction in consumption, that seems also to be quite unintended, so that's very important.

So I think, Jenny, you're very right to highlight those environmental levies, as Jack mentioned, and we too would support those moving into taxation—the legacy environmental levies—because that's perhaps where some of this can be fixed. Our view is that those legacy environmental levies should be moved into general taxation, as I say. I think, for clarity, we're talking here about the renewables obligation and the feed-in tariff. They're two environmental levies that are now the legacy ones, they're no longer live. There are a couple of other levies on bills, which are the Warm Home discount and the energy company obligation, but they are social levies and sometimes they all get mixed in to the same umbrella. So, if we're talking here about those environmental legacy levies—that's hard for me to say—in terms of the renewables obligation and the feed-in tariff, then we absolutely would support those moving to general taxation, and certainly not onto gas, which would just be adding even further costs to gas, which is already very high, and would obviously be to the detriment of fuel-poor households that may have to remain on it for some time.

Okay, but ultimately we're trying to eliminate fuel poverty and meet our net-zero targets, so how are we going to identify these worst-first homes that we need to prioritise, obviously? And how are we going to have a system in the new Warm Homes programme that will enable us not to produce these perverse incentives to get everybody having new gas boilers? Those who benefited, that is. But clearly there's something wrong with a programme where 96 per cent, in the last year for which statistics are available, were gas boilers. Who wants to go first on this?

I'm happy to start, if that's okay, Jack. Yes, I think from our perspective here, the key word here, I guess, is 'aligned', isn't it? We believe we should have a fuel poverty focused programme that's there to support those on the lowest incomes living in the least efficient homes, that's spent on a fabric-first basis. So, you upgrade the energy efficiency of those homes before, or at least at the same time as, replacing their heating systems, when it's viable to do so with low-carbon heating technology. But you're not risking potentially increasing their costs even further if you haven't improved the fabric of those homes. That's then delivered with all of the awareness raising and advice that we spoke about earlier, and is underpinned by good-quality installations and redress and so forth.

But a fuel poverty focused programme that's focused on lifting households out of fuel poverty with that worst-first approach, supporting those on the lowest incomes living in the least efficient homes to make their homes much warmer for less, would help us progress towards our decarbonisation targets, and there is no pathway to net zero that doesn't involve going through the homes of fuel-poor households. And so in it lies a critical opportunity to improve the lives of those households as we decarbonise and upgrade the energy efficiency of our existing housing stock. I think we said in our submission that warm and safe homes are both at the heart of tackling fuel poverty and of a fair, affordable, just transition to net zero, and if we don't do the upgrades, and we don't do clean heat, we'll fail at both.

So, what we wouldn't, though, support is potentially having a decarbonisation programme on the one side, as I believe it may have been proposed elsewhere, focused on decarbonising all homes, housing for everybody, potentially including fuel-poor households, and then kind of have a separate programme that tries to provide some additional advice and support to fuel-poor households over here that is quite disconnected. Because even if that first programme, the programme that is decarbonisation focused, included fuel-poor households and required them to make no financial contributions, even if it then went on to help others, even if they made the more able to pay contributions themselves, it doesn't prioritise those who need it the most, who need this now. It doesn't prioritise fuel-poor households living in the least efficient homes where these are destroying their lives and their experience of home. So, any support for others can't come at the expense of fuel-poor households, so that's why those two things need to be aligned, as we say, and that's why we reflected on that in our evidence with those principles, as we suggested.

Okay. I'll come back to you in a moment, but I'll leave you with the question I'm going to come back to, which is: are you in favour of, therefore, two programmes, or can we have both objectives in the same one, single programme? Jack.

So, before I get into the decarbonisation versus fuel poverty question, which is really important, I think there's just a point to be made about the principle view, which we support, that we shouldn't be installing any more fossil fuel gas boilers, which then, quite quickly, runs up against the practical reality of having a programme that is, rightfully, trying to support fuel-poor and vulnerable households, often at times of crisis. So, often when people engage with the Warm Homes programme, it's at a period of acute crisis; their boiler has broken down, they can't afford to repair or replace it, they just want to have their home be warm again. At that point, it is probably not in that household's best interest to then think about a whole-house retrofit plan for their property, install multiple measures, install low-carbon heat. This all take time. We've already mentioned that there are significant shortages in skills and tradespeople.

So, while we absolutely support the principle that we shouldn't be installing any more gas boilers, the reality is that, for lots of households that are engaging with the Warm Homes programme now, and likely in the future, what's in their best interest would be probably repairing their boiler, if that's possible, or replacing it in circumstances when it can't be repaired, and then that triggering a process whereby they engage with an adviser who walks them through what the pathway to creating a net-zero house looks like for them. And this comes back to increasing the caps and allowing people to dip into the fund more than once. They then have a pathway whereby they have heat in their home to deal with the initial crisis, but they also know that they can reduce their fuel costs in the medium term by installing energy efficiency, and they know that they can install low-carbon heat afterwards.

So, that's where the challenge is in terms of people's engagement at periods of crisis. As to whether decarbonisation and fuel poverty are actually in opposition, we don't think that they are at all. We think that, as Ben has mentioned, there's no pathway to net zero that doesn't involve improving the homes of people who are in fuel poverty. The two ambitions are aligned and, actually, the fact that we need to improve the energy efficiency and insulation of all properties, regardless of their heating system, means that, actually, they're very closely aligned. This means, though, that we have to have high standards for the measures that we install, we have to make sure that when we do install low-carbon heating that those systems are sized correctly, installed correctly, that people know how to use them.

And then something that Ben mentioned as well—and it comes back to the question I think you wanted to ask about whether there should be one or two programmes—from our perspective, there needs to be one point of entry. There should be, ideally, a one-stop-shop style approach where people engage with a service, and whether they are supported through the fuel-poverty wing or through a decarbonisation wing, it happens behind the scenes and they're not having to decide where their household fits, that it needs to be made as smooth as possible for households to engage with the service. So, no, we're not supportive of having two separate policies—[Inaudible.]

Okay. I'll come back to you in a minute on something, but, Ben, one programme or two?

I think it's difficult to know what we're comparing here. So, in our view, we need a fuel-poverty-focused programme, and, if you have one point of entry and then there's a programme that prioritises those who need this help now, and they can either stick their hand up or they get joined up through a demand-led programme, or they get joined up as part of an area-based one, then they can then access that much needed and vital support to upgrade the energy efficiency of their home on a fabric-first basis at no cost to themselves and so on and so forth, with all the advice and assistance that we spoke about earlier, then that sounds to me like a fuel-poverty-focused programme that would also be meeting our climate change need and urgency and targets, but the key thing here is the prioritisation. The risk is, if you end up with one programme that's entirely focused on decarbonisation that just provides some support to fuel-poor households, that, when you go through the point of entry you don't then have to pay towards it because you meet the eligibility criteria, you are not prioritised, and you will not necessarily get that support now or in the coming years and you could well be left behind, but we need to get these households out in front.

So, the key thing here is that, if the Warm Homes programme is to have another iteration, it is a fuel poverty-focused programme that is aligned with our decarbonisation ambitions, and that's why we talk about fabric first, because, obviously, if, then, it's not viable yet to install a low-carbon heating option in their property, then, as Jack said, you may well have to repair their boiler, which is something that's not even possible under the Nest scheme currently, I don't believe—it's just being replaced.

In some instances, yes, you may have to replace that or make sure you don't leave them without any heating, and, for others, it may well be able to accommodate those heating systems now as well, alongside those upgrades, and done at the same time. But the key thing here is the prioritisation, ensuring that there's dedicated, tailored and targeted support available to those who need it most.

Neither of you has mentioned, instead of repairing or replacing somebody's boiler in the first instance where, you know, it has broken down and, clearly, people need a heating system—. Why not go straight to the quite efficient electric heaters, electric radiators, that are now quite widely available, which, obviously, don't need a lot of installation? You shove them on the wall and plug them in. Clearly, it means you've got to take out the gas radiators and change the cooker, if they've got gas cookers, but why isn't that considered an option, rather than continuing to install the gas systems that we know we're going to need to eliminate?

I suppose for some households that could be an option. I'm certainly not an expert in the efficiencies of direct electric heating, but, I think, given that the costs are different between gas and electricity, there is a risk that you could end up having a household paying more to heat their home using those kinds of electric heaters, but Ben may know more on this than me.

Okay. Okay, so, moving to the really important question, which is how do we develop the skilled workforce that we need for this really massive task (a) on insulating the fabric of people's homes and (b) on understanding and correctly installing the heat pumps of the future, as well as the solar panels—instead of roof tiles, solar panels in the appropriate south-facing households et cetera, how do you think we're going to do that? Is the optimised retrofit programme that is being undertaken in social housing going to deliver for us there, or do we need something in addition to that?

I think that the optimised retrofit programme will tell us some really useful things about the optimised retrofit pathways that certain households will need to take, and it's really beneficial that it's engaging with small and medium-sized enterprises and is looking to improve skills. We haven't seen a great deal of information about how that's progressing and what the impacts have been so far, and it'll be really interesting to see that.

I think that, given the scale of the challenge, we need to be doing more. It would be brilliant to see retrofit courses being offered in all of the colleges around Wales, with people understanding that this is a well-paid, secure job that is helping to decarbonise and make homes across Wales better. I think that there's a real just lack of knowledge, let alone understanding, about what is needed and the jobs that are needed, and that this is a great opportunity.

Likewise, I think that we need to be thinking about how we reskill the existing workforce. We have a lot of gas boiler engineers in Wales who will end up, in all likelihood, not installing gas boilers by the end of their careers, and so we should be being honest and proactive, and thinking about what does reskilling and retraining look like.

Ben.

One thing that we could, perhaps, add to that, and it comes back to a question that I think Ken asked, about the conversation that we had around interim targets, is that it's also about the confidence that those supply chains and industry need. So, as we said, that is another benefit of having those interim targets, but it's also the benefit, we feel, of, actually, the Warm Homes programme going forward also being a statutory scheme as it is now, rather than one that may be entirely discretionary, like the optimised retrofit programme or the discretionary assistance fund that Welsh Government currently offer.

The final question in Welsh Government's current consultation into the Warmer Homes programme asks whether you think the programme should be set out in regulations, or if it can simply be supported by scheme guidance. And I think, currently, the Home Energy Efficiency Schemes (Wales) Regulations 2011 set in place the arrangements for the current programme. And that will need to be amended for the future one, and I guess Welsh Government are perhaps wondering as to whether those regulations could be repealed in their entirety, with the next iteration, as we say, being delivered as an entirely discretionary Welsh Government-funded one.

But we strongly believe that it should be a statutory scheme that's set out in legislation. And, yes, that could be less prescriptive, so you could include—. More of the technical details, perhaps, relating to some of the measures that are available, could be stated in guidance issued by the Minister, which would allow for that greater flexibility, Chair, to include new technologies and low-carbon heat options as they become more viable. But Welsh Government should put that programme into legislation, because that would give the confidence to households that this will be available year-in and year-out over the next five to 10 years, or whatever the duration of that programme might be. It would give confidence to all of those national, regional and local organisations and partners like ourselves, the Energy Savings Trust, Citizens Advice, Warm Wales and others, who are all working on this programme to provide advice and support and signpost and help people through that, and to industry and the Welsh supply chain. So, I think perhaps that's something that's worth reflecting on in the context of that question too.

Okay. Thank you very much indeed. Jack, is there anything you wanted to add, or is—? I think we've pretty much covered this point. Is that right as far as you're concerned?

Nothing further to add. Just to clarify an earlier point I made, we agree that the priority should be on supporting fuel-poor households, and that, if there were a scheme that was also focused on decarbonisation, funding should be ring-fenced for supporting low-income vulnerable or fuel-poor households. I just wanted to make that point clear.

Very good. Thank you very much, both of you, for your contributions. Jack, we'll write to you with some of the additional information that it would be really useful for us to have, and we will also be seeking to get some evidence from British Gas. We will send you a transcript of both your contributions, so please look at what you have said to make sure that we have captured it accurately, and let us know if there's anything that needs to be changed. Thank you very much for your time this afternoon. Thank you.

Thank you, Chair, for your inquiry.

Thank you.

We have 10 items of papers of note. Is there anything anybody wants to raise in public session before we move into private session? I take that as a no. Nothing further to add on those papers.

We will now move into private session and have the rest of the meeting in private.