What we told the Department: our Warm Healthy Homes Fund consultation response

1. Do you agree with the proposed approach when assessing eligibility?

First, we strongly welcome linking the income threshold to the National Living Wage and uprating it annually. A static threshold quietly narrows eligibility every year through inflation without any policy decision being taken, as happened with the £23,000 line in place since 2021. Automatic uprating fixes this permanently.

Second, we strongly support excluding disability and health related benefits, and the winter fuel payment, from the income calculation. In our experience this kind of disregard is the least understood feature of the current scheme: many eligible households assume these payments count as income and never apply. We would urge the Department to state the disregard prominently in all public-facing material, not only in guidance notes, and to express the whole test in one or two plain sentences. A homeowner who cannot easily tell whether they qualify is a homeowner who can be told anything on their doorstep, and scheme transitions reliably attract doorstep misrepresentation.

Third, on the Universal Credit passporting requirement of three consecutive assessment periods: we understand the intent, but UC entitlement fluctuates month to month with earnings, and seasonal and self-employed workers, common in Northern Ireland, may repeatedly fall just outside three consecutive periods while being in persistent fuel poverty. We suggest either a look-back approach (for example, receipt in any three of the last six assessment periods) or clear signposting that such households can still qualify through the income-threshold route.

Fourth, Pension Credit is a sound passport but is well documented as under-claimed. The income-threshold route will catch many eligible pensioners who have never claimed Pension Credit, and application support should be designed on the assumption that older applicants will arrive through that route without existing benefit paperwork.

2. Do you agree with the proposed approach to household savings?

First, £6,000 mirrors the lower capital limit used in working-age benefits, but for applicants aged 60 and over the more relevant established approach is Pension Credit, which disregards the first £10,000 of savings. Older households' savings are typically emergency funds earmarked for funerals, care or home repairs, held by people with no ability to rebuild them. If the Department already proposes more generous tariff treatment for over-60s above the floor, consistency argues for the more generous £10,000 floor for that group too.

Second, whatever floor is chosen should be index-linked, in the same way the Department proposes to uprate the income threshold with the National Living Wage. Capital limits in the working-age benefits system have been frozen since 2006; the Resolution Foundation calculated in 2025 that adjusted for inflation the £6,000 lower limit would now stand at over £10,000. Importing a frozen figure imports nearly two decades of erosion on day one.

Third, a practical point from the delivery side: whole-house retrofit works disrupt homes, and households commonly need modest funds of their own for redecoration, floor coverings and enabling works that grant schemes do not cover. A savings rule that penalises exactly the buffer a household needs to accommodate the works risks deterring applications from suitable homes, or leaving funded measures incomplete. The savings test should be designed so that holding a sensible works-and-emergencies buffer never disqualifies an otherwise eligible household.

Finally, as with the income test, the savings rule should be stated in plain language in all public-facing material. Complexity depresses uptake among precisely the older applicants this fund most needs to reach.

3. Should applications be prioritised by the energy rating of the property?

Yes to prioritising by energy rating: a fabric-first fund should reach the worst housing first, and homes rated E or below are the right priority group. We also welcome the confirmation that a home assessment will establish the rating, since many of the worst NI homes, older owner-occupied properties that have not been sold or let for decades, have no current EPC at all and must not be disadvantaged for that reason.

Our substantive concern is the proposal to carry out home assessments on a first-come, first-served basis. First-come, first-served rewards the most informed, most digitally connected applicants, and severe fuel poverty correlates with the opposite: older, offline, rural households who hear about schemes late and apply late, if at all. With a limited budget, worst-first prioritisation in principle risks becoming fastest-first allocation in practice, and the E-rated pensioner who applies in month nine may find the budget consumed by better-informed applicants from month one.

We suggest three mitigations. First, triage the assessment queue rather than processing it purely by date, using information already collected at application (property age, heating fuel, benefit passporting) as a proxy for likely severity. Second, fund proactive outreach through the community organisations that older households already trust, so that the priority group actually enters the queue early; we would gladly assist any such effort at no cost. Third, monitor and publish the profile of assessed and funded homes by council area and EPC band as the fund runs, so any drift toward the well-informed rather than the worst-housed is visible and correctable in-year.

Finally, assessment capacity is itself a delivery risk: a large eligible population all requiring home assessments will need a substantial assessor workforce from day one, and we would encourage the Department to publish its expected assessment pipeline so that NI firms can resource for it.

4. Private rented sector: fully funded low-cost measures, and should windows, solar PV and battery storage be added?

In principle a landlord contribution is easy to argue for, since the works improve a privately owned asset. But for this specific, deliberately low-cost measure set (cavity and loft insulation, draught proofing, ventilation), the practical arithmetic favours full funding: any contribution requirement becomes a landlord veto, and it is the tenant, the person the fund exists for, who pays for that veto in cold and damp. Full funding of the cheapest, highest-impact measures is a defensible price for removing the refusal barrier.

The conditions should be explicit: a binding commitment that neither a rent increase nor an eviction will be attributable to the improvement for a defined period, with repayment due if breached; a commitment to continue letting the property for a defined period, or repay on early sale; the ability for tenants to initiate an application themselves, with a clear landlord consent process; and records of funded PRS properties, so a landlord cannot serially draw public funding across a portfolio while keeping properties otherwise below standard.

On additional measures: these are high-value capital improvements that permanently increase the worth of a privately owned asset, and in the case of windows they overlap with the repair and maintenance obligations a landlord already carries. Full public funding here is a transfer to the asset owner rather than to the tenant. The benefits of PV and battery storage do not automatically reach the tenant: export payments and bill savings follow the electricity account and the equipment ownership, which can leave the tenant no warmer and no better off while the landlord collects the return on a publicly funded asset. Unless a scheme can guarantee the benefit flows to the occupant, it should not fund the equipment.

The budget is finite and the Department's own logic is fabric-first. Every fully funded PV and battery installation for one landlord is several cavity and loft jobs not done for households in EPC E properties. While money is constrained, it should buy warmth in the worst housing, not generation assets on rented roofs. If the Department wishes to include these measures for the private rented sector at all, they should require a substantial landlord contribution, be available only after the property's fabric measures are complete, and carry an enforceable guarantee that the energy benefit accrues to the tenant.

5. Do you agree with the proposed grant limits (£35,000, rising to £45,000, with £500 for remedial works)?

We answer No solely because of the £500 allowance for maintenance and remedial works; we support the proposed grant limits themselves and want that support recorded clearly.

The £35,000 limit, rising to £45,000 for non-traditional and solid wall construction and environmentally constrained properties, is realistic for a genuine fabric-first, whole-house retrofit including an air source heat pump, PV and storage, and the uplift correctly reflects that solid wall insulation is the most expensive common measure. This is a major and welcome improvement on the current scheme's limits.

The £500 remedial allowance, however, is not credible against real Northern Ireland costs, and it threatens the fund's own prioritisation logic. The homes this fund rightly prioritises, EPC E and below, are precisely the homes most likely to need remedial work before measures can be installed: roof repairs before loft insulation, damp remediation before wall insulation, and electrical upgrades before a heat pump. From our published NI 2026 benchmarks, compiled from written quotes from working NI tradespeople: making good after electrical work alone typically runs £600 to £1,800; minor roof repairs £150 to £400 for slipped slates and £400 to £1,200 for ridge repointing; a consumer unit upgrade, commonly needed before a heat pump in an older home, £400 to £700. A single one of these routinely exhausts £500.

The predictable consequence is that the worst homes fail at assessment stage because their remedial needs exceed the allowance, reproducing the too-poor-to-be-helped trap that has undermined previous schemes: the households in greatest need excluded precisely because their homes are in the worst condition. We recommend the remedial allowance be set at a realistic evidence-based level, in the region of £3,000, or structured as a separately assessed enabling-works element within the overall grant limit, and that it be reviewed annually against actual NI installed costs. We publish our benchmark data openly and would gladly share it with the Department for this purpose.

6. Do you agree that an applicant may apply only once?

We understand the administrative intent, but "one application per applicant" conflates two different things: limiting repeat awards (reasonable) and limiting attempts to access the fund (harmful). Two scenarios show the problem, plus one drafting point.

First, the unsuccessful applicant whose circumstances change. A household refused in 2027 because their income sat marginally above the threshold may fall below it in 2029 through retirement, bereavement or illness. If their single application is spent, the fund's own eligibility rules become unreachable for exactly the households falling into fuel poverty during the fund's lifetime.

Second, the partially served household. Budget constraints, measure availability or phased delivery may mean an assessment funds some measures and not others. A household that accepted loft insulation in year one should not be permanently barred from the heat pump their assessment identified but the year’s budget could not cover.

On drafting: the proposal states the limit per applicant, while the fund's logic, and we assume the Department's intent, attaches to the property. We would ask that the final rule say so explicitly, since the difference matters at the margins (an applicant who moves home; a property that changes hands).

7. Do you agree with the proposed quality standards (registered contractors assigned to householders)?

Our reservation is confined to one word: "assigned". The proposal says contractors "should be assigned to householders" and also that "a list of registered contractors would be provided to households". These are different models. Assignment gives the householder whoever they are given; a list gives them a choice among accredited firms. We urge the Department to adopt the list-with-choice model explicitly: choice preserves trust, keeps service quality competitive within the accredited pool, and avoids the take-it-or-leave-it dynamic that damaged confidence in earlier schemes.

Three further recommendations. First, publish the registration criteria early and keep the accreditation route proportionate for small firms and sole traders, who make up most of the Northern Ireland trade base; otherwise the registered pool becomes a handful of large contractors, with longer waits and thin rural coverage. Second, make the register public and verifiable, showing each contractor’s accreditations and council coverage, in the same way householders can verify Gas Safe, OFTEC, NICEIC and NAPIT registration today; verifiability is the householder’s best protection against the doorstep impersonation that scheme launches attract. Third, build in performance monitoring with a clear complaints route and a published suspension and removal process, so registration remains a living quality signal.

NI Trades operates a tradesperson platform across all 11 council areas, verifying identity, insurance and credentials at application. We would gladly support the register’s public accessibility at no cost, whether by hosting or mirroring the registered contractor list on nitrades.co.uk, displaying registered contractors’ scheme accreditations and coverage areas in a searchable form, or sharing what we observe about trade coverage gaps by council area and trade type.

8. Is industry ready to adopt or move to the principles of PAS 2030/2035?

Industry in Northern Ireland is not ready today, and precisely because PAS 2030/2035 (or an equivalent) is clearly the direction quality assurance is heading, we would urge the Department to treat building that readiness as part of the fund itself rather than a matter left to industry.

The readiness gap is structural, not attitudinal. PAS became embedded in Great Britain through schemes such as ECO, which never operated in Northern Ireland; NI's schemes have not required PAS certification, so most competent NI installers have never needed PAS 2030, and the Retrofit Assessor and Retrofit Coordinator roles that PAS 2035 depends on barely exist as a workforce here. GB experience also shows the cost side: certification and per-job documentation costs pushed smaller installers out of scheme work and concentrated delivery in larger firms. Northern Ireland's trade base is dominated by small firms and sole traders; importing that consolidation effect unmanaged would shrink capacity and rural coverage exactly when the fund needs both.

We therefore support the staged approach proposed, existing trade-body accreditations first, PAS later, on condition that the transition is actively built, not merely announced. Specifically: publish the transition timeline and criteria well before any switch, so firms can invest with confidence; fund or subsidise PAS certification costs for small NI firms as part of the scheme’s delivery budget; commission Retrofit Assessor and Coordinator training through the further education colleges, with target numbers, before PAS 2035 is relied upon; and make the transition trigger a published readiness review, not just a date. Done well, this is an economic opportunity as much as a compliance exercise: a PAS-certified NI installer base can compete for retrofit work beyond this fund, including in Great Britain, and the fund is the natural instrument to create it.

9. Are there other standards or accreditations that should apply?

First, and most important for Northern Ireland: OFTEC. Around two thirds of NI homes heat with oil, the highest share in the UK, so a fabric-first fund fitting air source heat pumps here will spend much of its life decommissioning oil systems: draining, removing and safely disposing of tanks and appliances. OFTEC registration is the recognised competence for oil-fired equipment and tank work, and its omission from a list built for the most oil-dependent housing stock in the UK looks like a GB template imported unadjusted. Any contractor removing or decommissioning oil installations under the fund should hold the relevant OFTEC registration.

Second, NAPIT alongside NICEIC for electrical work. Both are long-established, equally recognised electrical registration bodies operating in Northern Ireland; specifying NICEIC alone would arbitrarily exclude a substantial share of competent, registered NI electricians and shrink the available pool for the extensive electrical work heat pumps, PV and battery storage require.

Third, HETAS for solid-fuel appliances, which the fund will encounter when replacing or removing solid-fuel heating in older rural properties.

10. Are the proposed aftercare arrangements sufficient?

The first gap is seasonal. A follow-up at 6 to 12 weeks after installation will, for most installations completed in spring and summer, occur before the equipment has ever worked hard. Problems with air source heat pumps, running costs, comfort settings, and post-insulation condensation overwhelmingly surface in the first heating season, not the first quarter. We recommend a second, scheduled contact during the first winter after installation (November to February), when the householder is actually living with the system under load, with a visit where needed. For heat pumps in particular, this first-winter contact should include a running-cost conversation, since a heat pump on an unsuitable electricity tariff can cost more to run than the system it replaced, and the householder will conclude the technology failed rather than the tariff.

The second gap is independence. The proposal routes any follow-up visit to the contractor who completed the works, which means the party who may have caused a defect is the party assessing it. Routine snags, fine; but there must be an independent escalation route where the householder disputes the contractor’s assessment, a defined defects liability period, and, critically, provision for contractor insolvency: works of this value should carry insurance-backed guarantees so the remedy survives the firm. The Managing Agent should own the aftercare outcome, not merely instigate the phone call.

Three additions. First, handover education at completion, not just a call weeks later: heat pumps run on principles opposite to the boilers households have used all their lives, and older applicants in particular need a plain-language demonstration and a leave-behind guide, with the phone follow-up building on that rather than substituting for it. Second, telephone-only instigation will miss some of the most vulnerable applicants; the Managing Agent should follow non-responders by letter and accept contact through a trusted intermediary such as a family member or support organisation. Third, aftercare should double as scheme monitoring: collecting satisfaction, faults and, where consented, energy usage data, so the fund learns which measures and contractors perform.

11. Equality implications

Age. Several proposals interact badly with older applicants specifically: first-come, first-served assessment queues advantage the digitally connected and disadvantage older, offline households; the £6,000 savings floor is less generous than the £10,000 the state already applies to pensioners through Pension Credit; Pension Credit passporting inherits that benefit’s well-documented under-claiming among eligible pensioners; and telephone-only aftercare instigation will miss some older householders. Individually modest, together these tilt the fund away from the age group most exposed to fuel poverty. Proactive outreach through trusted community organisations, plain-language rules, and non-telephone contact routes are equality measures, not administrative extras.

Disability. We strongly welcome the exclusion of disability and health related benefits from the income assessment; we urge that this disregard be advertised prominently, because entitled households who assume these payments count as income simply never apply. Whole-house works are also more disruptive for disabled householders and those with dependants: scheduling flexibility, clear communication about disruption, and decant support where needed should be built into contractor requirements. All scheme materials should be available in accessible formats; the EasyRead consultation document sets a good precedent.

Rural. Northern Ireland’s rural households are disproportionately oil-heated, in older, harder-to-treat properties, and thus disproportionately in the fund’s priority group; they are also worst served for contractor coverage. Two proposals compound this: the VAT-registration requirement and any accreditation route that is disproportionate for small firms both shrink the rural contractor pool, since rural areas depend most heavily on sole traders and small local firms. We would encourage the rural needs assessment to consider delivery capacity by council area, not only eligibility.

Employment status. The requirement for three consecutive Universal Credit assessment periods disadvantages seasonal and self-employed workers whose UC entitlement fluctuates month to month with earnings, a pattern common in rural Northern Ireland and in the construction trades themselves. A look-back approach would treat these households equitably.