Policy paper

Equality impact assessment for the Heat and buildings strategy

Updated 1 March 2023

This was published under the 2019 to 2022 Johnson Conservative government

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This publication is available at https://www.gov.uk/government/publications/heat-and-buildings-strategy/equality-impact-assessment-for-the-heat-and-buildings-strategy

This document records the analysis undertaken by Department for Business, Energy and Industrial Strategy to fulfil the requirements of the Public Sector Equality Duty (the equality duty) as set out in section 149 of the Equality Act 2010.

1. Outline of proposal

This Equality Impact Assessment (EIA) assesses the overarching impacts of the 2021 Heat and Buildings Strategy (HBS). The HBS provides a strategic overview of the existing and planned policy interventions required to decarbonise our buildings to enable the UK to meet its legally binding carbon budgets, lowering energy bills, improving quality of life and supporting skilled green jobs and our longer-term net zero targets.

This EIA is based on policies set out in the HBS published in October 2021. It includes references to responses to consultations that have been published since the HBS, where they have enabled an improved understanding of how HBS policies may impact protected groups. In developing the HBS and associated policies, regular engagement with stakeholders was conducted and has fed into individual policy-level EIAs and this EIA.

The impact of HBS policies on protected characteristics will continue to be considered as part of our policy development, and we will continue to review, monitor and evaluate policies to consider the impact on those with protected characteristics as we work to decarbonise buildings within the UK.

The HBS and related policies support key government commitments including:

  • The UK’s statutory five-year carbon budgets
  • The UK’s statutory target of reaching Net Zero greenhouse gas emissions by 2050
  • The statutory fuel poverty target for England – to improve as many fuel poor homes as is reasonably practicable to achieve a minimum energy efficiency rating of Band C by 2030
  • The UK’s nationally determined contribution (NDC) to the Paris Agreement – to reduce economy-wide greenhouse gas emissions by at least 68% (compared to 1990 levels) by 2030

The HBS sets out the context and scale of the challenge required to decarbonise buildings, namely:

  • Buildings are responsible for around 30% of our national emissions. [footnote 1] The vast majority of these emissions result from heating: 79% of buildings emissions and about 23% of all UK emissions. [footnote 2] (estimates from 2019)
  • The majority of the UK building stock uses fossil fuel heating systems, with natural gas central heating being used to heat 86% of homes in England. [footnote 3]
  • A significant amount of the UK building stock has low thermal efficiency, so much heat is wasted. Only about 46% of the total housing stock were rated at Energy Performance Certificate band C and above in 2020. [footnote 4]

The HBS includes new ambitions and policy proposals to set the direction of travel to decarbonise buildings and put us on track to meet our legally binding carbon budgets, and net zero greenhouse gas emissions by 2050. The strategy emphasises policies which will help us move away from wasting energy and burning fossil fuels for heating and present enormous opportunities for jobs, growth and levelling up.

The HBS contains a suite of ambitions, proposals and consultations, including:

  • A target to upgrade households to Energy Performance Certificate (EPC) C by 2035 where practical, cost effective and affordable.
  • An ambition to phase out the installation of new natural gas boilers by 2035, using natural trigger points such as when an existing gas boiler reaches the end of its life.
  • Proposals to end installations of fossil fuel heating systems in properties not connected to the gas grid.
  • Ambitions to grow the low carbon heating systems market, including scaling up the installation of heat pumps to 600,000 installations per annum by 2028, develop the market and accelerate deployment of low carbon heat networks.
  • An ambition to work with industry to reduce the upfront and running costs of heat pumps by 25-50% by 2025 and to parity with boilers by 2030.
  • The implementation of the Future Homes Standard from 2025, which will ensure that new homes are constructed with high levels of energy efficiency and low carbon heating with no need for retrofitting at a later date.

The HBS communicates a gradual approach to decarbonising buildings, taking a ‘fabric first’ approach to improving energy performance and then incentivising consumers by providing financial support to encourage green choices (e.g. through our new Boiler Upgrade Scheme). These actions are intended to grow markets to bring down costs of key technologies such as heat pumps, create choice and minimise disruption for households and businesses.

By the mid-2020s, major strategic decisions will be required, including on the role of hydrogen in heating buildings. We will continue to prioritise research and innovation to improve technologies and build the evidence base to inform these decisions. This research may also help us mitigate impacts to individuals sharing protected characteristics. It is important that this is balanced with moving ahead with low-regret deployment of energy efficiency and low carbon heating to meet near term Carbon Budgets. As well as providing opportunities for economic growth and job creation, prioritising improvements in the energy efficiency of buildings will help to reduce bills in the long term, improve the health and warmth of our buildings, and ensure that we meet our statutory fuel poverty target.

The HBS is clear that the policies it sets out will not take us all the way to 2050. The HBS and associated suite of policies and support schemes have been developed in a way to prioritise support for vulnerable households, and enable them to reap the benefits of greener, more energy efficient homes.

While the policies included in the HBS impact all UK citizens, from small businesses to global conglomerates and fuel poor households, to landlords owning a portfolio of properties, the proposals have been designed to best support different building and tenure types which face different decarbonisation challenges. For example, there may be alternative support available for social housing tenants than there is for owner occupiers as they are impacted differently. Therefore, these policies affect both individuals that share protected characteristics, and those who do not.

Though the policies in the HBS impact a cross-section of consumers, to ensure that potential additional negative impacts to key groups are mitigated, the HBS embeds a principle to protect vulnerable and low income households, where some protected characteristics are overrepresented [footnote 5], such as ethnic minorities and those with disabilities.

The HBS prioritises financial support for the vulnerable and those in fuel poverty through energy efficiency schemes, such as the Local Authority Delivery Scheme (LAD), Home Upgrade Grant (HUG) and Social Housing Decarbonisation Fund (SHDF), totalling a record level of investment of £6.6 billion on clean heat and energy efficiency over this Parliament. The Government has also expanded the Energy Company Obligation 4 and Warm Home Discount schemes until 2026. Both these schemes are focused on those most in need and will provide over £6.2 billion of support to low income and vulnerable households, an increase of more than £1.7 billion between 2022 and 2026. The £450 million Boiler Upgrade Scheme also provides households with grants of up to £6,000 to support the purchase of low carbon heating.

2. Summary of the evidence considered in demonstrating due regard in relation to the equality duty

This section sets out the evidence considered as to the extent that building policies affect those with protected characteristics.

Evidence on the impacts of policies within the HBS was considered across a range of consultations, government responses and external sources to identify potential areas of discrimination and opportunities to improve equality and foster good relationships. Details of key evidence sources that indicate characteristics potentially impacted by policies within the HBS are set out below, with identification and further analysis of the impacts in sections 3 and 4.

Race

Age

Disability

Gender reassignment

  • No evidence of impact

Sex

  • No evidence of impact

Sexual Orientation

  • No evidence of impact

Being married or in a civil partnership

  • No evidence of impact

Being pregnant or on maternity leave

Religion or belief

  • No evidence of impact

In addition to the above, some of the policy proposals contained within the HBS, including Private Rented Sector (PRS), Home Upgrade Grant and Social Housing Decarbonisation Fund are modelled using the National Household Model (NHM). The NHM is a discrete event simulation model that allows the user to model supplier actions by installing various measures in different houses and estimating the impact. The model is based on the English Housing Survey (EHS), an annual survey of 13,000 face-to-face interviews and 6,000 physical surveys of households in England which, when taken together, represent all the different house types in the country. To estimate impacts for Great Britain as a whole, outputs have been scaled up based on the ratio of the number of households in England to Great Britain, calculated from official statistics. In terms of protected characteristics, the EHS only captures age, disability and race, as sample sizes are too small to be robust for other metrics. There is a need for policies which are based on this model to undertake actions to further understand the impacts across all protected characteristics.

BEIS also collects a range of evidence, including energy efficiency statistics, which are published monthly. The evidence is used to understand and measure the impact of our policies. [footnote 6] The datasets inform the public about our progress in improving the energy efficiency of our buildings, and how we are progressing toward our fuel poverty target.

3. Impacts identified

Evidence shows that ethnic minorities, those living in household where the oldest person is aged 16-24 and households containing people with disabilities are overrepresented in fuel poor households [footnote 7], [footnote 8]. People who are elderly, very young, disabled, or pregnant are also at elevated risk of negative health outcomes from cold homes [footnote 9], [footnote 10], [footnote 11], [footnote 12]. The HBS is committed to improving the energy efficiency of the UK building stock, and to supporting the most vulnerable in the transition to low carbon buildings. A number of HBS policies – such as the HUG, SHDF, LAD scheme, ECO4, the Winter Fuel Payment and Warm Home Discount – provide targeted support for vulnerable, low income or fuel poor households, and those with energy inefficient homes. Further details on page 4 and 1 0-11.

We recognise that there are other challenges that may impact certain protected characteristics. There is a risk that those who are digitally excluded (typically older people) may be less aware of HBS policies or support available. We also understand that the disruption that can be associated with retrofitting may present particular challenges to certain groups.

While the evidence does not indicate that HBS policies will disproportionately impact other protected characteristics (gender reassignment, sex, sexual orientation, being married or in a civil partnership, religion or belief), the potential for any impacts will remain under review as policies develop, and after implementation. We will continue to consult stakeholders on the impact of our policies. The Government is committed to continuing to undertake Equality Impact Assessments (EIAs) for new heat and buildings policies.

The remainder of this section assesses the impact of some of the key themes of the HBS against the three limbs of the public sector equality duty, with reference to evidence received in respect of individual policies comprised within it.

1. Eliminate unlawful discrimination, harassment, victimisation and any other conduct prohibited by the 2010 Act.

Some of the policies set out in the HBS may have disproportionate impacts, both positive and negative, on vulnerable low income households. Although ‘vulnerability’ and ‘income’ are not protected characteristics, as set out above, people with disabilities, younger and older households, and people from ethnic minorities are disproportionately represented in low income and vulnerable groups [footnote 13]. Additionally, given National Institute for Health and Care Excellence guidance [footnote 14], we define vulnerable low income households as being linked to ‘age’ and/or ‘disability’ protected characteristics. [footnote 15] The HBS and its constituent policies seek to mitigate for the risk of unlawful discrimination against vulnerable low income households. As set out in section one, the HBS prioritises financial support for the vulnerable and those in fuel poverty through schemes such as the LAD, HUG and SHDF.

Some policies, such as changes to heating systems (as proposed in our end to installation of natural gas boilers from 2035 and our proposal to end installation of fossil fuel heating in off gas grid homes from 2026) and the installation of energy efficiency measures required to meet EPC targets, may cause disruption to residents that asymmetrically affect some protected groups.

Evidence from the English Housing Survey [footnote 16] suggests that occupants of homes off the gas grid tend to be older on average [footnote 17], meaning elderly consumers may be more affected by the proposed regulations to phase out fossil fuel heating in off grid homes than younger consumers. This is due to the demographics of the off-gas grid housing stock, rather than a deliberate attempt to target this group of consumers.

A possible impact on protected characteristics is the potential inconveniences of building work on older age groups and those with disabilities. This was considered via consultation, where some respondents noted that some vulnerable consumers may be less able to manage the process of changing their heating system, or be less able to operate new and unfamiliar heating systems. Respondents highlighted that some households may therefore require additional support and advice to steer them through the installation process and help them to operate their new heating system efficiently once installed.

Respondents also noted the need for government to address financial barriers to heat pump deployment – which government is doing through a range of schemes such as HUG, LAD and SHDF.

Our suite of policies that will phase out the installation of fossil fuel heating off the gas grid are still in development, and we will continue to engage with stakeholder groups to ensure potential negative impacts on people with protected characteristics are recognised and considered as part of policy development. Wider actions we are taking across the policy portfolio to develop and grow the market for heat pumps, including, the provision of high-quality information and advice, maturing supply chains and training of installers, should ensure that any negative impacts are limited.

In line with the responses to our consultation, our assessment is that it is unlikely that the policies will have disproportionate direct negative impacts on population groups with protected characteristics under the Equality Act 2010.

Where homes are not appropriately heated, for example, because heating systems are undersized or because there is a break in service when an oil boiler breaks down, reports including the Heat Networks Market Framework (2020) and Fuel Poverty Strategy (2019) suggest that elderly [footnote 18], pregnant and disabled groups may be particularly affected and at an elevated risk of negative health outcomes [footnote 19]. Access to skilled installers who can install new systems quickly and to a high standard will therefore be critical during the shift to low carbon buildings. We are supporting this through the work we are doing with industry, to ensure the heat pump installer base can rapidly expand to accommodate the increasing numbers of heat pump installations by 2026, and that heat pump installers are properly trained in low carbon heating technologies.

To support the most vulnerable through the transition to low carbon buildings, policy design is crucial to ensure certain groups do not miss out on support, in particular the elderly and people with disabilities. For example, in responding to consultations on the Warm Homes Discount and ECO4 schemes some stakeholders expressed concerns that some households with people with disabilities risk becoming ineligible for support under the new requirements.

However, under both the Warm Homes Discount (WHD) and ECO4 schemes, mitigations have been put in place to protect these groups. As set out in our responses to these consultations, the WHD has been expanded and reformed to better identify those in need of support and remove barriers to support by awarding rebates automatically. Government also introduced ECO4 Flex to ensure households with an occupant whose health condition may be worsened from living in a cold home can qualify for support.

Ensuring all households, irrespective of their heating source, have an advocate is essential to eliminate unlawful discrimination. This is particularly an issue for heat networks customers, That is why, and as set out in the Heat Networks Market Framework consultation, government committed to appointing Citizens Advice as the consumer advocacy body for heat network consumers, and is seeking to regulate heat networks via the Energy Bill introduced to Parliament on 6 July 2022 to allow for that appointment to be made.

Social housing is an area where delivering improvements to energy efficiency and heating can particularly benefit the vulnerable. The Social Housing Decarbonisation Fund (SHDF) aims to target inefficient homes rated EPC Band D and lower and will consequently impact households in fuel poverty, delivering energy efficiency and heating upgrades to lower their energy costs and improve health and wellbeing. Social housing occupants are more likely to be fuel poor, from an ethnic minority or disabled than in other housing sections.

Key funding requirements have been set for the SHDF to ensure tenants’ well-being, comfort and health are considered throughout the scheme. The SHDF also carried out stakeholder engagement through its ‘learning community’, which speaks directly to social housing landlords on various topics including equality and considers protected groups in retrofit projects. We also consulted with academics and spoke directly to a small group of social housing tenants brought together by the Northern Housing Consortium, their ‘Tenants Climate Jury’. The results of this stakeholder engagement led to the SHDF changing the application process, requesting social housing landlords to specifically reference planned considerations towards vulnerable tenants, particularly those with protected characteristics.

Reasonable adjustments can be made to mitigate the inconvenience of retrofit work for groups that may find it more difficult to accommodate. For example, the SHDF consulted with academics and spoke directly to a small group of social housing tenants brought together by the Northern Housing Consortium, their ‘Tenants Climate Jury’. The results of this stakeholder engagement led to the SHDF changing the policy and application process, requesting social housing landlords to specifically reference planned considerations towards vulnerable tenants, particularly those with characteristics listed under the Equality Act 2010.

Such provisions ensure that individual needs are considered and catered for in policies and allow protected groups to benefit from the positive impacts of improved energy efficiency. Government will continue to assess potential negative impacts of our policies, and mitigations.

We do not anticipate HBS will impact on sexuality, gender reassignment, religion, sex, or marital status. We will continue to assess potential impacts during policy development and implementation.

2. Advance equality of opportunity between people who share a particular protected characteristic and people who do not share it.

Prices and bills

Below we set out how price and bill impacts on consumers will be carefully considered during policy design, and in some cases low carbon solutions are more efficient and may lead to bill savings.

The potential for the shift to low carbon heating leading to increased energy bills which subsequently impact on fuel poor households, where those with protected characteristics are overrepresented, was raised in responses to consultations on Heat Network Zoning and the Green Gas Levy. In response, government committed to implementing stringent budget control measures for the Green Gas Support Scheme, limiting the funds that could be raised by the Green Gas Levy. These ensure that bill impacts are as low as possible and cannot rise unexpectedly. While Heat Networks Zoning will involve certain buildings in zones being required to connect a heat network, we propose that exemptions may be sought where it would not be cost-effective to connect compared to an alternative low carbon solution [footnote 20]. This is an example of how the vulnerability principle is practiced across HBS policies.

In addition, some heat networks can help consumers save on bills. Research into consumer experience of heat networks commissioned by BEIS indicated that those aged 65 or above were typically overrepresented in buildings connected to heat networks [footnote 21]. Heat networks are also more suited to areas of denser population; therefore it is assumed a higher proportion of ethnic minority backgrounds may be connected to them than the proportion within the wider UK population [footnote 22]. Consequently, HBS policies could advance equality of opportunity for these groups.

Within the HBS we restated our intention to look at options to shift energy levies and obligations away from electricity to gas over this decade. This would have intentional negative impacts on those continuing to use fossil fuel heat sources as a way to disincentivise this behaviour. This would be balanced by the positive impacts to those switching to heat pumps and other technologies using electricity. During policy development we will aim to identify, assess and mitigate equality impacts to individuals with protected characteristics, drawing learnings from policies referenced above.

We note that since the publication of the HBS, the cost of energy has become an increasingly significant issue for many households and Government has taken steps to mitigate impacts via the Energy Price Guarantee and Energy Bill Support Scheme, in addition to other welfare measures. However, these issues are outside the scope of this EIA as it applies to the Heat and Buildings Strategy, and policies within, as of October 2021.

Fuel Poverty Annual statistics published in 2021, indicate that households with an ethnic minority Household Reference Person (HRP) have a higher likelihood of being in fuel poverty but a lower average fuel poverty gap than households with a white HRP [footnote 23]. Households where the age of the oldest member is between 16 and 24 have the highest likelihood of being in fuel poverty (25.2%), with an average gap of £156. [footnote 24]

In England, the statutory fuel poverty target is to ensure that as many fuel poor homes as is reasonably practicable achieve a minimum energy efficiency rating of Band C, by 2030. It is the government’s view that energy efficiency improvements are the best way to tackle fuel poverty in the long term, contributing to the long-term reduction in energy bills as well as reducing carbon emissions in line with Net Zero.

The view that energy efficiency measures are an effective means for lowering bills in in all housing tenure types is widely shared. However, some respondents to publications, such as BEIS’s Building a Market for Energy Efficiency Call for Evidence have flagged the need to prioritise measures for the fuel poor through energy efficiency policies.

Several schemes are in place to deliver energy efficiency upgrades to low income or fuel poor homes that will help reduce their energy costs, advancing equality of opportunity, including:

  • HUG provides funding for energy efficiency upgrades and low carbon heat installations, taking a whole house retrofit approach to the worst performing and low income properties.
  • The SHDF supports social landlords to make energy efficiency and low carbon heat upgrades. The SHDF targets households in social housing that are more likely to be fuel poor, from ethnic minorities or disabled persons, meaning the SHDF will disproportionately benefit these groups.
  • The LAD scheme provides funding to local authorities across England, supporting low income households in all English regions.
  • ECO4 is focussed on delivering upgrades to low income and vulnerable households in EPC Band D-G homes.
  • In addition, government supports a number of schemes aimed at alleviating fuel poverty including the Winter Fuel Payment and the Warm Home Discount

These schemes focus on low income and vulnerable households who are at risk of living in fuel poverty. As noted above, these schemes are therefore expected to further advance equality of opportunity for those with a protected characteristic.

Upfront Costs

Government recognises that the cost of a low carbon heating system installations may be a barrier to those on lower incomes. This has the potential to disproportionately impact groups that are over-represented in this bracket, including race, disability, and younger people [footnote 25].

We have taken steps to reduce these barriers, which has been acknowledged by stakeholders. It is our assessment that the Boiler Upgrade Scheme (BUS) has limited adverse or disproportionately negative impacts on at-risk groups and those who share a protected characteristic. The BUS is a demand-led, voluntary scheme with deployment across England and Wales. The grant model is designed to broaden access to support versus tariff mechanisms where the full costs of installations are required to be paid by customers upfront. This view was shared by stakeholders in responses to the public consultation conducted on the Future Support for Low Carbon Heat consultation proposals in April 2020. We will, however, evaluate the scheme to examine participation across different demographics.

Vulnerable households supported by schemes such as the Home Upgrade Grant (HUG) and SHDF have low carbon heating installed without any exposure to the upfront costs. Protecting these most vulnerable households from the costs of the transition to low carbon buildings is in line with the principles of the HBS. HUG specifically aims to support low income households living off the mains gas grid in England. Off grid households are likely to make the transition to low carbon heating first. Due to the focus of the scheme on low income and fuel poor households the HUG scheme is expected to advance the equality of opportunity for households with a protected characteristic by providing full grant funding for low income households. However, the full PSED Impact Assessment for the HUG scheme did reflect that due to the prevalence of rural households in the eligible pool, white households are overrepresented at 96% of the HUG eligible pool versus 89% in the general population.

Workforces

The policies and proposals in the HBS can increase employment opportunities in low carbon and green sectors but pose transition risks for some high carbon sectors. The HBS states it expects to support up to 240,000 jobs by 2035 resulting in £6 billion additional Gross Value Added by 2030. In addition, we are taking steps to ensure equality of opportunity for those looking to join the workforce needed to decarbonise buildings.

The HBS referenced an interim uplift to Part L of the Building Regulations 2010. During the policy development for the interim uplift to Part L of the Building Regulations 2010, we identified a risk that by requiring assessors to enter homes and take photographs of work carried out for the purpose of energy assessments there may be a negative impact on assessors who are disabled or have mobility issues. It was therefore decided to include flexibility in the statutory guidance as to who should take photographs to address this risk and mitigate any potential impact on disabled assessors.

The Green Jobs Taskforce identified that there is poor representation of ethnic minorities and women in a number of key green sectors [footnote 26]. There are opportunities to address this through diversity and inclusion schemes, traineeships and using government schemes to encourage inclusive hiring practices, as well as education policies such as Skills Bootcamps, T levels and traineeship programs.

The Taskforce looked at skills needs to reach net zero across the whole economy rather than just the buildings sector, however its’ findings regarding possible equalities impacts will be important considerations in future skills and supply chain policy development for energy efficiency and low carbon heating.

Access to infrastructure and public goods

There are significant opportunities across several policy areas to improve access to infrastructure and public goods through targeting of policy. For the Government’s commercial activities, the Government applies its commissioning to supporting key social outcomes through the Social Value Framework. The public sector must maximise social value effectively and comprehensively through its procurement. Applying social value requirements in procurement can have a significantly positive impact by broadening the benefits that are delivered. Key outcomes set out in the Social Value framework include creating new businesses, new jobs and new skills, reducing the disability employment gap, tackling workforce inequality and improving community integration.

Access to clean air is unevenly distributed across protected groups. Ethnic minorities are particularly exposed to air pollution [footnote 27]. Moving away from fossil fuel heating systems should reduce air pollution and improve air quality.

Access to HBS schemes and policies

Several respondents to consultations have highlighted that digital exclusion risks discrimination against groups not online, in particular the elderly and those with disabilities. For example, responses for the Fuel Poverty Strategy for England consultation called for offline customers to be protected from discrimination, noting that the digital divide is increasing and must be addressed. They also said that the best tariffs should be available to all consumers, especially the vulnerable, elderly and disabled - those most likely to be offline.

As set out in the consultation response, current licence conditions give energy suppliers flexibility to charge prices in line with cost of delivery, including the difference in cost between paper bills and online bills. This is a matter for Ofgem to consider.

Government has taken steps to improve access to its content and communication channels. For example, in July 2022 it launched a new energy retrofit advice service on GOV.UK to help people understand how best to make changes to their homes. Acknowledging the potential risk of digital exclusion, particularly to older people, the website will later this year be supported by a new phoneline, and a local advice provision service. The phoneline will provide trusted advice to consumers who need further information on their home energy retrofit journeys and provide a digital assist service for the energy advice tool on GOV.UK, allowing those not online access to vital information.

In the next financial year, Government will also launch a series of local demonstrator projects, which will test various approaches to delivering in-person advice, with a particular focus on harder-to-treat properties, vulnerable and digitally excluded consumer groups. Lessons learnt from these projects will inform further action post-2025.

We will continue to review and improve our digital content and communication methods to make sure they are accessible and understandable to all.

Wider Impacts

Without mitigation efforts, climate change will continue to intensify well into the 21st century [footnote 27]. Adverse impacts of uncontrolled global warming will disproportionately impact currently young people, who will survive to see higher levels of global warming for a longer period of time. Thus, mitigating climate change advances equality of opportunity between older and younger generations.

The UN states that “climate change has a greater impact on those sections of the population, in all countries, that are most reliant on natural resources for their livelihoods and who have the least capacity to respond to natural hazards” [footnote 28] and thus that “the negative impacts of climate change will disproportionately affect individuals, groups and peoples in vulnerable situations including women, children, older persons, indigenous peoples, minorities, migrants, rural workers, persons with disabilities and the poor” [footnote 29]. Research has noted that this may be because some protected groups can be more exposed to, more susceptible to, and less able to cope and recover from damage caused by climate change. [footnote 30] Thus, mitigation of climate change is highly likely to advance equality of opportunity among protected groups.

3. Foster good relations between people who share a particular protected characteristic and people who do not share it.

Within the HBS, we have committed to review and improve the way we communicate information and provide support. Our approach to public engagement seeks to communicate with and gather feedback from the public – including those who share protected characteristics and those who do not. In this way, we aim to foster good relations.

4. Impact analysis

The HBS sets out a suite of policies and proposals to reduce greenhouse gas emissions, limit the extent of global warming and tackle climate change.

We have identified potential positive impacts to vulnerable, low income and fuel poor households, such as by providing financial support and improving home environment. Potential negative impacts have also been identified but are limited, mitigated and justifiable in view of the overall objectives (tackling climate change, levelling up and tackling fuel poverty).

Furthermore, across policies, there are examples from government responses of mitigations being put in place via exemptions (Heat Network Zoning) or budget controls (Green Gas Support Scheme) to protect fuel poor households, and steps being taken to reduce risks of digital exclusion (such as updates to GOV.UK page). These changes are consistent with the HBS principle to support the most vulnerable through the transition to low carbon buildings.

More broadly, mitigation of climate change is highly likely to advance equality of opportunity among some protected groups. This is particularly the case for young people, who disproportionately benefit from avoiding future global warming, and protected groups which are disproportionately low income and exposed to natural hazards.

The potential positive impacts of the trajectory and proposals set out in the HBS include:

  • environmental (emission reduction and air quality benefits)
  • economic (reducing costs, opportunities for investment, market growth, jobs and skills)
  • levelling up and tackling fuel poverty
  • health and wellbeing (reducing and avoiding physical illnesses, warmer comfortable working and living environments).

Some of these benefits, such as reduced energy costs and warmer homes, may be felt more by vulnerable low income households – which correlates with age, race, ethnicity and disability.

The HBS sets out a phased approach to the transition to Net Zero – targeting specific housing and building types in different ways. Because of this phased and targeted approach, there is very little overlap between our policy package, except in instances where multiple policies are targeted to provide support for low income and fuel poor households (where people with certain protected characteristics are likely to be overrepresented), wherein the cumulative effects of these policies are positive.

The majority of UK buildings are likely to undergo some disruption in order to become more energy efficient and make the switch to low carbon heating. Our policy framework will, therefore, need to include mitigations to minimise risks of discriminating against groups who may be disproportionately impacted by physical changes to their homes due to their circumstances, for example those with disabilities. The policies within the HBS seek to grow markets for energy efficiency and low carbon heating in a way that ensures a positive experience for households, including minimising disruption and reducing costs.

The introduction of proposed minimum energy efficiency standards and phase out dates for high carbon heating systems within the HBS is phased and targeted - so that a building or household is likely to only have to enact changes through one regulatory lever. For example, households in off gas grid properties are expected to need to make a switch to low carbon heating when replacing fossil fuel heating systems from 2026, but they will not then need to switch again in 2035, as the 2026 date is specific to off gas grid properties, but the 2035 date is specific to on gas grid properties. In this way, negative cumulative impacts to people with protected characteristics have been kept to a minimum. The introduction of further policies, including changes to fuel pricing in future will be assessed to ensure that they do not have a cumulative negative impact on people with protected characteristics in future.

5. Recommendations

As established in the preceding sections, the policies and proposals included in the HBS have a wide range of impacts that could both positively and negatively impact individuals with protected characteristics.

The department has considered the impacts of not actioning heat and buildings decarbonisation policies; which would be likely to cause far more negative impacts both to the general population and to those with protected characteristics.

Furthermore, a number of adjustments have already been built into some of the policies in the HBS (as described in earlier sections) to mitigate impacts on those with protected characteristics. Significant financial support is also provided to vulnerable households. Considering this, BEIS has taken the view that any potential negative impacts are justifiable in view of the overall objective of tackling climate change, levelling up, and supporting delivery against legal targets.

Therefore, we intend to proceed with our policies and services. Additionally, we intend to continue to monitor and adjust the policies in the strategy, as appropriate, considering the latest evidence and research to limit negative impacts to individuals with protected characteristics and take steps where necessary to advance equality of opportunity and foster good relations between groups.

6. Monitoring and reviewing

We will seek to monitor the effectiveness and appropriateness of our strategy, and the policies and proposals embedded within it, through our monitoring and evaluation processes. Projects and policies in the HBS will complete process and impact evaluations after implementation. These evaluations will consider several high-level evaluation questions:

  • What has been the impact of the scheme, and did it achieve its original objectives?
  • How did the scheme generate any attributed effects on its stakeholders, including those with protected characteristics?
  • How effective and efficient has the delivery of the scheme been?

The key findings from these will be collated and summarised by the Department and used to inform future project and policy development.

These processes can help us to:

  • holistically assess progress, identify and maximise opportunities, manage risk and rectify issues
  • identify opportunities to mitigate and eliminate discrimination, improve equality of opportunity and foster good relations
  • prioritise projects and programmes that require additional support
  • meet our legally binding carbon budget contributions, including carbon budgets and net zero commitment
  • meet our statutory fuel poverty target to improve as many fuel poor homes as is reasonably practicable to achieve a minimum energy efficiency rating of Band C by 2030.

Some of the policies referenced in the HBS are still early in development and, therefore, have not been fully assessed for equalities impacts. These policies will undergo their own equality impact assessments and give consideration to this wider HBS EIA and the protected characteristics impacted ahead of final design and sign off by ministers, to ensure compliance with the PSED. We will continue to review, monitor and evaluate our assessment of impacts.

We will continue to engage with stakeholders when developing policy and legislation, including via formal consultations.

  • 65 or older
  • younger than school age
  • living with a long-term health condition which makes them more likely to spend most of their time at home, such as mobility conditions which further reduce ability to stay warm
  • living with a long-term health condition which puts them at higher risk of experiencing cold-related illness (for example, a health condition which affects their breathing, heart or mental health)

  1. BEIS (2021), Final UK greenhouse gas emissions national statistics: 1990 to 2019. And BEIS (2020), Energy consumption in the UK 2020. This figure includes indirect and direct emissions but excludes international aviation and shipping. ↩

  2. BEIS (2021), Final UK greenhouse gas emissions national statistics: 1990 to 2019. Includes indirect and direct emissions but excludes international aviation and shipping. ↩

  3. DLUHC (2021), English Housing Survey 2019 to 2020: energy, annex table 2.2. ↩

  4. DLUHC (2020), English Housing Survey 2020 to 2021: headline report, Annex Table 2.8. ↩

  5. Fuel poverty: Ethnicity facts and figures. Government figures on fuel poverty indicate that white households were less likely to be in fuel poverty than households from all other ethnic groups combined. ↩

  6. Household energy efficiency national statistics, and fuel poverty statistics are published annually. ↩

  7. Annual Fuel Poverty Statistics LILEE Report 2021 (2019 data) ↩

  8. Out in the cold: report ↩

  9. Sustainable warmth: protecting vulnerable households in England ↩

  10. Fuel poverty strategy for England ↩

  11. Fuel poverty: cold homes and health inequalities in the UK ↩

  12. Sustainable warmth: protecting vulnerable households in England ↩

  13. Annual Fuel Poverty Statistics LILEE Report 2021 (2019 data ↩

  14. NICE Guidance is evidence-based guidance for health, public health and social care practitioners. ↩

  15. Based on NICE guidance on Excess winter deaths and illness and the health risks associated with cold homes (NG6, 2015), in England we consider low income households to be vulnerable if at least one member of the household falls into one (or more) of the following categories: ↩

  16. English housing survey ↩

  17. Phasing out the installation of fossil fuel heating in homes off the gas grid: impact assessment ↩

  18. Protecting health and reducing harm from cold weather – local partnerships survey report ↩

  19. Fuel poverty, cold homes and health inequalities in the UK ↩

  20. In addition, consumers in heat network zones will be subject to the wider regulation of the heat network sector, as discussed above. ↩

  21. Heat networks consumer survey: consumer experiences on heat networks and other heating systems ↩

  22. According to the 2011 Census, the White ethnic group accounted for 86.0 per cent of the usual resident population in 2011. Source: ONS (2021). Ethnicity and National Identity in England and Wales: 2011. Available online at Ethnicity and National Identity in England and Wales: 2011 . ↩

  23. Annual Fuel Poverty Statistics LILEE Report 2021 (2019 data) ↩

  24. Annual Fuel Poverty Statistics LILEE Report 2021 (2019 data) ↩

  25. Annual Fuel Poverty Statistics LILEE Report 2021 (2019 data) ↩

  26. Net Zero Jobs ↩

  27. Fecht D, Fischer P, Fortunato L, Hoek G, de Hoogh K, Marra M, Kruize H, Vienneau D, Beelen R, Hansell Aet al., 2015, Associations between air pollution and socioeconomic characteristics, ethnicity and age profile of neighbourhoods in England and the Netherlands, ENVIRONMENTAL POLLUTION, Vol: 198, Pages: 201-210 ↩ ↩2

  28. Introduction to Gender and Climate Change, UNFCCC. ↩

  29. Understanding Human Rights and Climate Change, 2015, UNHRC . ↩

  30. Islam, N. and J. Winkel (2017), Climate Change and Social Inequality, UN Department of Economic and Social Affairs (DESA) Working Papers, No. 152, UN, New York. ↩

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