CFP response to the DBT Smarter regulation consultation
Published 29 January 2024
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The Committee on Fuel Poverty answers consider the impact of these proposals on the fuel poor and therefore focus on the impact on consumers of energy services.
23. What are your views on the creation of a single, multi-sector Priority Services Register (PSR)?
In principle The Committee on Fuel Poverty supports the better use of data across regulated services as advocated by Ofgem in their Vulnerability Strategy 2025 and Ofwat’s Vulnerability Focus Report 2016 if this leads to improved identification and support for vulnerable customers.
We do however have concerns about how data is gathered and updated. We believe it is essential for customers to be added to the PSR with their agreement and be easily able to remove themselves if their circumstances change. Work on fuel poverty has shown that although the numbers in fuel poverty remain fairly consistent, the households who account for the fuel poor can change as people move home or their income alters through a change in their circumstances. [footnote 1]
Customers must see a benefit in being on a shared PSR, and confident that energy or other utility companies can be trusted to store and share data in ways that are beneficial and not punitive. The recent example of introducing prepayment metering when customers are indebted through existing smart meters without adequate consent is an example of poor practice. There are several examples of successful tell us once/one stop shop approaches given in Appendices with a strong customer focus providing models of good practice.
We share the concern about the low take-up of existing support for energy efficiency schemes and income support payments for fuel poor households. A well-designed PSR could assist in better targeting. In our 2023 Annual report we emphasise the benefits of improved partnership working to identify and support fuel poor households.
24. What are the best data sources of vulnerability that the PSR should use? Who should be able to input data?
We recognise the need for safeguards in input, access and data sharing, and support the proposal for appropriate and controlled access to data. We support the need to protect confidentiality through means such as Unique Property Reference Numbers for customers who are fuel poor. Local advice, health and local authorities could potentially input data with the customers consent through an easy to use portal. Access to and use of the data would need to be strictly controlled and used only for the purpose it was inputted i.e. to target resource and support to vulnerable households. A shared PSR could be of benefit not just to regulated companies but could also assist other agencies seeking to support the fuel poor. For example, a shared PSR could assist local authorities who administer energy efficiency funding to identifying eligible households.
25. What vulnerabilities and services should the PSR cater for?
Definitions of vulnerability both within sectors and across the three regulated services under review differ and place different emphasis on characteristics or circumstances to trigger inclusion on the register. The criteria chosen must link to the expectations of how the register will be used. The consultation document suggests that Ofgem-led working group should be expanded to include Government departments to co-ordinate Government input into a PSR. We see this as linked to better use of Government data to improve targeting of fuel poor households in energy efficiency and financial support schemes. We are of the view that a core of agreed vulnerability criteria for a multi-sector PSR should include, as the consultation document suggests, financial vulnerability criteria.
26. How can existing affordability support be better communicated to increase customer awareness?
The Committee on Fuel Poverty shares the concern for the low take-up of support. We have commissioned research into understanding the barriers and enablers to supporting the fuel poor to make a fair and equitable transition to net zero. This will include consideration of the customer journey and the drivers to engage with programmes. The publication of this research in the spring 2024 is beyond the deadline for response to this consultation, but we expect the research findings to assist with answering this question.
In our annual report we highlighted the difficulties that come with an overly complex landscape of support for the fuel poor, with a plethora of schemes and programmes with differing eligibility criteria and timeframes. Straightforward non-stigmatising language that encourages people to self-identify, ease of access, and clarity about use and benefits are all important components of a multi-sector PSR.
There are lessons to be learnt from the recent challenges in take-up of the Energy Bill Support Scheme where this was not automatic. There was ample evidence to show that relying on digital communication alone is not sufficient. Persistence and repeated communication was required through a variety of channels - letter, phone, promotion by advice agencies, social landlords, newsletters, as well as on-line.