ECO Flexible Eligibility Statement of Intent (v3)

Hammersmith & Fulham Council ECO 4 Flexible Eligibility Statement of Intent

Local authority name: Hammersmith & Fulham

Publication date: 29 September 2023

Version number: V.3

Publication on website: H&F Council website

This statement sets out Hammersmith & Fulham Council's flexible eligibility criteria for the Energy Company Obligation (ECO4) and Great British Insulation schemes that run until March 2026.

The ECO4 scheme will focus on supporting low-income and vulnerable households. The scheme will improve the least energy-efficient homes helping to meet the government's fuel poverty and net zero commitments. The Great British Insulation scheme will support the ECO4 scheme in the delivery of predominantly single measures targeted at a wider range of households.

The flexible approach for local authorities (LAs) to identifying fuel poor and vulnerable households who may benefit from heating and energy-saving measures is referred to as 'ECO4 Flex' and 'Great British Insulation Scheme Flex'.

The council welcomes the introduction of the ECO4 Flex eligibility routes as it helps them achieve plans to improve the homes of those in fuel poverty or vulnerable to the cold.

The council is publishing this statement of intent (SOI), on 29 September 2023 to confirm that each of the households declared will adhere to at least 1 of the 4 available routes outlined.

Route 1: Owner-occupied households and private rented sector households with a gross annual income less than £31,000. This cap applies irrespective of the property size, composition, or region.

Route 2: Owner-occupied households and private rented sector households that meet a combination of 2 of the following proxies:

Proxy 1) Homes in England in Lower-layer Super Output Area 1 to 3 (LSOA) ^{[Footnote 1]} or homes in Welsh provision LSOA 1 to 3 on the Welsh Index of Multiple Deprivation 2019 ^{[Footnote 2]} or homes in Scotland in 'data zone' 1 to 3 on the Scottish Index of Multiple Deprivation for 2020 ^{[Footnote 3]}.

Proxy 2) A person living at the premises is entitled to a council tax reduction on the grounds of low income.

Proxy 3) A person living at the premises is considered to be vulnerable to the cold under the National Institute for Health and Care Excellence (NICE) guidance NG6: Recommendation 2, for reason other than their low-income ^{[Footnote 4]}.

Proxy 4) A child living at the premises is eligible for free school meals, due to low-income ^{[Footnote 5]}.

Proxy 5) A person living at the premises is supported by a scheme established by the LA or DA that is named and described within their statement of intent and established to support people living on a low-income and considered vulnerable to the cold under NICE Guideline NG6.

In Hammersmith & Fulham Council, residents may be eligible under this proxy if they have completed a warm and well assessment (and deemed eligible) which is carried out by the National Energy Foundation's Better Housing, Better Health service.

Proxy 6) A household referred to the LA for support by their energy supplier or Citizen's Advice or Citizen's Advice Scotland, because they have been identified as struggling to pay their electricity and gas bills.

Proxy 7) Households identified through energy supplier debt data. This route enables obligated suppliers to use their own debt data to identify either non pre-payment meter households (non-PPM) or pre-payment meter households (PPM).

Non-PPM customers

These are customers who have been in debt for more than 13 weeks ending with the day on which the declaration is made and are in a debt repayment plan with their energy supplier or repaying their fuel debt through 3rd party deductions.

PPM customers

Suppliers may also identify PPM households who:

have either self-disconnected or received supplier discretionary or friendly credit within the last 13 weeks ending with the day on which the declaration is made
are in a debt repayment plan with their energy supplier
repaying their fuel debt through 3rd party deductions.

Proxy 7 is for supplier owned debt data and is listed here for information only.

Note: Proxies 1 and 3 cannot be used together. Proxy 7 cannot be used in combination with proxy 5 or 6.

Route 3: Owner-occupied and privately rented sector households that have been identified by either a person registered in the General Practitioner Register, a Scottish Health Board, a Welsh Health Board, an NHS Foundation Trust, or an NHS Trust as vulnerable, with an occupant whose health conditions may be impacted further by living in a cold home. These health conditions may be cardiovascular, respiratory, immunosuppressed, or limited mobility related.

This is because the council has identified a positive correlation between households who suffer from long-term health conditions and living off a low income, with living in poorly insulated homes.

Route 4: Owner-occupied households and privately rented sector households that are referred under Route 4: Bespoke Targeting. Suppliers and LAs can submit an application to the Department for Energy Security & Net Zero (DESNZ) where they have identified new methods to identify a low income and vulnerable households.

Applications need to demonstrate a number of factors, including that the proposed methodology is more effective at identifying households in fuel poverty than the criterion offered under Routes 1 and 2.

Route 4 is applicable to ECO4 Flex only.

Scheme eligibility

All potentially eligible households should apply through Better Housing, Better Health on 0800 107 0044 or one of their approved ECO and Great British Insulation Scheme installers, if a list of approved installers is available, to see if they can either benefit from the scheme or be assessed for eligibility under any other relevant programme.

Installer enquiries: Any supplier or installer who seeks a council declaration on behalf of an eligible resident will first need to be registered with the 'NEF Supplier Network'. The network ensures that councils have information about the standards, practices and accreditations of installers working in their area reducing the risk of fraud, poor quality installations and exploration of vulnerable residents that the council is looking to assist via ECO Flexible Eligibility.

For further information about the network and guidance on how to register, suppliers should contact suppliernetwork@nef.org.uk

An LA officer (not a 3rd party working on behalf of an LA) will be responsible for checking, and verifying evidence, and issuing declarations.

For any general enquiries relating to this statement of intent contact Esther Harris, fuel poverty and energy efficiency lead on 07776 672 537 or email her at esther.harris@lbhf.gov.uk

CEO or dedicated responsible person mandatory signature

Hammersmith & Fulham Council will administer the ECO4 Flex scheme according to the Electricity and Gas (Energy Company Obligation) Order 2022 (ECO4 Order.

Hammersmith & Fulham Council will administer the Great British Insulation Scheme Flex according to the Electricity and Gas (Energy Company Obligation) Order 2023 (ECO4A Order).

The CEO or dedicated responsible person of the council will oversee the process of identifying eligible households under ECO Flex and Great British Insulation Scheme Flex. The Council will notify Ofgem of households that declarations have been issued for, via the declaration notification template.

All personal data collected or processed by Hammersmith & Fulham Council for the purposes of ECO4 Flex or Great British Insulation Scheme Flex will be processed and stored in accordance with the: