Chapter 1: A National Retrofit Programme
The outcome we want to see:
An end to fuel poverty, with lower fuel bills and increased comfort for all households, lower emissions and strong economic growth with Scotland the most attractive place in Great Britain for energy companies to invest in energy efficiency .
Why is this important?
1.1 More than four out of five homes in Scotland today are likely to still be in use in 2050. So in order to tackle fuel poverty and meet our energy and emission reduction targets a primary focus of our strategy must be on improving the energy efficiency of Scotland's existing homes by "retrofitting" our housing stock. The step change in provision of energy efficient homes called for in the Infrastructure and Investment Plan will not happen without action on a national scale. A National Retrofit Programme will help to maximise the measures and funding opportunities available to households across Scotland.
1.2 At the core of our National Retrofit Programme will be area-based schemes focussed on tackling fuel poverty with a leading role for local councils, using Scottish Government funding to bring together a range of funding streams and lever maximum investment by the energy companies into Scotland. We have been working with the Fuel Poverty Forum to develop the principles for such schemes. The Forum believes that area-based action offers the most effective and efficient delivery method. This programme will focus on fuel poor areas first, and work alongside the Warm Homes Fund. Our expectation is that these area-based schemes will cover the whole of Scotland in around 10 years, which is consistent with the rate of progress we have achieved with our current area-based programmes.
1.3 Alongside these area-based initiatives, we want to ensure that over time some kind of help or incentive is available to every house in Scotland with the precise offer depending on household circumstances, income and geography. We want therefore to encourage local councils to work with other partners to go beyond action to tackle fuel poverty, by drawing in investment from Green Deal, European Investment Bank and other sources to encourage householders to take-up energy efficiency measures, in line with their local housing strategies. This will benefit local communities through savings on fuel bills, generate local economic activity and contribute to emission reduction.
1.4 We also need to consider the role for the appropriate use of minimum standards for energy efficiency of existing housing should these incentives fail to deliver the scale of action needed. (The role of standards is considered further in chapter 2.)
1.5 By 'retrofit' we mean refurbishing or re-fitting existing homes to make them more energy efficient, for example by insulating walls, doors or windows to keep heat in. It can also involve installing new technology such as 'smart meters' that monitor energy use, a new boiler or renewable heat or hot water systems. The measures fitted will vary from house to house as they will depend on what is appropriate and cost-effective in each case. Retrofit can also integrate sustainability and energy efficiency with routine repair, maintenance and improvement work. Examples of such an approach would include using environmentally sustainable materials for all work carried out, and making energy efficiency improvements at the same time as a roof repair or while fitting a new kitchen or bathroom. The Sustainable Housing Design Guide  includes advice on sustainable maintenance and refurbishment.
Progress so far
1.6 We are already making good progress on energy efficiency in Scotland, as highlighted in the introduction to this document. Figures from the Carbon Emission Reduction Target ( CERT) scheme show that Scottish households received over 327,400 free or subsidised, professionally-installed, cavity wall or loft insulation measures between April 2008 and September 2011, with more than one in every ten homes receiving support. The Scottish Government funds local councils to deliver a Universal Home Insulation Scheme ( UHIS) offering free insulation to households in their area which has played an important role in driving this uptake.
1.7 Alongside this, our four-stage Energy Assistance Package is designed to tackle fuel poverty as well as emissions and was supported by a budget of £37.7 million in 2011-12. Working together, these schemes have made a real difference to individuals and communities across Scotland as the case study in box 2 shows.
1.8 But there is still considerable potential for further action all across Scotland. For example, there are up to 544,000 homes still needing cavity wall insulation and as many as 611,000 homes with solid walls  . There is a great opportunity for Scottish businesses to act to tackle fuel poverty and reduce emissions. That is why we are proposing that a national retrofit programme should be part of the strategy to improve Scotland's homes.
Ms P, who lives in Dundee, received a letter from her local Save Cash and Reduce Fuel (SCARF) service about the Universal Home Insulation Scheme run by Dundee City Council. She completed the home energy check and sent it back to SCARF. Ms P was referred to Everwarm for insulation. She was also referred to the Energy Saving Scotland Advice Centre (ESSac) as a potential Energy Assistance Package client. The ESSac adviser referred Ms P for a benefit check and also for new heating as the system she had was inefficient.
Ms P later contacted the ESSac to say the advice was a great help and that she now receives Disability Living Allowance. She is also entitled to have central heating installed under Stage 4 of the Energy Assistance Package. Ms P can now look forward to a warmer home that she can afford to heat – all thanks to the Scottish Government's Universal Home Insulation Scheme, Dundee City Council, SCARF, Everwarm and the staff at the ESSac.
Learning from the past
1.9 In devising a new programme it will be important to learn from and build on lessons from past experience. The report Environmentally Sustainable Maintenance and Housing Associations  includes 40 case studies on projects from the late 1990s - early 2000s that attracted additional funding for sustainable innovation and explores why these projects did not lead to mainstreaming of new ideas. The wrong measures in the wrong place, or incorrectly fitted, will fail to achieve the desired result and, of even greater concern, could even be detrimental to the building fabric and occupants' health. For example, inappropriate installation of insulation can exacerbate condensation problems.
1.10 With these kind of issues in mind, the Scottish Government has published a guide to insulating cavity walls correctly  . The Built Environment Sub-Group of the 2020 Climate Group has been working with Architecture and Design Scotland and others to develop a database of case studies and guidance to support development of a retrofit strategy based on house construction type.
1.11 As important as getting the right measures correctly fitted is how people actually live and behave in their homes. Carbon and energy bill savings achieved by a family living and possibly working in an energy efficient home will not necessarily match those modelled in an empty property.
1.12 Heriot-Watt University is developing the Riccarton Eco-village and Living Laboratory ( REALL) facility which will provide a ground breaking research and test facility for the integration of buildings, technologies and behaviours for housing design. The aim is to deliver world-class research on sustainable and low carbon housing that will provide a step-change in future housing development, technology and policy that takes into account how people behave in their homes. A report  by the Scottish Government Building Standards Division has also been prepared providing guidance on how to live in a low carbon house
Our specific objectives for a National Retrofit Programme
1.13 Our action to tackle fuel poverty through the National Retrofit Programme will also drive our commitment to reducing emissions and energy use. The report on proposals and policies (the RPP) sets out the action needed by government, business, individuals and communities to meet the targets in the Climate Change (Scotland) Act (see Box 1). The report includes three 'milestones' for housing to help meet the overall target of a 42 per cent reduction in emissions by 2020 across all sectors. The National Retrofit Programme, and other actions in this strategy, will help to make sure we reach these milestones. Table 1 shows where we are now.
Measures needed by 2020
Progress to 2010
1. Every home to have loft and cavity wall insulation (where cost effective/ technically feasible) and draught proofing measures such as pipe lagging.
Every home to have loft insulation of at least 100 mm by 2020.
Every home to have cavity walls insulated, where appropriate and technically feasible.
Latest figures from the Scottish House Condition Survey show that by the end of 2010 around 82% of lofts had at least 100 mm insulation and 36% had 200 mm or more.
2. Every home heated with gas central heating to have a highly efficient boiler with appropriate controls,
The RPP assumes over 1,000,000 boiler replacements over the period from 2008-2020.
The Energy Saving Trust estimates that more than 128,000 new gas boilers were installed in Scottish homes between April 2010-March 2011 and around 120,000 between April 2011-March 2012  . If this replacement rate continues until 2020 well over a million homes will have highly efficient new boilers.
3. At least 100,000 homes to have adopted some form of individual or community renewable heat technology for space and/or water heating.
The RPP assumes large scale uptake of solar thermal panels; biomass boilers; and heat pumps by 2020.
Around 13,000 homes had some form of renewable heat by the end of 2010 (Scottish House Condition Survey).
1.14 A second RPP will be published at the end of 2012 with proposals to meet a new set of annual targets up to 2027. Members of the Sustainable Housing Strategy Group took part in a seminar to consider the findings of the "Housing Futures" research  by Glasgow Caledonian University to assist in identifying the priorities for the next decade. Building on that seminar, we are developing proposals for RPP2 consistent with this strategy and will set new milestones to be met by 2027.
Main challenges to address
1.15 Schemes such as the Energy Assistance Package and UHIS have been successful in installing many insulation measures and heating systems at a free or discounted cost. However, there are still many homeowners who have not engaged with such schemes. This may be because of the perceived "hassle" of installation, or apathy. But it can also be very difficult for consumers to engage with the complex range of schemes and programmes available when each household has its own individual needs and circumstances and each house is unique in its construction and the kind of measures that are suitable.
1.16 Much of the more straightforward and cost-effective work has been done and the more expensive measures and hard-to-treat properties remain. We will need to establish a compelling incentive structure to support and encourage people to have this work done. We will also have to communicate a potentially complex message about the balance between financial incentives and home-owners' responsibilities. This balance might vary depending on house type, household income and geography.
Q2: What do you think are the main barriers that prevent home owners and landlords from installing energy efficiency measures ?
Q3: Please explain any practical solutions and/or incentives to overcome any barriers you have identified?
1.17 Scotland has a wide range of house types. In line with the rest of the UK, the majority (1,494,000) of homes in Scotland are houses rather than flats (864,000). However, in Scotland a much greater proportion of the stock is flatted properties - 37 per cent compared to only 19 per cent in England - although there are significant differences between Scottish urban and rural housing, as described below.
1.18 Almost three-quarters of Scottish houses are of cavity wall construction and nearly a quarter (24 per cent) have solid walls. The remainder use other types of construction such as non-traditional and system build. The Scottish House Condition Survey estimates that nearly a third (approximately 30 per cent) of Scotland's housing is 'hard to treat'. Most of these are solid walled dwellings.
1.19 Nearly a fifth of Scotland's homes are in rural areas where 46 per cent of homes are off the gas grid. Fuel poverty in rural areas is higher at 38 per cent of households compared to 26 per cent in urban areas  . This reflects the very different nature of rural housing. For example, a third of homes in rural areas were built before 1919 compared to 17 per cent in urban areas. More than nine out of ten rural dwellings are houses, with a high proportion being detached rather than terraced or semi-detached. Solid walls and other types of hard-to-treat wall are much more prevalent in rural than in urban areas.
Traditional buildings should not be seen as inevitably "hard to treat" buildings, although they may need a distinct approach to adaptation. Historic Scotland is carrying out a number of refurbishment pilots to test the effectiveness of different interventions in traditional buildings and to develop cost effective improvements in thermal performance that respect their fabric and the appearance. A variety of dwelling types have been chosen, including small detached rural properties, a village hall and 19th and 20th century tenements in Edinburgh and Glasgow. The buildings are currently being monitored and more information can be found here: http://www.historic-scotland.gov.uk/index/heritage/conservation/conservationresearch.htm
Q4: Given Scotland's diverse range of housing, what support is needed to enable people to get energy efficiency measures installed?
Q5: (a) What specific issues need to be addressed in respect of improving energy efficiency in rural areas, particularly more remote or island areas?
(b) How should these be addressed?
Action to address these challenges
Getting the best deal for Scotland from UK programmes
1.20 Scottish Government schemes to insulate homes have been particularly successful because we have integrated (and actively promoted) Scottish Government, UK and EU programmes to maximise their benefits to our communities. We will build on this success in the National Retrofit Programme.
1.21 We have worked with the UK Government as they have developed proposals for a new Energy Company Obligation ( ECO) and Green Deal, to be in place at the end of 2012 (see box 4). The aim of these new policies is to drive improvements to the energy efficiency of housing and other buildings. The ECO will replace the existing energy company obligations, the Carbon Emission Reduction Target ( CERT) and Community Energy Saving Programme ( CESP). Both the affordable warmth element of ECO (targeted at low-income households in fuel poverty) and the carbon saving element, which will be focused on insulating solid walls, will be particularly important for rural Scotland. We have helped to secure important changes to these proposals compared with the original plans. These have included a stronger focus on fuel poverty in low income areas, support for a wider range of measures such as hard to treat cavities and funding for highly cost-effective loft and cavity wall insulation in specific areas, which will deliver emission savings and assist the installation industry in the transition to the new arrangements.
1.22 We want to make Scotland the most attractive place in Great Britain for energy companies to invest to meet their obligations and to ensure that the benefits extend to all parts of the country, particularly remote rural areas with high levels of fuel poverty. Given that the UK Government estimates ECO investment to be worth around £1.3 billion each year across Great Britain, this opens up the prospect of a combined energy efficiency funding pot, including Scottish Government funding of at least £200m per annum. We are working with the UK Government on the £200m incentive fund allocated by the Treasury for an early adopters scheme for Green Deal uptake. We are working to ensure that we can develop a fund that will be attractive and easy to access for Scotland. This would be in addition to other sources of investment, such as European funding and contributions from householders themselves. This level of spending would be in line with the recommendations of the report on fuel poverty, by the Energy, Enterprise and Tourism Committee, published on 22 February 2012, which recommended a budget of at least £200 million a year to combat fuel poverty from both Government and energy company obligations. 
The Green Deal is a completely new finance mechanism funded by private capital. It will enable households to have energy efficiency improvements installed at no upfront capital cost and to pay for them, over a period of years, through a charge on their energy bill. At the heart of this arrangement is the 'golden rule': that the estimated savings on bills should equal or exceed the cost of the work.
The ECO will work alongside the Green Deal. It will involve three obligations for energy companies, relating to Affordable Warmth, Carbon Saving and an areabased Carbon Saving Communities obligation supporting a range of measures in low income areas. The UK Government hopes to drive the market in solid wall insulation through the carbon saving target while the affordable warmth obligation will be directed towards vulnerable low-income households in the private sector with entitlement to defined benefits.
1.23 With the Fuel Poverty Forum, we have reviewed Scottish Government energy efficiency and fuel poverty schemes to make sure they fit well with these new UK policies and with our plans for a National Retrofit Programme. Our programmes will be supported by £250 million of Scottish Government funding over the three years from 2012-13 to 2014-15. We have also introduced a new Warm Homes Fund to support community renewable and district heating projects in the areas worst affected by fuel poverty, which could particularly benefit communities in rural areas off the gas grid. This fund will amount to £50 million between 2012 and 2016. In addition, we are providing £5m in loans to extend the gas grid to communities within a reasonable distance of the mains gas grid  .
1.24 These are significant levels of funding and will make an important contribution to the low carbon economy in Scotland. While it is not straightforward to quantify the benefits in terms of job creation, the French Ministry for Ecology, Energy, Sustainable Development and Spatial Planning has estimated that 'for every 1 million Euros of investment in property-related thermal renovation, 14.2 jobs are created or maintained in the field of energy performance-related work.'  The National Retrofit Programme will provide opportunities for businesses across Scotland. The skills requirements for this are considered in chapter 5.
Other sources of funding for retrofit
1.25 Through the Energy Saving Trust the Scottish Government also provides a range of funding and advice and assistance for energy efficiency measures, including the Energy Saving Scotland Advice Centres. These include working with private sector landlords to provide information and assistance, support to local authorities on the uptake of CERT and CESP and pilot hard to treat loan schemes. The Scottish Government funded the Energy Saving Trust to carry out a 'water efficiency' pilot which has led to water efficiency becoming part of the package of energy saving advice provided through the 'one stop shop' network of advice centres.
1.26 Social landlords have the opportunity to access European Funds to support work on energy efficiency including the currently available £15 million SPRUCE fund for energy efficiency which is available in 13 local council areas. Restructuring of European funds in 2014 could provide further opportunities for landlords to improve the energy efficiency of properties using specific grant or loan funds.
1.27 Microgeneration and district heating will also have an important role in retrofitting Scotland's homes. Support for this is considered below.
1.28 Homes for Scotland has put forward proposals for a further potential source of additional funding for retrofit (see box 5). Such an approach would need careful consideration to determine whether or not it was desirable and workable, its relationship to other sources of funding for retrofit and the wider context of our emissions reduction targets to 2050. We know that new homes built today will be with us for the foreseeable future, well beyond the lifespan of this strategy, so these are important considerations. The Scottish Government will consider the findings of Homes for Scotland's research when it is published.
Homes for Scotland, the organisation that represents the Scottish building industry, has argued that Scotland already has the highest building standards in Europe and that further improvements in energy efficiency standards for new homes will come at a high cost for the amount of carbon saved. It argues that as an alternative to introducing what it considers would be excessive changes to the Building Standards, the new homes industry is open to the possibility of contributing a cash amount for every home built, creating a fund that could be used to insulate or improve the energy performance of the existing housing stock. Their view is that this approach would be far more effective in achieving overall emission reductions, alleviating fuel poverty and creating employment opportunities. Homes for Scotland has commissioned research to provide evidence of the benefits that might be achieved by such a fund.
Support for microgeneration and district heating
1.29 The main financial incentives for microgeneration are the Feed in Tariff ( FIT), Renewable Heat Incentive ( RHI) and Renewable Heat Premium Payment, which are reserved to the UK Government with the agreement of the Scottish Government. We work closely with the UK Government to ensure Scottish issues in particular are taken in to consideration.
1.30 We want to see the market for microgeneration continue to grow, as set out in our route-map  for microgeneration in the Renewables Routemap published in June 2011. The Route-map set out our intention to publish a Microgeneration Strategy to support the sector move from a niche market to the mainstream. We have been working with a Stakeholder Group to provide input on key actions to ensure Scotland maximises the benefits of UK Government funding mechanisms such as FIT and RHI. The Strategy will be available on the Scottish Government website and takes into account the results of the consultations on the Comprehensive Review of the FIT.
1.31 Microgeneration is integrally linked to energy efficiency as part of our overall policy to move towards a low carbon economy. Microgeneration technologies are most effective in terms of cost effectiveness, and in reducing emissions and energy bills only when combined with energy efficiency measures, such as insulation. Uptake of microgeneration will be strongly linked to our targets to reduce Scottish final energy consumption by 2020.
1.32 District heating is now central to Scottish Government's strategy for deploying heat (both renewable and non renewable) and the newly established Expert Commission on the Delivery of District Heating will work with us, providing recommendations to ensure a major shift to district heating in Scotland. This will include identifying key opportunities and appropriate financial mechanisms. Our District Heating Loan Scheme has been operating since 2011 and is expected to be self financing in the medium term, providing some confidence of finance opportunities for developers of these schemes. In order to achieve the scale of ambition we have for district heating, we have also made provision for funding district heating within the recently announced £103 million Renewable Energy Investment Fund and the £50 million Warm Homes Fund.
Delivery models for the National Retrofit Programme
1.33 The Fuel Poverty Forum has suggested that local councils should play a central role in delivery of the new programme because of their strong interest in tackling fuel poverty and cutting carbon emissions and in the jobs and business opportunities associated with investment in the green economy. We agree with this. Councils have the trust of consumers, a local understanding of housing quality issues and a strategic role in improving housing in their areas. Locally derived and delivered schemes also offer greater potential to deliver wider community benefits, such as the involvement of local companies in their delivery, including supported businesses  . So we propose that they should play a critical part in driving up energy efficiency work across Scotland. While councils already have arrangements in place to deliver UHIS, these will need to cover a wider range of work from April 2013 and take account of the potential of the Green Deal and Energy Company Obligation ( ECO).
1.34 The Fuel Poverty Forum has agreed a set of principles that should guide local councils' activity regardless of the delivery model they choose. These include:
- Scottish Government funding should be used to help maximise the leverage of ECO funding into the country by making Scotland the easiest and most cost-effective part of Britain in which to discharge the obligation.
- Area-based programmes should provide an offer of assistance to all. households within the locality and customers should continue to have a single point of access for all support and advice including on tariffs and income maximisation.
- Procurement of Scottish Government programmes should balance achieving economies of scale and administrative simplicity with the ability to take account of local issues and knowledge.
- Measures in the Scottish Government programmes should also support, wherever possible, commitments to reduce carbon emissions from housing.
1.35 We are also exploring possible new funding options to help support the necessary change in the scale of energy efficiency and renewables activity across Scotland.
These are outlined below.
a) Local councils bid into Scottish Government funding programmes
Essentially 'challenge funding', this would involve a central Scottish Government funding pot into which local councils bid against fixed criteria, including carbon saving and a needs-based assessment. Local authorities would be required to work with energy companies to develop programmes that would draw in additional funding through energy company obligations. Households not eligible for free or discounted measures would be offered Green Deal or other options under a one-stop-shop approach. Interest-free or low-cost loans may also be offered to such households.
b) A Scottish facilitated funding model
This option would expand the Scottish Government funded pot in option (a) by supplementing its funding with that from energy companies in response to their obligations (worth around £120 million a year in Scotland). This might encourage councils to develop more ambitious programmes to compete with the larger-scale programmes we expect to see developed in urban areas elsewhere in Britain. These would be attractive to energy companies in terms of meeting their obligations efficiently. The fund could be managed by a company or the Scottish Government. Local councils would be able to draw down resources from the fund on the basis of an agreed programme, on a "first come, first served" basis. Again, as in option (a), households ineligible for free or discounted measures would be offered Green Deal or other options under a one-stop-shop approach.
c) A formula-based model
Under this option the Scottish Government would allocate funding to local councils on the basis of an agreed formula. The funds would need to be spent in accordance with the principles agreed by the Fuel Poverty Forum, summarised at the beginning of this section. It would be a condition of grant that the maximum additional funding is drawn down from the energy company obligation.
Going beyond fuel poverty - Green Deal delivery mechanisms
1.36 Stepping up the level of energy efficiency work across Scotland will involve councils in developing delivery models that go beyond fuel poverty work to take advantage of the opportunities associated with the Green Deal and ECO and secure economic benefits for people in their area. To help with this, the Scottish Futures Trust  looked at emerging Green Deal delivery models. Their work has highlighted five main options:
- Limited promotion - where the local council's role is limited to promoting energy efficiency works, for example through a portal of local, accredited Green Deal suppliers. This model will benefit the local area by limited increases in activity, but potential risks are that there will be the opportunity cost of lost investment in comparison to authorities who take a more proactive approach to the Green Deal. This will impact on opportunities for jobs, fuel poverty, housing quality and carbon reductions.
- Green Deal Community Interest Company - where a consortium of local councils form a dedicated social enterprise in the form of a Community Interest Company ( CIC) to provide a regional green deal offer. The CIC would promote the Green Deal to suppliers and also market it to local residents. This model can be flexible in the range of activities it could engage in. There are, however, a range of risks depending on the activities it undertakes, including initial set up costs and reputational risk. But benefits include facilitating local delivery and promotion and supporting the local supply chain through dissemination of information.
- Framework of Green Deal providers - where the local council or a group of councils take an active approach in promoting demand and identifying packages of work and procuring a framework of accredited Green Deal providers. Packages of work using its own assets or on an area basis can then be priced through mini competition with the Green Deal providers. The key cost in this approach is establishing the frameworks, with reputational risk if works are carried out to a poor standard and potentially mis-selling risk if councils are managing demand. However, benefits include the ability of frameworks to cover a number of organisations so RSLs, other councils or community bodies could be covered
- Green Deal partnership - where the council (or a group of councils) procures a Green Deal delivery partner who will work exclusively to deliver the Green Deal, with the council providing strategic direction and monitoring agreed outcomes. In this model councils need to consider how the Green Deal package will be funded. Early models have considered using their own resources or PWLB  funding. More recently an alternative approach being considered is to use the Green Deal Finance Company. This model is similar to the approaches being considered by Newcastle City Council and Birmingham City Council. The key cost in this model is in the set up costs. Key risks include the scale of works required to justify the set-up costs, implementation takes around 12-18 months and governance arrangements need to be established as it will involve several councils working together to reach the required scale of activity. However, benefits include giving the council more scope to manage and promote demand and bringing in private sector expertise to assist in the process. It can cover a wide range of bodies such as RSLs, other local authorities and community bodies and provide targeted activity to key groups such as the fuel poor and develop schemes for local apprentices.
- Green Deal provider - where the local council itself becomes an accredited Green Deal provider. There are significant costs in this approach including staff training, accreditation, sales costs and costs in undertaking Green Deal works. This will in turn maximise operational risks faced by the council around mis-selling, Green Deal Finance organisation, warranties for work and competition in the Green Deal market. This approach provides benefits of being in control of any reputational risk, creating a work stream for its DSO and creating apprentices and providing scale in a local area.
1.37 There are also a number of sources of finance available to support the Green Deal more widely. These include the Public Works Loan Board, the Green Deal Finance Company and bank lending, all of which may be used to help support an expansion in energy efficiency work. We are also talking to energy companies to understand their expectations and requirements for the effective operation of ECO and Green Deal and the basis on which they might deliver these across Scotland.
Q6: Taking into account the models and funding sources outlined in sections 1.20- 1.37, what role might local authorities and other agencies play in bringing about a step change in retrofitting Scotland's housing?
Q7: What role should the Scottish Government play in a National Retrofit programme?
Q8: What role could the devolution of additional powers play in achieving more retrofit?
Q9: What further action is needed to achieve the scale of change required to existing homes?
Q10: How can we make sure a National Retrofit Programme maximises benefits to all consumers (for example, older people, those from ethnic minorities, those with long term illness or disability)?