Following the end of their Welsh Housing Quality Standard (WHQS) consultation at the start of August, Welsh Government are considering feedback on their ambitious proposals to eliminate fuel poverty and decarbonise social homes in Wales.

I’d be amazed if any of the seventy-plus responses disagreed with their intent. It would be hard for anyone to argue that these goals are important, hence responses will be about how to best achieve them.

What’s required are insights based on good science and real delivery that envisage how to deliver their bold ambition – for the proposed standard currently falls short in this regard. Welsh Government’s plan makes their ambitions challenging and expensive, but unless the proposals change, sadly an inevitable failure.

Why? Because a significant minority of homes in 2033 will still be left in fuel poverty as a consequence of them falling outside the “bell curve” distribution assumptions in the complex, desk-modelled system used for assessing this risk. The same model will forecast a typical home’s carbon emissions at around a single tonne/CO₂^eq per year. Which is not the “net zero” intended in Welsh Government’s plans.

In any field, success should be measured, not modelled. To succeed, the measurements used must be perfectly aligned to the objectives sought. To eliminate fuel poverty, success must be in pounds and pence. For carbon, CO₂^eq per year.

Measuring both for each individual home can be done through the smart meters already being rolled out throughout social homes. These are soon to be more widespread than social homes with EPCs, and likely to have near-complete coverage in the next few years.

To eliminate fuel poverty, Welsh Government should set a price limit on tenants’ heating and hot water bills – no doubt index linked. For carbon, set 0kgCO₂^eq per year. And, importantly, these limits should be evidenced by measurements for every home, not modelled average forecasts.

Here, though, is where Welsh Government needs to step back and let the landlords’ come forward with their own expertise. Remove the interim targets, prescriptions and micro-management, and let the landlords plan their own route that best fits with the challenges they face in their own portfolio.

Whilst it’s reasonable to require the landlords to regularly share their plans and progress towards these objectives, give them the freedom to succeed within those headlines. Innovation to tackle the inevitable grant-funding gap, hard-to-treat homes and resident engagement can emerge, and of course lessons should be shared – whether they be good and especially if they are less good.

This approach can be put into clear focus with the ongoing energy crisis concerns that consume many landlords and tenants currently. A clear cap on tenants’ heating and hot water costs would empower landlords to act in far broader ways: interventions from bill switching or subsidies, through boiler flow temperature adjustments on condensing boilers or demand-shifting storage for cheaper tariffs, and on to energy system efficiencies and building fabric improvements.

With success actually measured in the heating and hot water bill of each and every family, the focus stays on what eliminating fuel poverty is really about.