ECO local authority flexible eligibility

Last updated on: 09-Apr-2021

Eligibility for Energy Company Obligation (ECO) - Statement of Intent (SOI)

Introduction to the flexible eligibility scheme

Gravesham Borough Council (GBC) will use the flexible eligibility (FE) part of the Energy Company Obligation (ECO) to reduce fuel poverty in the Borough.

This Statement of Intent (SOI) sets out how households will be declared to be eligible for ECO:  Help to Heat funding. This scheme is part of the government’s Affordable Warmth programme. This is in accordance with guidelines from the Department for Business, Energy and Industrial Strategy (BEIS).

It should be noted that the final decision on whether any individual household will benefit from energy saving improvement rests with the obligated energy suppliers or their contractors.  Inclusion in a Declaration of Eligibility issued by the Council to an ECO provider will not guarantee installation of any works that may help reduce fuel poverty.  The final decision will depend on:

  • the survey carried out by supplier’s agents/contractors and installation costs calculated
  • the energy savings that can be achieved for a property
  • whether the supplier has achieved their targets or require further measures to meet their Energy Company Obligation targets.

In identifying households as eligible under Flexible Eligibility, Gravesham Borough Council is seeking to enable residents to benefit from funding and will obtain consent from households before including them in a Declaration.

Identifying eligible households

Gravesham Borough Council will use a variety of methods to identify households with low income and vulnerable residents that may benefit from the installation of measures under ECO Flexible Eligibility. This scheme is available for those who live in private housing (owner occupiers or renting from a private landlord).

The Council will cross reference data which it holds or can access on Energy Performance Certificates/SAP ratings, heating type, prepayment meters, expenditure on fuel, housing type/age/condition

Low income households living in energy inefficient housing in the private rented sector will be identified through enforcement activity under the Housing Act 2004.

In order to be eligible the resident must meet one of the following criteria:

Living in fuel poverty, but not in receipt of benefits

Households not in receipt of income related benefit with an income of less than £30,000 after paying for rent and mortgage will be identified as ‘low income’.

Low income

The resident is in receipt of any income related benefit listed below:

  • Housing benefit
  • Council tax reduction/support (other than single occupancy)
  • Child tax credit - no income cap
  • Working tax credit - no income cap
  • Universal credit - no income cap
  • Pension credit (savings credit)
  • Carers allowance - for the household in which the person who is being cared for lives
  • Industrial injuries disablement benefits
  • Severe disablement allowance
  • War pensions mobility supplement
  • Armed forces independence payment
  • Constant attendance allowance
  • Living in Layer Super Output area in Gravesham

Vulnerability to the cold

The resident may:

  • Be in receipt of disability living allowance, personal independence payment, incapacity benefit or attendance allowance
  • Be on the Energy Companies' Priority Service register
  • Have a disability blue badge
  • Have an invitation for free flu jab for health reasons
  • A member of the Core group Warm Home Discount recipient
  • Aged over 60, particularly those over 75
  • Young children under 5 and/or pregnant women People with addictions (e.g. substance misusers)
  • People who have attended hospital due to a fall in the last year
  • People diagnosed with dementia
  • Recent immigrants or asylum seekers and refugees (if living in private tenure)

Health condition worsened by the cold

Through this scheme the Council is looking to help/support households containing people with the following characteristics, which reflect the National Institute for Health and Care Excellence (NICE) 2015 guidance on excess winter deaths and illness cause by cold homes containing people with any of the following characteristics:

  • People with cardiovascular conditions (ischaemic heart disease, cerebrovascular disease)
  • People with respiratory conditions (in particular chronic obstructive pulmonary disease (COPD) and childhood asthma)
  • People with mental health conditions (e.g. schizophrenia, bipolar disorder)
  • People with disabilities People who are terminally ill People with suppressed immune systems (e.g. from cancer treatment or HIV, MS)
  • Neurobiological and related diseases (e.g. fibromyalgia, ME)
  • Haemoglobinopathies (sickle cell disease, thalassaemia)
  • People with severe learning difficulties
  • People who move in and out of homelessness

High energy costs

People may be eligible if their property has at least one of the following:
  • 100 millimetres or fewer loft insulation
  • Unfilled cavity walls
  • Uninsulated non cavity walls
  • No working central heating
  • The primary heating source for the home is not mains natural gas
  • The home is a flat above business premises
  • The home is a system built property
  • The household uses a prepayment meter

Where there isn't an Energy Performance Certificate (EPC) the above questions will be asked to assess the likelihood of a household having high energy costs.

Additional information

The criteria will be kept under review, in relation to levels of referrals made, delivery of installed measures and the practices of other authorities.

Being eligible is no guarantee that measures will be installed.  A final decision on whether any individual household can benefit from energy saving improvements under this strand of ECO will be made by the obligated suppliers or their agents/contractors.

As part of the Council’s commitment to the Kent Fuel Poverty Strategy, Gravesham Borough Council residents may be eligible to additional grants or support from time to time.

Any referral or enquiry received that does not meet the above requirements will be considered on a case by case basis.


The Council expects referrals from flexible eligibility to come in three ways:

  • Self-referrals from residents
  • Referrals from other council teams or partner organisations
  • Referrals from ECO providers or installers

Gravesham Borough Council will ensure appropriate referral processes are in place while maintaining the protection of personal data.  This will include initial identification of eligible households using the BRE Housing Stock Assessment for Gravesham.  We will also work with partner agencies to determine those that may be vulnerable due to living in a cold home, suffering from a qualifying medical condition.

Declaration will be passed to contractors through a secure data transfer.  In turn they will be expected to provide information on the outcomes of the referrals.

Delegated authority

Under the Local Government Acts 1972 and 2000 and the Local Authorities (Arrangements for the Discharge of Functions) (England) Regulations 2000, this Delegated Authority is a voluntary function rather than statutory, as the only formal role of local authorities in this area is the production of a Home Energy Conservation Act (HECA) report.  Gravesham Borough Council and Dartford Borough Council shall have adequate governance arrangements in place to deliver this according to the relevant statutory instrument (The Electricity and Gas (Energy Company Obligation) (Amendment) Order 2017), as mentioned in its guidance.

The Delegated Authority will be considered through the Dartford Borough Council SOI until such time that the Council’s decision to move to another option for this delivery is finalised.

Evidence, monitoring and reporting

Gravesham Council will verify that a resident meets the eligibility criteria before processing a declaration.  To evidence eligibility the following information will be documented:

  • Name, address and telephone number/email address
  • Property, heating type and measure required
  • Clarification relating to supporting the criteria

To prevent fraud this information will be collected on the application form which residents sign to declare the information is correct.  External sources will be sought such as EPC data and gas grid maps to verify answers.

Gravesham Borough Council will also work with public health and other health professionals to determine those that may be vulnerable to living in a cold home, suffering from a qualifying medical condition.

Applicants will be asked where they heard about the scheme to monitor which promotional methods, are being effective.

The ECO providers will provide key information, including the number of referrals made and the number of funded installations delivered.

Gravesham Borough Council will record key information including the number of referrals made and the number of funded installations delivered for reporting both to the Department of Business, Energy and Industrial Strategy (BEIS) and future Home Energy Conservation Reports.


This Statement of Intent (SOI) is signed on behalf of Gravesham Borough Council by:

David Hughes, Chief Executive, Gravesham Borough Council.
Telephone: 01474 564422

Also by the Delegated Authority to Dartford Borough Council

Signed on behalf of Dartford Borough Council
Declarations will be assigned to Dartford Borough Council and on behalf of Gravesham Borough Council.  All declarations will be signed by: Sandra Woodfall
Environmental Promotions Officer Telephone:   01322 343056


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