Cold Homes, Fuel Poverty and FHDC Independent Living: Why Older Residents Are Still Being Left in the Cold

In the bleak mid-winter; Frosty wind made moan; Earth stood hard as iron, Water like a stone;

 Christina Rossetti

Cold is not just uncomfortable; for older people it can be deadly. National campaigners estimate that 4,950 excess winter deaths in the UK in winter 2022/23 were caused by people living in cold homes. That is the human context for what might otherwise look like dry paperwork about Energy Performance Certificates (EPCs) and a council spreadsheet.

And the stakes are rising locally. Kent’s own population projections show the 65+ population increasing by 40.6%, from 326,000 to 458,600 over the projection period cited. In plain English: there will be many more pensioners in Kent, and more of them will be living with the health risks that cold housing amplifies.

So it is a fair, urgent question to ask: are the homes linked to Folkestone & Hythe District Council’s accommodation for older residents and vulnerable people as energy-efficient as they should be?

The law: EPCs are not optional paperwork

EPCs are governed by the Energy Performance of Buildings (England and Wales) Regulations 2012. They exist for a simple reason: when a building is sold or let, the energy efficiency should be transparent, and people should be given information and recommended improvements.

Enforcement matters too. Government guidance says it is the duty of the local weights and measures authority (in practice, Trading Standards) to enforce EPC requirements in its area, and it also says enforcement bodies must record enforcement action and report it annually.[4] Crucially, the same guidance recognises an awkward reality: if an authority would be enforcing “against itself” (or its parent authority), enforcement duties must be transferred to another authority.

In Kent, that puts the spotlight on Kent County Council (KCC) Trading Standards, which has its own published enforcement policy describing how it uses tools such as penalty notices where appropriate.[5]

What the EPC spreadsheet shows

A review of EPC records for Folkestone & Hythe District Council’s council-owned Independent Living properties—occupied predominantly by residents aged 55 and over—checking whether a valid EPC exists, whether the rating falls below Band C, and whether any certificates have expired, shows the following:

There are 541 properties on the EPC register for these properties Of these, 101 are recorded as below EPC band C (about 19%), and 15 have expired EPCs (about 3%).

If we narrow it to the Folkestone/Hythe area postcodes starting CT19–CT21, there are 412 properties, with 60 below C (around 15%) and 13 expired EPCs (around 3%).

One postcode stands out for the wrong reasons: CT19 6QP shows 30 properties, 11 below C, and 7 expired EPCs. An expired EPC is not proof a property has been unlawfully let — but it is a red flag, because EPCs are time-limited and the whole point is to provide current information when homes are marketed and let.

Fuel poverty in Folkestone & Hythe is not theoretical

KCC’s fuel poverty bulletin (using the “Low Income Low Energy Efficiency” definition) treats a household as fuel poor if it lives in a home rated D–G and would fall below the poverty line after housing costs and energy needs.

On that measure, Folkestone & Hythe stands at 12.8% fuel poverty, equivalent to 6,513 households. The most acute ward-level rates are in Folkestone Harbour (16.9%), East Folkestone (16.8%) and Folkestone Central (16.0%). Across Kent’s 12 districts, Folkestone & Hythe ranks as the third worst for fuel poverty.

And older households are plainly exposed: the same bulletin shows fuel-poverty rates of 12.0% for “one person aged 60 or over” and 10% for “couple, no dependent children, aged 60 or over”. That is the demographic most likely to be living in the kinds of council-linked supported and older-person accommodation listed by directories such as HousingCare.

What the council says it is doing — and what still doesn’t add up

To be clear, Folkestone & Hythe District Council does point to retrofit action. Its own “Retrofitting homes” page says more than 120 council-owned homes have recently been upgraded, and that it has £2.6m of government funding, matched by council investment, targeting another 300 homes with measures including insulation, double glazing, heat pumps and solar PV — with a stated goal of achieving at least EPC band C for all social homes.

Its Housing Asset Management Strategy also recognises fuel poverty and refers to a drive towards minimum EPC C by 2030, while noting there are still substantial numbers of homes below that level.

So the question is not whether anything is happening; it is whether the effort is reaching the right homes fast enough, especially where older and vulnerable residents are concentrated — and whether basic EPC compliance and transparency are being treated as non-negotiable.

Two questions that now need answering in public

First: Have any of the properties in the spreadsheet been let (or marketed for letting) while recorded as having expired EPCs, or without an EPC made available as required? The EPC register alone cannot answer this. Only the council can, by publishing (or at least disclosing to councillors and auditors) a simple schedule: property identifier, last letting date, EPC rating and date, and planned retrofit works.

Second: What has KCC Trading Standards actually done on EPC enforcement — including in relation to public bodies? Government guidance anticipates conflicts where an authority might be enforcing against itself and requires transfer arrangements. Yet, in public-facing searches, it is difficult to find clear, routine reporting of EPC enforcement outcomes against public-sector landlords in Kent (or confirmation that there have been none). If enforcement is happening, Kent residents should be able to see: how many investigations, how many penalty notices, and how conflicts are handled.

Because when we are talking about older residents, fuel poverty, and cold homes, this is not a box-ticking exercise. It is about preventable harm — and, sometimes, preventable deaths.

The Shepway Vox Team

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