Regulatory invisibility and energy poverty: EPC exclusion, Traveller mobile homes and Ireland’s low-carbon transition

Peer-reviewed paper 1-264-26

Energy Performance Certificate (EPC) systems play a central role in residential decarbonisation by determining how dwellings are assessed, benchmarked and made eligible for retrofit support. However, these systems are largely designed around conventional, permanent, site-built housing and can exclude non-standard dwelling types. This paper examines the exclusion of permanently occupied Traveller mobile homes from Ireland’s EPC framework and considers the implications for energy poverty, retrofit policy and energy justice. Using a critical narrative synthesis, the study integrates academic literature, statutory reports, policy documents and community-based evidence to trace the relationship between Traveller accommodation policy, regulatory classification and contemporary decarbonisation frameworks. The findings show that mobile homes occupied by Traveller households remain structurally invisible within EPC-based energy governance. This exclusion limits access to retrofit grants, reinforces dependence on expensive and carbon-intensive fuels, and prevents these dwellings from being captured in national emissions and retrofit datasets. The paper argues that energy poverty in Traveller mobile homes is not only a consequence of low income or poor dwelling fabric, but also of institutional systems that determine which homes are recognised, measured and supported. Without an equivalent assessment mechanism for mobile and non-standard dwellings, Ireland risks reproducing a two-tier low-carbon transition in which already recognised housing benefits from public investment while marginalised households remain excluded. The paper calls for inclusive certification, dwelling-type disaggregation and culturally informed retrofit policy to ensure that residential decarbonisation is both measurable and just.