Heat and energy efficiency strategies: consultation analysis

Analysis of responses to the consultation on heat and energy efficiency strategies and regulation of district heating.

2. Local Heat & Energy Efficiency Strategies to Support Delivery of Energy Efficiency and Heat Objectives of SEEP

2.1. Duty to Produce and Implement a Local Heat and Energy Efficiency Strategy

2.1.1. Section A of the consultation document discusses placing a statutory duty upon local authorities to work with relevant stakeholders to develop Local Heat & Energy Efficiency Strategies ( LHEES) and to use their powers to implement these strategies in order to support delivery of the objectives of Scotland's Energy Efficiency Programme ( SEEP). The consultation sets out the proposed scope and content and explains that local authorities would be supported in developing LHEES with the provision of national guidance and data sets, such as the Scotland Heat Map.

Section A: Q1. Do you agree that local authorities should have a duty to produce and implement a Local Heat & Energy Efficiency Strategy ( LHEES) as outlined above? Please explain your view.

2.1.2. As shown in the following table, most of those who answered this question did agree with this proposal (64). Six disagreed while five did not specify their agreement or disagreement but made other comments.

Section A: Question 1

Yes No Other comment No reply
Business & Industry (24) 17 1 1 5
Network, Professional or Trade body (18) 12 2 1 3
Local government (17) 13 1 3 -
Third sector & Community (9) 8 - - 1
Public sector (7) 4 - 1 2
Academic (4) 3 1 - -
Other organisation (1) 1 - - -
Individuals (7) 6 1 - -
Total (87) 64 6 6 11

2.1.3. All of those who gave an answer to the tick box question provided additional comments in support of their view. These views are summarised in the following paragraphs.

Comments from those who agreed

2.1.4. The 64 respondents who agreed that local authorities should have a duty to produce and implement a Local Heat & Energy Efficiency Strategy ( LHEES) all provided supporting comments. Almost all of the respondents who ticked 'yes', however, qualified their support.

2.1.5. Many, from across respondent groups, commented that such a duty is required in order to: promote decarbonisation of heating; reduce energy use or energy waste; or to meet targets relating to climate change, affordable warmth, reducing fuel poverty or energy security.

2.1.6. A small number commented that leadership from local authorities will be vital in taking the strategy forward, or to raise the profile of heat and energy efficiency in each area. Some respondents also commented that it would not be possible to deliver such a strategy consistently across the country without such a duty. One respondent, from the business & industry group, commenting on the situation in Denmark, said that the approach should be mandatory in order to comply with EU directives on Renewable Energy and Energy Efficiency.

2.1.7. There were, however, a number of suggestions and concerns over how such a duty could be implemented:

2.1.8. The main concern, noted in 26 responses from those who agreed, as well as in a further seven responses from those who disagreed or did not specify , was over funding, support and resources for the implementation of such a duty. These comments were seen mainly in responses from the local government, business & industry and the network, professional or trade body groups.

2.1.9. The following, from a respondent in the business & industry group, is typical of the comments on this issue:

"It is critical that local authorities are appropriately resourced to produce and implement a LHEES. Further consideration will therefore need to be given to the resource and support requirements that will be required and how these can be delivered".

2.1.10. Within the comments on the need for support for local authorities were several concerns that local authorities may not have the capacity, skills or relevant expertise needed to produce and/or implement the LHEES. A small number commented that resources were made available when other, similar, strategies were implemented, for example the local housing strategy. Others mentioned that when Glasgow City Council developed their Energy and Carbon Masterplan they received EU funding and were supported by university and business partners.

2.1.11. There were also calls for local authorities to be allowed, or encouraged, to share best practice, share solutions or share resources in order to make use of economies of scale.

2.1.12. Several respondents commented that while local delivery, reflecting local conditions, will be key to successful implementation; this must be supported by a clear national framework, guidelines and support. There were comments that a cohesive, consistent approach was seen as necessary both to attract investment and to provide reassurance to consumers. Some also mentioned the need for oversight at a national level or queried how the duty would be enforced, including queries over penalties for non-compliance.

2.1.13. There were also comments on the need for 'joined up' thinking or strategies with suggestions that these should encompass fuel poverty, climate change, local air pollution, energy efficiency and decarbonisation, with targets set at a national level where these do not already exist.

2.1.14. Respondents included a wide range of suggestions for the type of support that would be required, in addition to financial support as mentioned above. These included:

  • Access to relevant data.
  • Access to expertise.
  • More information or detail on producing the LHEES or on implementation.
  • Standard evaluation tools.
  • Guidance to ensure a LHEES is not biased towards any specific technology or fuel.

2.1.15. Several respondents also stressed the need for flexibility in order to allow for local solutions relevant to local characteristics, particularly in relation to: low-density or rural areas, installing district heating schemes in existing roads, the availability of suitable waste heat, existing fuel sources and customer choice. One local government respondent, for example, felt that these issues had not been considered within the consultation document which, they felt "seeks to apply a one size fits all approach to regulation". Other respondents mentioned the need for the LHEES to fit with local plans while also fitting with national plans, including Scottish Planning Policy and the Scottish Energy Strategy, and asked for more detail on the support that would be available to manage these alignments.

2.1.16. A small number commented on review periods. This included one, from the business & industry group, who said there needs to be a mechanism for updating the LHEES to take account of evolving renewable energy opportunities. Another, from the network, professional and trade body group, agreed with the need for the LHEES to be set for a long term period and to be updated regularly; they suggested every five years, saying this should also include 5 year measurement milestones.

2.1.17. Other factors that respondents felt needed to be addressed included how to allow for the LHEES to fit within existing local plans and any schemes already in existence. The need to involve other public bodies, Community Planning Partnerships ( CPPs), community councils, the home building industry and other stakeholders was stressed and, allied to this, were requests for advice on how best to engage or involve other relevant stakeholders such as public bodies, developers, suppliers and customers; as many of these will already be involved to some extent in the delivery of other relevant local plans while others may need to be brought on-board. A small number asked whether local authorities would be given sufficient power to require companies to provide the data required or to implement the strategy. There was also a query as to whether duties could be placed on other sectors involved in the LHEES.

2.1.18. Other queries included:

  • Whether the duty would relate to producing the LHEES or to its implementation?
  • Who will be responsible for enforcement and what form will this take?

2.1.19. At the two consultation events there was also broad agreement with this duty and similar comments were made, and issues raised, to those seen in the consultation responses:

  • This duty would help to take the work forward.
  • The duty would help to raise the profile of local heat and energy efficiency.
  • The need for more information on implementation.
  • Comments on the resources and support that will be needed to produce and implement the LHEES.
  • The potential for regional or joint LHEES.
  • Engagement with a wide range of stakeholders.
  • The need for alignment with local plans and existing regulations.

Comments from those who disagreed

2.1.20. Of the six who disagreed, two qualified their response; one said they would have chosen a 'yes, but' option due to resource restrictions within local authorities; this individual group respondent suggested that the duty should be placed on Community Planning Partnerships.

2.1.21. The other, from the academic group, said they did not disagree entirely but that there would need to be national co-ordination and regulation. This was echoed by a business & industry respondent and one from the network, professional and trade group who wanted to see a single national approach or strategy in place before local authorities make decisions about their own areas.

2.1.22. The business & industry respondent was also concerned that district heating may not be the most appropriate solution for every area and also said that the impact on consumers, along with consumer preference, need to be taken into account. A local government respondent also disagreed because they did not feel that district heating will be suitable for all areas and that placing a duty would, therefore, lead to a burden on resources where little opportunity for district heating exists.

2.1.23. A network, professional and trade respondent did not agree with local authorities setting district heating zones as, they felt, this would lead to uncertainty for the property industry.

Other comments

2.1.24. The six respondents who did not specify their agreement or otherwise all included comments similar to those seen above, mainly: concern over funding, capacity or resources.

Section A: Q1b. What are your views on the appropriate geographical scale for the preparation of LHEES? Should each local authority produce a single strategy for its area, or would it be possible for local authorities to work together to prepare strategies jointly for a wider area?

2.1.25. A majority of the 64 respondents who replied to this question said that this should depend on local circumstances (40). The following, from a local government respondent, is a typical example: "The scale should be at least at a LA level although there may be circumstances where it is more appropriate to undertake it at a regional level or across a number of local authorities, particularly where there is opportunity for shared resources, joint procurement and collaborative working".

2.1.26. Around half of these respondents, from across respondent groups, wanted to see the decision on producing a strategy based on local circumstances or needs; several commented it should be up to each local authority to decide. A similar number, including many of the local government group, felt that local authorities should produce their own strategy but then be allowed, or required, to work with others to produce or deliver strategies appropriate for a wider area.

2.1.27. Both groups gave similar reasons and identified similar potential benefits and these included:

  • The need to avoid any limitations caused by an artificial administrative barrier; the need to fully assess appropriate geographic scale and allow plans to be based on local authority area, Local Development Plan area or any other relevant scale.
  • Differences in size, and therefore available skills, expertise and resources, between different local authorities.
  • The need for economies of scale or to avoid duplicating costs for similar work in neighbouring areas.
  • That it is logical for LAs to work together to develop technological solutions relevant to their areas where appropriate.
  • The need for cross boundary working where, for example, major heat loads cross LA boundaries.

2.1.28. There were also some comments on the need to allow for sub-local authority strategies, for example to ensure that the needs of urban and rural locations are considered.

2.1.29. A small number of respondents highlighted proposals in the recent planning consultation to create regional partnership working groups and suggested this could be used as a potential model for delivery of the LHEES.

2.1.30. There were also calls for a Scottish-wide strategy, guidance or template to ensure consistency and in order to avoid any 'postcode lottery' or differences across areas that might deter developers or consumers. A small number suggested that there should be a central support unit to provide support, guidance and training and to facilitate sharing or joint working.

2.1.31. A public sector respondent felt that there should be a community-led approach involving all relevant stakeholders and energy providers in each area.

2.1.32. Additional comments from those who felt that local authorities should produce their own strategy before working with others included:

  • That the strategy should be at local authority level in the first instance as each local authority understands their area and its needs.
  • That the strategy could be at local authority level, with an overarching strategy, rather than full LHEES, across boundaries if appropriate.
  • That a funded regional body or bodies could help co-ordinate cross boundary working.
  • That a duty to co-produce a strategy could lead to difficulties or conflicts or become overly complicated.

2.1.33. A third sector respondent commented that in England there is legislation that enables councils to collaborate and take collective decisions; some of these combined authorities are involved in district heating projects. In Scotland, the Tay Cities Deal was cited as an example of current, successful cross-boundary working; another example was that of Edinburgh and Midlothian working together on a new energy from waste facility.

2.1.34. Smaller numbers, across respondent groups, supported production of a single strategy or supported a requirement for joint working.

2.1.35. Those who simply supported a single strategy felt that local authority level was best to ensure local needs can be identified and met without any complexity that might arise from preparing a strategy for multiple authorities across a wider area. It would also allow for more targeted, local delivery to meet the needs of smaller local areas. Many of these respondents, however, did say that local authorities should consult with their neighbours. Several of these respondents also commented that the strategy would still need to link to, or reflect, regional and national plans, with a small number of suggestions that plans could be produced at local level but delivered at a regional level.

2.1.36. Those who supported an initial requirement for joint working did so as areas relevant to heat networks will not necessarily follow local authority boundaries. A third sector respondent gave an example of where some parts of a housing estate had been excluded from one energy programme that covered the rest of the estate, because of their postcode. Respondents also felt that joint working would lead to more consistent, efficient and cost effective strategies. Sharing skills, expertise and resources were also key reasons for supporting joint working.

2.2. Scope and Content of LHEES

Section A: Q2. Do you agree with the proposed scope and content for LHEES? In particular, do you agree LHEES should (a) set targets for energy efficiency and decarbonisation and (b) include a costed, phased delivery programme that will meet local targets? Please explain your views.

2.2.1. Comments on this question came from 71 respondents, across respondent groups. Some answered all parts of the question separately while others gave a more general comment on the proposed scope and content.

2.2.2. The first part of the question 'Do you agree with the proposed scope and content for LHEES?' was addressed by 25 respondents, across respondent groups, and 21 of these respondents said that they do agree while three others said that further information or detail is required. The other, from the third sector, wanted to see the scope widened to include all aspects of energy use.

2.2.3 In relation to setting targets for energy efficiency and decarbonisation, most of the 59 who commented said that they agreed with the need for LHEES to set targets (47). Attendees at the consultation events said that setting targets is essential and that these targets should be accompanied by a timeline, including a review of LHEES goals.

2.2.4. Amongst those who agreed there were also comments that these targets will need to be in line with national targets and priorities.

2.2.5. Several local government respondents commented on the need for any targets to be achievable.

2.2.6. Other comments included the need for baselines of carbon emissions or the need for other data to support target setting.

2.2.7. Several respondents mentioned the need to ensure targets relating to fuel poverty or socio-economic targets are also highlighted, as well as the need for a consistent approach to socio-economic assessment; this point was also made at the consultation events.

2.2.8. There were some queries in relation to:

  • Whether all buildings would be included as some may be unable to meet targets because of the building's use.
  • Whether both new and old buildings would be included.
  • The cost of implementation.
  • That the long-term nature of such a strategy should be taken into account.

2.2.9. One local government respondent felt that targets should be set nationally rather than by local authorities. There was also a comment from a third sector respondent that local authorities do not have control over the policy levers needed to deliver targets. Two third sector respondents commented on the need for a national body to oversee targets; both for LHEES targets and overall SEEP targets.

2.2.10. In relation to the last part of the question, most of the 47 who commented did agree that LHEES should include a costed, phased delivery programme that will meet local targets (28). A third sector respondent said:

"It is vitally important that a key feature of the LHEES is a costed and phased delivery programme, setting out what steps will be taken, by who and by when. This is key to ensure the strategy is turned into action".

2.2.11. Respondents, from business and industry and the network, professional and trade groups, said each strategy would also have to include details of how each intervention would be funded.

2.2.12. One local government respondent did not agree saying: "The annual 'bidding' process for HEEPS/ SEEPs funding makes the production of a costed, phased delivery programme extremely difficult even over a short timescale as there is no certainty of funding".

2.2.13. 16 respondents said they were not sure. These respondents, along with the small number who gave more general comments rather than agreeing or disagreeing, raised a number of queries. These included the availability of funding, resources, support, skills and knowledge. Issues around future industry or policy changes were raised, as was concern around engaging the wide range of stakeholders that would be involved.

2.2.14. Consultation event attendees felt a costed and phased delivery programme was essential.

Section A: Q3. Please provide any evidence you have regarding the data available (or that could be available) to local authorities that would be useful or key to preparing and implementing such plans beyond the Scotland Heat Map and the EPC Register (including data held both within and outwith the public sector).

2.2.15. Most of the 45 respondents who replied to this question gave their view on what data will be required rather than what is, or might be, available. Responses came from across respondent groups, although few from the 'network, professional or trade body' group commented.

2.2.16. The main sources mentioned as potentially useful were Department of Business, Energy and Industrial Strategy ( BEIS) data on electricity and gas consumption, data from network operators or suppliers (perhaps making use of SMART meter data) and the Heat Map database.

2.2.17. Many others were mentioned by only one or two respondents and these included some general types of data as well as more specific named sources, such as:

  • Land registers, urban planning maps and maps of existing network infrastructure.
  • Council Tax/Business Rate data.
  • Landlord Registration data.
  • Home Analytics data on housing stock.
  • Building data (fabric, energy rating etc).
  • Emissions data.
  • Weather data.
  • Demographic data and demographic projection.
  • Scottish Index of Multiple Deprivation and fuel poverty data.
  • Scottish Household Survey data.
  • Data on energy consumption in public buildings.
  • Gas utility maps.
  • Consumption data from smart meters.
  • Health and Social Care data.
  • Data held by local authorities such as heat demand, population, topography, infrastructure and building use.
  • Information from public bodies, for example air quality, NHS energy use.
  • Data from trade and academic sources.
  • The Energy Saving Trust's Home Energy Efficiency Database ( HEED): domestic energy efficiency data, and HEED+.

2.2.18. There were comments on the need for more robust data in order to ensure that the Heat Map is accurate and on the need for 'real time' data. The voluntary nature of data provided was seen as potentially limiting its accuracy. One respondent from business & industry asked why energy bill data is not fed into the Heat Map. Another suggested that information on fuel used for heating and hot water from EPC reports should be included.

2.2.19. Respondents also identified gaps in data and these included data collection from district heating schemes, although there was a caution that any requirement to provide such data should not place any unnecessary burden on local authorities or others.

2.2.20. A respondent from business & industry wanted to see "a consistent cost database that is maintained and updated that energy planners can use".

2.2.21. Another, from the same group, felt that information on the amount of excess heat emitted by industrial producers would be useful.

2.2.22. A respondent from the academic group said that LHEES will provide information that can be used to "provide much clearer understanding of the potential for different technologies according to different assumptions".

Summary: Section A

Most of those who replied agreed that local authorities should have a duty to produce and implement a Local Heat & Energy Efficiency Strategy ( LHEES), although most had some queries, concerns or suggestions.

Key themes included that this will be vital in taking the strategy forward, or to raise the profile of heat and energy efficiency in each area.

The themes of reducing energy use and heat waste, promoting decarbonisation of heat, and meeting targets on climate change, fuel poverty, energy security and affordable warmth were ones that respondents, from all of the different sub groups, returned to in this and in subsequent sections.

A key concern, and again this was seen across respondent types and in response to many of the questions, was that of the availability of funding, support or other resources to enable local authorities, and others involved, to produce or implement the LHEES.

In relation to separate strategies for each local authority, or joint strategies across areas, respondents felt this should be dictated by local circumstances. This need to allow flexibility for local requirements and conditions was another theme that appeared at a number of different questions and across respondent groups.

Many respondents who commented on the proposed scope and content for LHEES agreed that LHEES should set targets for energy efficiency and decarbonisation and include a costed, phased delivery programme that will meet local targets.

Targets were seen as essential in moving work forward and there were comments that these targets should be accompanied by a timeline, including a review of LHEES goals.

There were a variety of suggestions in relation to the data available (or that could be available) to local authorities that would be useful or key to preparing and implementing such plans, beyond the Scotland Heat Map and the EPC Register.

The main sources mentioned as potentially useful were BEIS data on electricity and gas consumption, data from network operators or suppliers (perhaps making use of SMART meter data) and the Heat Map database.

There were comments on the need for more robust data in order to ensure that the Heat Map is accurate and on the need for 'real time' data. The voluntary nature of data provided was seen as potentially limiting its accuracy.


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