Fuel Poverty Strategy for Scotland: consultation analysis
Analysis of written responses to the public consultation exercise on a draft Fuel Poverty Strategy for Scotland.
This summary presents headline findings from the analysis of responses to the Scottish Government’s consultation on a Fuel Poverty Strategy for Scotland. The consultation closed on 1 February 2018 and 91 responses were received with 80 groups or organisations and 11 individual members of the public responding.
Review of the Fuel Poverty Definition (Questions 1-2)
The Scottish Government proposes that the Warm Homes Bill will include a new definition of fuel poverty including an income threshold based on 90% of the UK Minimum Income Standard ( MIS) (after subtracting housing, fuel and childcare costs) and that the 10% fuel cost to income ratio will be based on an After Housing Cost ( AHC) basis. Question 1 sought respondent’s views on the proposed new definition of fuel poverty.
The new definition of fuel poverty was broadly welcomed by many respondents, while others expressed support for the attempt to improve the definition of fuel poverty. Positive points raised regarding the new definition were most frequently that it will: better target support to the most in need; prevent relatively wealthy households with high energy costs from being considered to be in fuel poverty; and improve understanding of the number and distribution of households in fuel poverty.
However, many responses were caveated, particularly expressing concern that the Scottish Government does not propose to follow the Definition Review Panel’s recommendations to adjust the UK MIS threshold upward for households living in remote rural areas. There were concerns that the proposed definition is more complex than the previous version and that this may make identifying or assessing fuel poor households more of a challenge.
There was broad support for use of AHC income including as a more accurate measure of the income available to spend on fuel. However, respondents often requested greater clarity on which housing costs are included or excluded.
Adoption of the MIS was also supported in principle by many respondents.
Remote rural or island communities : A large number of respondents expressed concerns that the Scottish Government does not propose to follow the Definition Review Panel’s recommendations to adjust the UK MIS threshold upward for households living in remote rural areas. Several respondents provided examples to illustrate a concern that the proposed definition will seriously under-represent the extent of fuel poverty in remote rural or island areas and lead to resources or investment being diverted away from the areas where fuel poverty is highest.
Households where at least one member of the household is long-term sick or disabled: Respondents who commented on this issue all suggested that MIS thresholds should be adjusted where at least one member of the household is long-term sick or disabled.
Question 2 asked for views on the proposal to use 75 years of age as a threshold for identifying those who are likely to be vulnerable to the adverse health outcomes of fuel poverty.
Opinions were often nuanced, with some respondents both seeing merit in the proposals and expressing reservations. Overall, the majority of respondents tended to express concerns. The most frequently raised issues included that, as advised by the Definition Review Panel, there should be further work ‘to develop a specific list of health and disability categories, as well as age bands, to satisfactorily encompass the term “vulnerable to the adverse health and wellbeing impacts of living in fuel poverty”. It was observed that life expectancy is below 75 in many of Scotland’s most disadvantaged communities, that the reasons for choice of 75 are not clear, and that State Pension Age might be a more appropriate threshold.
It was also suggested that the proposed change could have a disproportionate effect in rural and island areas where a higher proportion of the population is elderly and so would be more likely to be excluded on grounds of age alone.
Recognising the distinctiveness of all our communities (Question 3-4)
Question 3 and 4 asked if respondents have identified additional challenges or opportunities in relation to island communities or remote rural communities.
In broader comments, it was suggested that the Scottish Government should recognise and respond to established higher living costs in these areas and follow the Definition Review Panel’s recommendation to upgrade the UK MIS threshold.
Respondents identified a range of challenges associated with island communities which they thought the Scottish Government should consider when developing the Strategy. It was noted that the remoteness of island communities can lead to high costs, including in relation to travel and transport. Also associated with remoteness were lack of mains gas and hence higher energy prices. The weather and climate, older population profile, low incomes, age and condition of much of the housing stock, and shortage of accredited installers for energy efficiency measures, were also highlighted.
In terms of opportunities, general comments included that there should be flexibility for communities to develop solutions, with Local Authorities and third sector partners often suggested to be best placed to tailor resources to local circumstances.
Specific opportunities identified included the development of renewable energy generation projects and resolving grid constraints to provide additional carrying capacity for energy from renewable sources. It was also suggested that new local electricity supply and storage projects, and the potential of district heating schemes, should be explored. Finally, there were suggestions around developing local supply chains and addressing skills shortages and creating employment by investing in apprenticeships or training.
Respondents tended to refer back to their comments on islands in response to the question on rural and remote rural communities or suggested that the issues on islands and remote rural areas are essentially the same. Of those who commented at this question, points specific to challenges and opportunities for rural and remote rural communities on the mainland raised were that the concept of ‘island proofing’ should also be applied to remote and rural areas.
Partnership working (Questions 5-9)
At Question 5, on how national partners and local delivery organisations can work better together to identify and support those at risk of, or experiencing fuel poverty, a number of respondents emphasised the value of close partnership working between services and agencies – national and local. Many saw an opportunity to learn from existing partnership working and cited a range of existing approaches and guidance as offering potential to inform further development of partnership working. In terms of specific services, respondents most frequently referred to the importance of better partnership working between housing, health and social care services.
At Question 6, in terms of what local partners can do to contribute to meeting national aims of effectively and sustainably tackling fuel poverty, respondents emphasised the value of better partnership working to maximise the impact of local partners’ activity. Ensuring there is a shared commitment across partners, and that fuel poverty has a clear place alongside partners’ competing priorities, were also seen as important.
Question 7 asked how the Scottish Government can support local delivery partners to measure their success. A number of respondents wished to see the Scottish Government produce a reporting framework linked to the outcomes expected from partners, including guidance on methodology and indicators for local partners to use in measuring their impact. It was also suggested that a standardised measurement/reporting tool, and potentially a centralised reporting ‘hub’, could further improve this reporting.
Question 8 asked how the Scottish Government can best support local or community level organisations to accurately measure, report on and ensure quality of provision of advice and support services and their outcomes. Respondents tended to focus on developing a monitoring and evaluation framework with associated indicators and guidance for organisations to use in measuring their impacts.
Question 9 considered how the one-stop-shop approach could be enhanced for the benefit of HES clients. Suggestions included closer working with local partners and community-level organisations, and more use of outreach approaches and face-to-face engagement.
Targets and indicators (Questions 10-12)
Question 10 asked for views on the proposal to set a new statutory target to eradicate fuel poverty in the Warm Homes Bill. Respondents often made a general statement welcoming the proposal or supporting a statutory target in principle. Such a target was suggested to be important or essential, to demonstrate Government commitment, or to provide a means to monitor progress.
A number of respondents made points concerning use of the word ‘eradicate’ and some felt that this is not right word if the target is actually to reduce fuel poverty to below 10%. Others argued that the Scottish Government should be aiming to completely eradicate fuel poverty, in other words to reduce levels to zero, or should set a date by which this will occur. Some respondents suggested that the existing targets should be more ambitious.
The importance of adequate resources being made available was also highlighted, and respondents noted that the consultation paper contains little information on how the proposed targets will actually be delivered.
Question 11 asked about the proposed sub-targets. The three sub-targets are: the overall fuel poverty rate will be less than 10% by 2040; ensure the median household fuel poverty gap is no more than £250 (in 2015 prices before adding inflation) by 2040; and remove energy efficiency as a driver for fuel poverty by ensuring all homes reach a minimum energy performance rating by 2040.
Respondents sometimes made a statement welcoming or supporting the inclusion of sub-targets, or noting that they approved in principle. Although some respondents suggested the sub-targets to be ambitious but achievable, others felt they are not ambitious enough or that they lack urgency.
With respect to timeframes, while some gave their support, others thought that the proposed timeframe is too long.
A number of respondents commented on Sub-target 3: Remove energy efficiency as a driver for fuel poverty by ensuring all homes reach a minimum energy performance rating by 2040. Although many respondents welcomed this sub-target, some thought it should be achieved sooner than 2040. A number of respondents noted that the minimum acceptable energy efficiency standard has yet to be defined and that this detail is needed.
Question 12 asked for views on the proposed interim milestones. Although a small number of respondents who, in principle, had opposed the inclusion of the sub-targets also argued against the inclusion of interim milestones, a much more frequent position was that they are supported. Reservations expressed about the milestones were most likely to be that the levels and timeframes proposed are not, or may not be, sufficiently challenging or that they represent only very modest reductions on present levels of fuel poverty.
Comments specifically on milestone 1 were typically that it is not ambitious enough, with respondents noting that the figures set out in the consultation paper suggest that only a small percentage of households would be removed from fuel poverty by 2030. On milestone 3, it was felt that detail is lacking.
Monitoring, evaluation and reporting (Questions 13-18)
Question 13 asked how the new Fuel Poverty Advisory Panel and Fuel Poverty Partnership Forum should monitor progress towards meeting the proposed sub-targets and interim milestones.
A number of respondents commented on the importance of establishing an approach to monitoring from the outset. This was often associated with the approach being clearly set out in in the Fuel Poverty Strategy. Respondents also commented on the importance of taking a partnership approach to tackling fuel poverty and felt that this should be reflected in the membership of the new Advisory Panel and Partnership Forum. Suggestions included having members who represent the rural and island perspective, or who have direct experience of working in the field of fuel poverty, or who have lived experience of fuel poverty.
It was suggested that the proposal for 4 yearly reporting does not seem sufficient. Annual, outcome-focused reporting was proposed as better way forward  . It was also suggested that reporting should cover progress made in meeting targets and milestones that relate specifically to rural and remote rural Scotland.
On the new Advisory Panel’s priorities in its first year (Question 14), a number of respondents felt that establishing an outcomes-focused monitoring and evaluation framework and scrutiny programme was a priority.
Respondents also identified a priority around reviewing the definition for fuel poverty to ensure that it covers vulnerable people, fuel poor people and does not discriminate based on geography  . A specific suggestion was that the new Advisory Panel could assess the extent to which Scottish Housing Condition Survey ( SHCS) data accurately reflects rural fuel poverty or fuel poverty at a small area level  .
Another priority identified was around partnership working and included that the new Advisory Panel should focus on the development of partnerships  .
At Question 15, in terms of examples respondents had of using proxies to identify fuel poor households, the most frequently used proxies were Council Tax Records (used by 18 respondents), the Scottish Index of Multiple Deprivation ( SIMD) (used by 16 respondents) and being in receipt of social welfare benefits, including Housing Benefit (used by seven respondents). Less frequently used proxies included EST Home Analytics and Energy Performance Certificate ( EPC) rating.
Question 16 asked about key lessons to be learned from any existing approaches that apply proxies in door-to-door, on-the-ground assessments. Comments included that the door-to-door approach is an effective, if resource intensive, way of gathering accurate information.
Some respondents highlighted the challenges associated with using the door-to-door approach, including that householders, and particularly older people, can be suspicious of those coming to their door and may in any case be reluctant to share detailed income and fuel use information  .
At Question 17 a number of respondents made broader comments about the use of doorstep tools for area-based schemes. There was support for the development of a tool which allows for easy identification of fuel poor households. However, others had significant reservations. Concerns included that it would or may not be well received by householders and by vulnerable householders in particular.
Other concerns or comments focused on the level of resources that would be required to use any doorstep tool.
Moving forward, some respondents commented on possible issues around any new tool including that it is difficult to comment on its value without knowing how it will be constructed and what it will be used for. It was suggested that it will need to be straightforward and user friendly. It was also suggested that users would require significant training and guidance.
At Question 18, in terms of how the Scottish Government can most effectively work with Community Planning Partnerships in a collaborative manner to report on overall fuel poverty levels as part of the SHCS, comments included that it will be important to utilise local data.
Outcomes and principles
Question 19 asked for views on how an outcomes-focused approach would work in practice. Many respondents began their comments with a statement of support for taking an outcomes-focused approach. Strengths and positive impacts anticipated as stemming from such an approach in the field of fuel poverty included that it would shift the focus away from properties, numbers of energy efficiency measures installed, or funding invested, and onto the impact on people, and specifically on to people who need support the most.
Other comments included that gathering qualitative feedback on the impact that fuel poverty or energy efficiency measures have had on individual households may be a challenge.
A number of respondents simply agreed that the outcomes-focused approach would encourage national and local policy and delivery partners to work together effectively. Further comments included that it will support a collective vision that all partners can share. It was also suggested that it will help foster more closely aligned and successful partnership activity, and will encourage national and local policy and delivery partners to work together effectively.
The consultation paper sets out that the following principles will underpin the approach to tackling fuel poverty:
- The fuel poverty strategy will be firmly based on the principle of social justice and creating a fairer and more equal society, irrespective of whether individuals live in urban or rural Scotland;
- The Scottish Government's approach to fuel poverty eradication will be set on a statutory framework, measured and overseen by Ministers and delivered via partnership structures at a local level. Building on the assets of individuals and communities will be at the heart of this partnership and early intervention and prevention will be crucial to success; and
- The needs of individuals and families will be at the heart of service design and delivery and the fuel poverty strategy will address all four drivers of fuel poverty: income, energy costs, energy performance, and how energy is used in the home.
At Question 20 on the three principles, many respondents agreed that the principles are adequately reflected in the outcomes framework. Other comments tended to focus on areas which were not seen as being given sufficient coverage within the three principles. It was suggested that the needs of rural and island communities are not clearly acknowledged and taken into account.
The final question in this section, Question 21, asked respondents if they thought the proposed framework would help to strengthen partnerships on the ground. A majority of respondents, 72% of those answering the question, thought it would.
Those who thought the proposed framework would help to strengthen partnerships on the ground most frequently pointed to the importance of working collaboratively to tackle fuel poverty. Respondents also pointed to the importance of fuel poverty being established as a clear priority for the partnerships and the organisations they work with, and to all those involved in understanding how they and others can contribute towards achieving shared outcomes. Otherwise, respondents noted some of the conditions they believed would need to be in place for the collaborative approach to work successfully, including the availability of sufficient funding.
Question 22 asked respondents if they thought the proposals will have an impact, positive or negative, on equalities and in particular on those with protected characteristics (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation).
Of the respondents who answered the question, 59% thought there would be a positive impact for people with protected characteristics, while 32% thought impacts would be negative and 10% did not foresee there being any impact.
Respondents who took a generally positive view of the impacts of the proposals suggested benefits would include reducing inequality, targeting those most in need and making fuel poverty a priority, although some concerns about the outcomes in rural and island areas and the effect of raising the age threshold were also expressed.
Respondents taking a generally negative view often referred to their fundamental concerns that the proposed definition of fuel poverty does not properly recognise the issues faced by rural and island communities.
At Question 23, on the implications (including potential costs) for business and public sector delivery organisations from these proposals, a number of respondents commented that they are as yet unclear what the implications might be.
There was reference to increased burdens in terms of reporting and monitoring. The potential for increased costs to both businesses and delivery organisations, particularly when working in remote rural and island communities, was also noted. Local authority respondents in particular were amongst those who pointed to the demand on existing resources and to the need for additional funding. Opportunities for business development and job creation were identified as potential benefits stemming from the proposals.
The final consultation question, Question 24, asked respondents if they thought any of the proposals will have an impact, positive or negative, on children's rights. Of those who answered the question, 65% thought there would be a positive impact for children’s rights, while 19% thought impacts would be negative and 16% did not foresee any impacts. Comments included, most frequently, that any initiative to reduce inequalities or target fuel poverty in households with children is welcome. Benefits identified for children included improved living conditions, better health and wellbeing, and improved educational achievement. Negative impacts arising from the new definition of fuel poverty were suggested as including that resources may be diverted away from households with children.
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