Fuel Poverty Strategy for Scotland: consultation analysis

6. Monitoring, evaluation and reporting

Summary of Questions 13 to 18

• A number of respondents commented on the importance of taking a partnership approach and felt that this should be reflected in the membership of the new Fuel Poverty Advisory Panel.
• Suggestions as to those who should be included people who represent the rural and island perspective, with direct experience of working in the field of fuel poverty and with 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.
• In terms of the new Advisory Panel’s priorities for its first year, there were suggestions around strategic and policy work, monitoring progress, developing definitions and the evidence base and supporting partnership working.
• The most frequently used proxies were Council Tax Records, Scottish Index of Multiple Deprivation ( SIMD) data and being in receipt of social welfare benefits.
• There were mixed views on the use of proxies, although most who commented suggested the door-to-door approach is an effective, if resource intensive, way of gathering accurate information.
• 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.

6.1. Section 6 of the consultation paper asked six questions covering monitoring, evaluation and reporting.

6.2. The first two of these (Questions 13 and 14) focused on new governance arrangements that are being implemented to replace the old Scottish Fuel Poverty Forum. Ministers have approved a proposal for two new bodies to be established, an independently chaired Scottish Fuel Poverty Advisory Panel and a Partnership Forum. The new Advisory Panel will be a smaller, strategic group which will meet at five times per year. The Partnership Forum will have a wider membership and will meet a minimum of once per year, with the potential to meet a second time within the same year if required.

6.3. The Scottish Government expects these new groups to be operational by early 2018.

Question 13 - How should the new Fuel Poverty Advisory Panel and Fuel Poverty Partnership Forum monitor progress towards meeting the proposed sub-targets and interim milestones?

6.4. A total of 62 respondents commented at Question 13. A breakdown of the number of comments received by respondent type is set out in Table 14 below.

Table 14: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	3
Energy Company	2
Health and Social Care	3
Housing Association	7
Housing Body or Group	3
Inter-agency Group or Partnership	5
Local Authority	18
Other	3
Research Group	2
Third Sector	9
Organisations	55
Individuals	7
All respondents	62

The overall approach to monitoring

6.5. A number of respondents commented on the importance of establishing an approach to monitoring from the outset. This was often associated with the approach forming part of the terms of reference for the groups or being clearly set out in in the Fuel Poverty Strategy. On this latter point it was suggested that the Strategy should include a Monitoring and Evaluation Plan.

6.6. There were also comments on how the framework for monitoring of progress should be developed. These included that the new Advisory Panel and Partnership Forum should be responsible for developing the approach to monitoring, including Key Performance Indicators ( KPIs) which they would then use to monitor progress. It was suggested that key stakeholders should be involved in this work.

6.7. However, concerns were raised about the lack of information on how the new Advisory Panel and Partnership Forum would be accountable to the public. A small number of respondents raised other concerns, including that it is not clear that the new Advisory Panel will be able to challenge Ministers if sub-targets are not met. It was suggested that the groups need to have sufficient powers to ensure that plans are implemented and revised if required.

6.8. Finally, there were some concerns that the low frequency of meetings proposed makes it hard to see how the new Advisory Panel could effectively influence the delivery of the proposed sub-targets and milestones.

The composition of the new Advisory Panel and Partnership Forum

6.9. Around 1 in 9 respondents who answered the question 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.

6.10. On membership, there was a question as to how transparency of membership will be achieved and a comment that having further details about how the groups’ members would be appointed and by whom would be helpful. There was also a suggestion that the membership of the two groups should be on public record.

6.11. Suggestions as to those who should be included in the membership of the groups were people:

• Who represent the rural and island perspective. This issue was raised by around 1 in 8 of those who answered the question. A specific suggestion was that the composition of both groups should be prescribed to ensure that the interests of rural and remote rural Scotland are represented.
• With direct experience of working in the field of fuel poverty, such as in-home energy advisors. This could also include local delivery partners.
• With lived experience of fuel poverty. The Experience Panels established under the devolution of social security was cited as an example of involving people with lived experience in the decision-making process.
• From the protected characteristics groups set out in the Equality Act 2010.
• Representing any regional fuel poverty groups that might be established.
• Representing each of the Regional Networks. ^[14]

Type and quality of data

6.12. A number of the comments referred to the type and quality of data and information which should be used to inform the monitoring of progress. General comments included that robust processes and accurate and robust data will be required and that the approach should be evidence-based. It was also noted that there are different levels at which progress can be monitored and that at the national level this is likely to be achieved through the use of national and other survey data. At a local level, it was suggested that a means through which the quality of local partnership working can be evaluated in different parts of the country should be established. An early priority for the new Advisory Panel should be the development of methods by which relevant local partnerships can be identified and feedback on their performance provided.

6.13. It was suggested any monitoring approach should draw on data already being gathered. A number of respondents made specific reference to the use of data gathered through the SHCS, including seeking clarification around how it will be used by the new Advisory Panel or Partnership Forum.

6.14. However, a small number of respondents were of the view that SHCS data is not robust at the local level, including for some rural local authorities because of the sample size ^[15] . More generally, there was a view that that significant additional work on top of what is currently measured and reported through the SHCS will be required and it was suggested that local authorities, Registered Social Landlords and HES could have a role to play. It was also suggested that the groups should have full access to all relevant Scottish Government information.

6.15. In terms of the overall approach to be taken, it was felt that the new Advisory Panel should facilitate the use of real data in monitoring and analysis of policies and projects, and that this approach should go beyond basic measures such as numbers of installations and the very basic assumptions used to model energy use. There were also suggestions about the types or sources of other data or evidence that should be used. These included:

• Mapping of progress across Scotland.
• Data from the EPC Register.
• Localised Fuel Poverty surveys. These could be standardised survey with higher sample rates than the SHCS.
• Good practice examples.
• Evidence of the effectiveness of fuel poverty funding schemes and advice and advocacy.
• Customer satisfaction information.

6.16. It was also suggested that there should be a review of the current proxies, for example Council Tax banding, available for different fuel poverty schemes.

Reporting

6.17. It was suggested that the proposal for 4 yearly reporting does not seem sufficient. Annual, outcome-focused reporting was proposed as better way forward. Other suggestions concerning the approach to reporting included:

• Progress should be reported to Scottish Ministers or the Scottish Parliament.
• Reporting should cover progress made in meeting targets and milestones that relate specifically to rural and remote rural Scotland.
• Reporting should be broken down by at risk groups. The potentially disparate outcomes for equalities groups, including BME groups, disabled people, and women should be considered.
• Local Authorities should report on partnership working.

6.18. Queries included whether the reports of the new Advisory Panel and Partnership Forum will be published. It was also noted that Scottish Government’s second consultation on Local Heat and Energy Efficiency Strategies ( LHEES) proposes that fuel poverty and climate change are reported through LHEES. It was suggested that further consideration and clarity may be required as to how these proposals will fit with the Scottish Government’s new Fuel Poverty Strategy.

6.19. A number of respondents focused on any reporting requirements placed on other organisations, including commenting that they should be simple and easy to understand. It was suggested that guidance should set out a framework for public reporting requirements for local authorities, partnership organisations and local delivery partners.

Question 14 - What do you think the Advisory Panel’s priorities should be in its first year?

6.20. A total of 64 respondents commented at Question 14. A breakdown of the number of comments received by respondent type is set out in Table 15 below.

Table 15: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	2
Energy Company	2
Health and Social Care	4
Housing Association	8
Housing Body or Group	3
Inter-agency Group or Partnership	5
Local Authority	19
Other	4
Research Group	2
Third Sector	9
Organisations	58
Individuals	6
All respondents	64

6.21. A small number of respondents simply agreed with the focus of the new Advisory Panel’s work as set out in the consultation paper.

Strategic and policy work

6.22. It was felt that the new Advisory Panel’s key objective should be to operate as an effective oversight body for the Fuel Poverty Strategy and to ensure that the Strategy and Targets are clear. A suggested priority for new Advisory Panel’s first year of operation was to identify policy commitments that will have an impact on tackling fuel poverty. The new Advisory Panel would then focus on determining whether sufficient action is being taken in each policy area and identifying any gaps in action within any policy area. It was also suggested that the new Advisory Panel should:

• Have a role in influencing the upcoming Warm Homes Bill to ensure that it reflects the Fuel Poverty Strategy, Targets, and Milestones.
• Focus on introducing a requirement for action on fuel poverty to be included in Health and Social Care Strategic Plans, linking in to the similar requirements in Local Housing Strategies.
• Scrutinise the contracting of all delivery services to ensure their conditions are best suited to the organisations best placed to support fuel poor and otherwise vulnerable householders.
• Have a clear focus on action, including putting programmes that reduce fuel poverty in place.

6.23. Other comments suggested priorities relating to the workings of the new Advisory Panel and included setting Terms of Reference and developing a Business Plan and Communication Strategy. Raising the public profile of the new Advisory Panel, and the work it would be doing, was also seen as an important priority. As the previous question, there were also comments about the composition of the new Advisory Panel and it was suggested that ensuring the new Advisory Panel is made up of people from as wide a range of backgrounds as possible should be a priority.

Monitoring of progress

6.24. Very much in line with comments at the previous question, around 1 in 5 of respondents who answered the question felt that establishing an outcomes focused monitoring and evaluation framework and scrutiny programme was a priority. A specific suggestion was that developing a system to measure the affordable warmth outcomes of the new Fuel Poverty Strategy should be a priority. It was also suggested that priority should be given to the standardisation of monitoring and reporting.

6.25. Further comments included that any scrutiny programme should be linked to the work of other relevant agencies, such as the Poverty and Inequality Commission, and strategies, such as the Energy and Child Poverty Strategies.

6.26. As at previous questions, the importance of ensuring any monitoring approach works for rural areas was highlighted. It was also suggested that the new Advisory Panel should develop a strategy to adequately assess, monitor and improve the situation for people with protected characteristics. The example of fuel poverty among Gypsy/ Traveller communities was given as an example and it was suggested that the new Advisory Panel may wish to identify equality targets to monitor progress going forward.

Definitions and evidence

6.27. Around 1 in 6 of respondents who answered the question also identified a range of priorities associated with reviewing and researching definitions, including that for fuel poverty. Suggestions included that fuel poverty definitions need to be reviewed to ensure that they cover vulnerable people, fuel poor people and do not discriminate based on geography. It was suggested that the new Advisory Panel must ensure that the final fuel poverty definition is fit for purpose and allows all areas of the country the flexibility to tackle fuel poverty in their area.

6.28. Specific elements which respondents wished to see reviewed included:

• The scale and nature of fuel poverty across the country and how it is being tackled currently. A specific suggestion was that the new Advisory Panel could assess the extent to which SHCS data provides an accurate picture of rural fuel poverty or fuel poverty at a small area level. The mapping of the national and local support currently available was also suggested.
• The definition of vulnerability.
• Age thresholds.

6.29. A specific suggestion was that an independent group of public health experts should be commissioned to develop a list of health and disability categories, as well as age bands, that would satisfactorily encompass the term “vulnerable to the adverse health and wellbeing impacts of living in fuel poverty”. Reference was also made to taking up the recommendations in the report on the MIS for rural Scotland.

6.30. Identifying gaps and developing an approach to gathering qualitative information around lived experience of fuel was also seen as a priority. This could involve working in partnership with those with lived experience, communities, the third sector, academia and across Government.

Partnership working

6.31. Another priority identified was around partnership working and included that the new Advisory Panel should focus on the development of partnerships. Further comments referred specifically to local partnerships and included that there should be a review of powers and resources they require. It was also suggested that the new Advisory Panel should prioritise capacity and skills building within those local partnerships.

6.32. In terms of the membership of these partnerships, suggestions included that they should bring together local public, private and third sector partners working on public health, housing, income support and energy efficient. There was a specific reference to creating links with:

• Local communities.
• Community Planning Partnerships.
• Local delivery organisations across Scotland.
• Social housing providers and their tenants.
• The NHS.
• Human Rights bodies such as the Scottish Human Rights Commission.

6.33. Further comments related to partnership working included that the new Advisory Panel should ensure support and training is available for key local delivery partnerships and partners.

Question 15 - What examples do you have of using proxies to identify fuel poor households?

a) Which proxies did you use?

b) Based on your experience, how well did these proxies work in accurately identifying fuel poor households?

6.34. A total of 51 respondents commented at Question 15a and 46 respondents at 15b. At 15b, some respondents referred back to their comment at 15a. A breakdown of the number of comments received by respondent type is set out in Table 16 below.

6.35. A single analysis of the comments across both questions is presented below.

Table 16: Number of comments by respondent type

Type of respondent	Number of comments at 15a	Number of comments at 15b
Organisations:
Community or Tenant Group or Federation	2	-
Energy Company	5	5
Health and Social Care	2	2
Housing Association	6	6
Housing Body or Group	1	-
Inter-agency Group or Partnership	4	3
Local Authority	18	18
Other	2	1
Research Group	1	1
Third Sector	8	8
Organisations	48	43
Individuals	2	2
All respondents	51	46

6.36. Of the 51 respondents who commented at Question 15a, a small number noted that they do not have experience of using proxies to identify fuel poor households. However, one of these respondents did note that they have used home visits and detailed interviews as a means of assessment. Other respondents did identify proxies, although it was not always clear that they had direct experience of using them.

General Issues

6.37. Some respondents made broader comments on the use of proxies. These included that current proxies are inadequate and noting that those used currently tend to be focused on energy inefficiency rather than fuel poverty. A small number of respondents felt that proxies simply do not work. It was suggested that using proxies, assumptions, archetypes and inappropriate statistical techniques does not have any value in targeting fuel poor householders, and actively disadvantages the most vulnerable. However, a small number of respondents disagreed. For example, one suggested that the proxies they use (Scottish Index of Multiple Deprivation ( SIMD), Council Tax Bands and Home Analytics database, all set out further below) have worked well and that they would be keen to retain them. Another felt that using proxies to target programmes to all households in a particular area has allowed them to make a significant difference in a local community.

6.38. Other general comments about the use of proxies included that:

• It is important that any proxies used acknowledge that fuel poverty is not the same as income poverty.
• The impact of the use of proxies on the people living in fuel poverty or people who will be identified as such through the use of a specific proxy should be measured and evaluated. Being identified as fuel poor could expose households to stigmatisation if it is not done in a respectful and secure manner.
• Proxy data can often give local authority-level data but not wards or neighbourhood. In particular, it has the potential to miss smaller pockets of fuel poverty, in generally affluent areas.
• Proxy information often needs to be matched up with stock condition information and further refined to provide accurate results.
• Identifying fuel poor households is a particular challenge for local authorities which transferred their housing stock, because information on tenants and properties is no longer held by them.

6.39. Others noted that there are other means to identifying fuel poor households than the use of proxy. For example, a Local Authority respondent noted that a significant number of fuel poor households are identified by frontline staff who are visiting households for other reasons. They went on to suggest that it would be helpful to focus on supporting referrals from a wide range of workers, through training and awareness raising. A Health and Social Care respondent reported that they have worked with Shelter Scotland to customise a Healthy Homes - Fuel Poverty LearnPro module for health and social care staff including those in general practice. This contains a checklist to enable staff to identify fuel poor households.

6.40. Respondents also provided information about how they use proxy information to assess fuel poverty. Examples included:

• Producing Fuel poverty maps to identify households in fuel poverty and apply for funding such as HEEPS. Information is provided by datazone, enabling direct targeting of communities that are at high risk of fuel poverty.
• Using the Centre for Sustainable Energy’s Fuel Poverty Calculator.

6.41. The analysis presented below sets out the proxies identified at 15a in turn. The proxies about which further views were given, in line with Question 15b on how well that proxy works in accurately identifying fuel poor households, are presented first.

6.42. If four or more respondents reported using a particular proxy, the number of respondents has been stated. Please note that some of the comments made about particular proxies were made by respondents who had not reported using those proxies.

6.43. Council Tax Records (used by 18 respondents). In particular households eligible for Council Tax Reduction Schemes. It was also noted that Council Tax Banding A-C is used for HEEPS: ABS.

6.44. Positives associated with the use of Council Tax records included:

• It is an efficient and cost-effective method of delivery for area-based programmes.

6.45. Concerns or issues raised about using Council Tax records included:

• Council Tax banding A-C is a poor proxy as many householders in higher bands have inherited properties that are harder to heat because of their size.
• The use of Council Tax Banding A-C does not work well for rural areas as fuel poverty is pepper potted.

6.46. SIMD data (used by 16 respondents). Positives associated with the use of SIMD data included:

• It is an efficient and cost-effective method of delivery for area-based programmes.
• It can be used to target face-to-face fuel poverty or energy advice to the most deprived areas.
• It assists to some degree in identifying fuel poor households at a local level.
• If an area is in one of the most deprived data-zones then there is a high probability that, in the thermally inefficient properties targeted, there will be high numbers of fuel poor residents.

6.47. Concerns raised included:

• There is little correlation between the proxy of SIMD Income Domain distribution pattern with that of fuel poverty.
• Place-based measurements, such as SIMD, are not an effective means to capture the experiences of BME communities, as poorer BME households are not as concentrated in rural areas as their white counterparts.

6.48. SHCS (used by four respondents). Concerns raised included:

• The samples sizes used to inform the SHCS about the rates of fuel poverty in rural and remote Scotland are so small as to call into question their reliability ^[16] . As with some other national data, it needs to be ‘island-proofed’.

6.49. Receipt of social welfare benefits, including Housing Benefit (used by seven respondents). These proxies were noted as being used to assess applications under the UK Government’s ECO and the Warm Home Discount. Alternatively, it was suggested that receipt of Warm Home Discount rebate was itself a proxy.

6.50. EST Home Analytics (used by four respondents). Concerns raised included that the information held within this database is out of date.

6.51. Heat Mapping. Concerns raised included that Heat Mapping is modelled data and only applies to broad areas. ^[17]

6.52. Capped gas households, identified by heating engineers. This approach was reported as having been very successful.

6.53. Central heating other than gas or electric. It was noted that rural areas are more likely to have central heating or fuel types other than gas or electric, such as oil, liquefied petroleum gas and solid fuel, meaning this proxy has a rural focus.

6.54. Electric heating. It was suggested that a reasonably successful proxy is that of electric storage heating (or warm air) in buildings with poor thermal performance.

6.55. Information provided by other agencies, such as the local Citizens Advice Bureaux. The examples given included being a low income or workless household and being homeless or threatened with homelessness.

6.56. Other data or information sources which respondents reported as using as a proxy included:

• Local Authority Regeneration Areas.
• Local House Condition Survey Information.
• EPC rating (used by five respondents).
• Scottish Housing Quality Standard data.
• Thermal properties of housing.
• House type, for example croft houses.
• Weather exposure.
• Properties with off-gas grid.
• CACI data.
• Fuel Poverty maps (which can be accessed from the Scottish Government’s website).
• Evidence from the Home Energy Efficiency Database ( HEED).
• Fuel costs, including high, unaffordable fuel costs.
• Fuel debt.
• Self-disconnection or heating not being used.
• Rent arrears.
• Eligibility for Tax Credits
• Eligibility for Free School Meals or Clothing Grant Awards.
• Income Levels.
• Financial Health Check Service information.
• Households falling into Energy Company Obligation ( ECO) categories.

Other possible proxies, data sources or approaches

6.57. Other comments suggested possible proxies or other information or data which could be used to identify fuel poor households. These included:

• Cold Weather Payments, as a useful proxy for those at risk of fuel poverty because of low incomes.
• Electric heating, as an indicator of higher energy costs.
• For rural areas, off-gas grid and in particular off-gas grid in remote rural areas and islands.
• For urban areas Council Tax Band A-C and off-gas grid heating systems.
• In-depth stock and household surveys at a local authority level. One Local Authority respondent reported that they are developing a housing database which will monitor stock improvements across the private and social sector.
• EPC ratings from Home Information Packs.
• Energy usage data, such as higher or unexpectedly lower than average consumption levels.
• Household composition and circumstances, such as being older, unemployed, in receipt of benefits, having a health condition, having rent arrears, being in fuel debt etc.

6.58. Sources for information that could be used as a proxy included:

• The Property Services Register.
• Mapping tools that use postcode level data, such as Acorn or Mosaic.

6.59. Other possible approaches outlined included:

• The use of a Statement of Intent for ECO-Flex. Specifically, empowering trusted partners to make presentations of householders for ECO-Flex declarations.
• Creating dynamic digital templates that pre-populate criteria for a household.

Question 16 - What are the key lessons to be learnt from any existing approaches that apply proxies in door-to-door, on-the-ground assessments in this context?

6.60. A total of 39 respondents commented at Question 16. A breakdown of the number of comments received by respondent type is set out in Table 17 below.

Table 17: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	2
Energy Company	2
Health and Social Care	-
Housing Association	4
Housing Body or Group	-
Inter-agency Group or Partnership	3
Local Authority	13
Other	2
Research Group	1
Third Sector	8
Organisations	35
Individuals	4
All respondents	39

6.61. A number of the comments made broader observations about the use of door-to-door assessments. Although a small number felt that area-based approaches or the use of proxies is not a good way forward, around 1 in 8 of those who answered the question suggested the door-to-door approach is an effective, if resource intensive, way of gathering accurate information. It was also suggested that when the area-based approach is being used, the use of proxies works well or is a must.

6.62. 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. It was suggested that a sensitive approach from a known individual is key, and that using local and trusted third parties can be effective in building effective community relationships and delivering successful energy efficiency and fuel poverty programmes.

6.63. Other key lessons focused on the gathering of information or the sharing of advice. Points raised by respondents included that:

• The in-person, face-to-face approach is effective, because it is most likely to lead to real change. An example given was being able to show someone how to adjust their storage heater dials.
• It is important not to over burden the household with too many questions or multiple visits by different partners and companies monitoring the output. Also, any approach should draw on information which householders can supply easily.
• People in debt can be reluctant to divulge income information and there could be problems if any tool requires accurate income information to be effective.
• It is important that an assessor is able to provide the householder with advice and information about the proposed energy efficiency measures. For example, they need to be fully aware of how the possible funding works and how different households may have access to different pots of funding.
• The introduction of the DWP data matching service managed by EST has worked extremely well. The householder has to agree to basic data including name, address and date of birth being given to DWP who will then declare a match if the householder is in receipt of eligible income-related benefits. This service should be included in any door-to-door approach undertaken in the future.
• The rollout of Universal Credit may lead to significant confusion and lead to erroneous results or decisions around referral or entitlement to support.

6.64. Other comments related to the proxies being used and included:

• Given the new definition and revised approach, it would seem reasonable to take the draft outcomes in turn and examine what proxies might follow from them.
• Some proxies may be more effective than others. It will be important that any assessment takes account of the potential for individuals to have different expectations around what is affordable and whether they need financial support.

6.65. There were suggestions as to how on-the-ground assessment approach could be supported or better targeted, including:

• The process, and particularly the qualification criteria, can be confusing for householders. It would be helpful to have an easy to use definition of fuel poverty and clear eligibility criteria to ensure that there are no grey areas for householders.
• Proxies work best in projects with a degree of flexibility around the proxy and when used in conjunction with on the ground data provided by clients or by other local support organisations.
• The roll out of smart meters could provide a useful additional means of identifying vulnerable households.

6.66. There was also reference to the Low Income/High Costs assessment tool developed in England and it was suggested that the development of a practical and potentially highly accurate assessment tool for targeting and monitoring fuel poverty in local areas and on the ‘doorstep’ would be welcome.

6.67. There were also more general suggestions around working across communities to tackle fuel poverty. A town centre - based Energy Advice Centre was highlighted as providing a permanent hub for local residents to access support. Drop-in style Energy surgeries were also suggested.

Question 17 - Do you have any concerns about the use of a doorstep tool, in particular the challenges around delivery of area-based schemes?

6.68. A total of 56 respondents commented at Question 17. A breakdown of the number of comments received by respondent type is set out in Table 18 below.

Table 18: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	2
Energy Company	2
Health and Social Care	3
Housing Association	8
Housing Body or Group	1
Inter-agency Group or Partnership	4
Local Authority	19
Other	2
Research Group	1
Third Sector	9
Organisations	51
Individuals	5
All respondents	56

6.69. A number of respondents made broader comments about the use of doorstep tools for area-based schemes, including highlighting the significant achievements of area-based schemes across Scotland. There was also support for the development of a tool which allows for easy identification of fuel poor households. However, others (around 1 in 6 of those answering the question) raised significant reservations. Concerns included that it would, or may not be, well received by householders and by vulnerable householders in particular. There were also concerns about privacy and confidentiality.

6.70. Other concerns raised centred around a perceived focus on door-to-door to the exclusion of other approaches. These concerns stemmed from seeing it as a fabric only approach which has been the mainstay of existing projects which have failed to eliminate fuel poverty to date.

Resources

6.71. Other concerns or comments focused on the level of resources that would be required to use any doorstep tool. One Local Authority respondent reported that they have considerable experience in delivering complex schemes bringing together partners and complicated funding packages and felt with some certainty that door to door calling will be detrimental to the delivery of area-based schemes in their area. Respondents also suggested that door-to door approaches are resource intensive and make this type of tool potentially difficult to sustain for many Councils and local partners.

6.72. A specific suggestion was that organisations such as HES could be geared up to ask early questions about fuel poverty.

Assessment tools

6.73. On current household assessment tools, it was reported that delivery bodies generally use versions of the reduced dataset Standard Assessment Procedure ( rdSAP) form. The Research Group respondent highlighting this issue went on to comment that the extensive limitations of rdSAP and its parent assessment ( SAP) are well-known and that the use of proxies and assumptions in these tools is their most significant limitation.

6.74. Moving forward, around 1 in of 8 respondents who answered the question 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.

6.75. Points highlighted as to be considered when developing any new doorstep tool included that:

• It will be difficult to develop a tool which combines the comprehensive range of questions required to yield the most meaningful information, but which can be completed quickly.
• The quality and format of locally-held data may be variable.
• Accessing reliable data on income may be challenging.

6.76. Comments on how any new tool should be framed included:

• It will need to be straightforward and user friendly. One suggestion was adopting a standardised digital format suitable for completion on a tablet computer. However, there were also concerns about the use of a mobile tool to collate data on the doorstep. It was suggested that this has data protection implications for the storage and handling of data and for the security of the data if the device were to be lost.
• It may need to be customised at a local level. However, it was also suggested that consistency would be key; the tool would need to be flexible enough to take local circumstances into account, but at the same time would need to be based on a central system to ensure monitoring is possible.
• It will be important to consider how the tool can be designed and implemented in such a way as to minimise stigmatising households.

6.77. In terms of specific content or features of the tool, suggestions included:

• It should also be a practical referral tool to other local support partners as well as to HES support. It will also need to include regional/area-based data on all services available in the area.
• There needs to be enough flexibility in the tool, or the system, to support re-assessment of fuel poverty status over the project period of an area-based scheme.
• Open questions about whether people are struggling might be more effective than a focus on detail and figures.
• It could be used to identify different, universally available support mechanisms most of use to individual consumers, such as advice on tariffs, a benefits check, or on use of heating controls.

Use of any doorstep tool

6.78. Respondents also made a range of comments about the rollout or use of the doorstep tool including that:

• It will be important to undertake work to alleviate residents’ anxieties about doorstep-based approaches. ^[18]
• Users would require significant training and guidance.
• Clarity is needed around how the information gathered is collated and shared with relevant partners. One suggestion was that data should be fed into a central coordinating agency. It was suggested that HES could take on that role.
• It would be helpful if the tool was made available for residents to determine if they are fuel poor, with a referral system also put in place.

Alternative approaches

6.79. A small number of respondents commented on the overall approach which could or should be taken and generally suggested that a mixed or dual approach should be taken. A specific suggestion was for a universal approach for area-based schemes running alongside referral-based schemes which can be more targeted.

Question 18 - How can the Scottish Government most effectively work with Community Planning Partnerships in a collaborative manner to report on overall fuel poverty levels as part of the SHCS?

6.80. A total of 46 respondents commented at Question 18. A breakdown of the number of comments received by respondent type is set out in Table 19 below.

Table 19: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	1
Energy Company	2
Health and Social Care	2
Housing Association	8
Housing Body or Group	-
Inter-agency Group or Partnership	4
Local Authority	18
Other	1
Research Group	1
Third Sector	5
Organisations	42
Individuals	4
All respondents	46

Appropriateness of using SHCS data

6.81. Not all respondents agreed that there should be a focus on reporting on overall fuel poverty levels as part of the SHCS, with a small number suggesting that fuel poverty may not be best located within the SHCS. A particular concern was that the SHCS’s focus on the built environment may detract from the person-centred approach to tackling fuel poverty which is required.

6.82. A number of the other comments referred to issues already covered at earlier questions, including that the SHCS is based on a very small sample size, and a perceived need among a small number of respondents to improve the robustness of SHCS data for rural areas. Ensuring that the data collection side of SHCS is accurate and reliable at Community Planning Partnership ( CPP) and local authority level was also suggested.

Use of the SHCS data

6.83. Respondents made a number of suggestions as to how SHCS could be made of greater value to CPPs and others in assessing fuel poverty. On a broader point, a Local Authority respondent suggested that the Scottish Fuel Poverty Partnership Forum could liaise with representatives from all local authority CPP’s to find a commonly accepted method of sharing data and reporting effectively to enhance the findings of the SHCS.

6.84. Other suggestions as to how the Scottish Government could make an effective intervention included explaining how the local authority results have been developed.

6.85. In terms of how respondents thought the SHCS data could be made more useful or robust, suggestions included:

• Utilising local data such as data from local delivery organisations or that has been used to create Locality Plans to supplement the SHCS information. This was suggested with particular reference to rural and island communities.
• Combining the Home Analytics data with other along with data already collected.

6.86. A specific idea was that smart meter data could be used to inform future SHCS work. The Local Authority respondent making this suggestion thought this would enable a better understanding of how fuel poor households use energy. In particular, it was felt that this information could be used in conjunction with data available on income, fuel costs and property condition / energy efficiency measures, to ascertain the extent to which fuel poverty is attributable to household behaviours. The Scottish Government was seen as best placed to work with the range of organisations, including energy providers, who would need to be involved.

Other data and reporting issues

6.87. Other respondents raised wider issues and were looking for Scottish Government support around monitoring of progress towards eliminating fuel poverty. It was suggested that the Scottish Government should work with CPPs to utilise existing reporting structures and data sets where possible. The reporting mechanism should be proportionate, fit for purpose and prevent duplication of effort where ever possible. It was also suggested that a more regular fuel poverty reporting process should be put in place.

6.88. Specific issues raised included:

• Changes in the fuel poverty energy modelling as a result of the Warm Homes Discount and changes to fuel prices has meant it is not possible to make direct comparisons between set time-periods. It would be helpful if this could be addressed.
• Consideration could be given to the potential of fuel poverty mapping to be incorporated into SIMD statistics.

6.89. Finally, it was noted that that BME voices are often left out of formal planning structures, including CPPs, and it was suggested that work to report on overall fuel poverty levels should seek to engage BME and other under-represented groups to ensure they are not missing from the monitoring and planning.

Policy and practice support

6.90. Beyond data specific issues, a number of respondents also highlighted other areas of policy or practice in which they felt the Scottish Government could offer support to CPPs. These included working to ensure that fuel poverty is properly prioritised by CPPs and effectively linked to other service delivery activity.

6.91. It was suggested that it would be useful to having a fixed timetable for reporting on fuel poverty and delivery plans would help CPPs with their work planning. Moving forward, it was suggested that each CPP is able to enter into discussions about a more focused and regular timetable (if required) to take account of local circumstances.

6.92. A specific suggestion was that the Scottish Government should develop or endorse best practice as a means to encouraging CPP partners to recognise fuel poverty as a priority. One Local Authority respondent noted that Local CPPs ( LCPPs) ^[19] have a crucial role to play and that, in their area, local reports on key issues are compiled and made available to the LCPPs. They suggested that a similar approach could be considered in relation to fuel poverty. It was also suggested that Local Outcome Improvement Plans should contain specific actions around fuel poverty and the Scottish Government should support Councils and their partners in this effort.

6.93. Otherwise, a range of areas in which the Scottish Government might offer support to CPPs. These included:

• Supporting the development of an effective national network of referral pathways between CPPs and HES.
• Providing support to CPPs in how they could best incorporate fuel poverty outcomes into their statutory Local Outcomes Improvement Plans.
• Supporting an understanding of the social and financial impacts of fuel poverty across a wide range of services and partners. Specifically, developing a Social Return on Investment assessment of fuel poverty related activity.
• Providing advice and guidance on how to monitor the impact of fuel poverty related activity.
• Providing additional support and guidance for rural local authorities which takes cognisance of the unique rural dimension of fuel poverty.

Remit of and working with CPPs

6.94. The role of CPPs in tackling fuel poverty was highlighted. In particular, it was noted that CPPs have a duty to plan and deliver local outcomes with a specific focus on tackling inequalities. It was suggested that fuel poverty targets should be included with Community Plans and Single Outcome Agreement.