Cost analysis on heat pump policy: EIR release

Information requested

Information on the cost analysis on this policy, or any impact reports that have been done to get information on the fuel poverty that is created through the use of heat pumps.

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

We have enclosed documents that reference analysis of running costs for heat pumps, and fuel poverty. These are summarised here:

1	Fuel Poverty – All households to heat pumps effect on fuel poverty – Summary Final
2	RE: Briefing for Deep Dive On Heat Decarbonisation And Fuel Poverty on Thursday 4th March

An exception under regulation 10(4)(e) of the EIRs (internal communications) applies to some of the information you have requested because it is internal communication between Scottish Government Ministers and/or officials about fuel poverty and heat decarbonisation.

An exception under regulation 10(4)(e) of the EIRs (internal communications) also applies to some of the information you have requested because it is internal communication about lines to take.

These exceptions are subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. We recognise that there is some public interest in release as part of open, transparent and accountable government, and to inform public debate. However, there is a greater public interest in high quality policy and decision-making, and in the properly considered implementation and development of policies and decisions. This means that Ministers and officials need to be able to consider all available options and to debate those rigorously, to fully understand their possible implications. Their candour in doing so will be affected by their assessment of whether the discussions on this issue will be disclosed in the near future, when it may undermine or constrain the Government’s view on that issue while it is still under discussion and development.

An exception under regulation 11(2) of the EIRs (personal information) applies to some of the information requested because it is personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exception is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exception.

Some of the information you have requested is available from the Heat in Buildings Strategy Partial Business and Regulatory Impact Assessment that was published here: https://consult.gov.scot/energy-and-climate-change-directorate/heat-in-buildingsstrategy/
supporting_documents/Heat%20%20Low%20Carbon%20Heat%20%20Impact%20Assessment%20%20Partial%20BRIA.pdf.

We also publish an annual Heat in Buildings Progress Report (Heat in Buildings: progress report 2024 - gov.scot). This includes analysis of progress towards the outcome that the heat transition is fair, leaving no one behind, and through this, that heat is affordable. The relevant indicator (2.3.1A) reports on the percentage of homes in fuel poverty.

Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.

In addition to this information, I would also take this opportunity to share with you the wider work that the Scottish Government is undertaking to consider the interaction between decarbonisation and our wider objectives on fuel poverty.

We continue to work closely with the Scottish Fuel Poverty Advisory Panel as we finalise a fuel poverty framework. This will strengthen our reporting on fuel poverty, in line with our Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019.

The relationship between clean heating and energy prices, which are the main driver of fuel poverty, is complex. There are different types of clean heating systems, some of which cost more to run than others, and the costs also vary depending on the type of building and how well insulated it might be.

Running costs would likely increase for homes switching to electric heating from gas as things currently stand, but we expect that to change if measures are introduced by the UK Government to make electricity cheaper than it is at the moment. The Scottish Government is continuing to press the UK Government to do just that.

We have also said that the UK Government must urgently deliver a “social energy tariff”, in the form of an automatic and targeted discount on energy. Support should be available to all fuel users, offering protection to ensure that consumers can afford their current heating and energy needs while supporting them to make the change to clean heating.

Our Warmer Homes Scotland scheme supports those in, or at risk of, fuel poverty through the net zero transition by installing insulation, new heating and other energy measures. The scheme offers measures, including heat pumps, based on the appropriate technical assessments and the impact on the households’ energy costs is modelled. Clean heat technologies will not be recommended where this would push up a customer’s fuel bills when installed alongside other energy efficiency technologies and in these cases an alternative system, such a s a gas boiler if appropriate, will be offered.

The Scottish Government will shortly be introducing a Heat in Buildings Bill. This will set a target for Scotland’s homes and buildings to move to clean heating systems by 2045 alongside our continuing work to reduce fuel poverty. We will ensure that we take a flexible approach to encouraging change in the way people heat their homes. We will also include measures to improve the energy efficiency of our homes, which can reduce the energy needed to heat them and help reduce bills.

We are also continuing to work with social housing owners and landlords on our proposed Social Housing Net Zero Standard which is also designed to make social homes more comfortable and easier to keep warm.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

EIR 202500468946 - Information released - Documents

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