Heat network licensing: equality impact assessment

Key Findings

A summary of our findings is listed below;

Age

• The team agreed that there may be a considered impact for elderly people for ensuring they are protected from any disruption to their utility services such as heating or hot water.
• Our research clarified this can be mitigated through the use of the priority services register which is a free UK wide service that provides extra advice and support, including when there’s an interruption to your electricity, gas or water supply. It helps utility companies, including energy suppliers, electricity, gas and water networks to look after customers who have extra communication, access or safety needs. This will ensure the continued supply of utility services to meet the needs of the consumer listed in certain categories, for example someone of pensionable age.

Disability

There could be potential impacts on accessibility for consultation materials for example if anyone requires assisted reading such as large print, easy read or braille. This will be factored into our request from the digital team, APS and citizen space.

• Another impact discussed was in relation to access during any road closures or works such as ramps and ensuring areas are safe and barricaded appropriately. This will be covered by roadworks legislation and overseen by the Scottish Road Works Commissioner to ensure the safe planning, coordination and quality of road works throughout Scotland.
• Another consideration for this group would be mitigated under the priority services register which protects certain groups from having disruption to utility services such as heating and hot water. This will ensure the continued supply of utility services to meet the needs of the consumer in certain categories, for example someone who has a disability.

Sex

• There are no impacts or issues considered to arise over this characteristic as any licensing process will not be differentiating between sex. However, we must ensure we demonstrate inclusive engagement within our public consultation, through using gender inclusive language and writing in a way avoids indirect discrimination. Following the Scottish Government and APS guidelines.

Pregnancy and Maternity

• There could be an impact surrounding accessibility during road works in relation to the access of safe pavements for prams etc similar to the disability consideration. This would again be covered under the roadworks legislation and overseen by the Scottish Road Works Commissioner to ensure the safe planning, coordination and quality of road works throughout Scotland.
• Another aspect is the priority services register which protects certain groups from having disruption to utility services such as heating and hot water, such as living with children under 5 years old.

Race

• There could be impacts to be considered for language and accessibility to the consultation document. To date in our continued stakeholder engagement, we have not identified any need for a translation to be provided. However, if anyone requests a translation, this can be included into our request from the digital team, APS.

Religion or Belief

• There are no impacts to be considered, other than ensuring access to religious buildings in the event of roadworks. As considered in other groups this would be covered under the roadworks legislation and overseen by the Scottish Road Works Commissioner to ensure the safe planning, coordination and quality of road works throughout Scotland. This will ensure safe access routes to all religious buildings.

Sexual Orientation / Gender Reassignment

• We must ensure we demonstrate inclusive engagement within our public consultation, through using gender inclusive language and writing in a way avoids indirect discrimination. Following the Scottish Government and APS guidelines.

Marriage and Civil Partnership

• There are no impacts to be considered.

We also discussed other groupings/topics and have listed below a summary of our findings:

Socio-Economic and Geographic Factors

• The challenge in this area would be related to the cost of building and connecting to heat networks, however this is not considered in scope as part of the installation and maintenance licence. Our findings for this assessment confirm there are no impacts to be considered.

Intersectionality

• Although no direct impacts were identified, we did acknowledge the cumulative impacts on some groups such as older, disabled people during roadworks and always ensuring accessibility such as ramps and ensuring areas are safe and barricaded appropriately. As considered in other groups this would be covered under the roadworks legislation and overseen by the Scottish Road Works Commissioner to ensure the safe planning, coordination and quality of road works throughout Scotland.

Consultation Accessibility

• We will ensure where required there is the provision of materials in accessible formats such as Easy Read, translations, BSL, etc and also ensuring there are digital and non-digital routes for participation. Scottish Government internal website has guidance for creating accessible communications for the public. APS have produced publishing guidelines to help ensure our communications are inclusive and accessible and can help with translations.

Mitigation and Monitoring

• Scottish Government policy officials will continue to engage with internal and external stakeholders to seek their input on the licensing regime to help shape policy design. This engagement will take place during the public consultation period (pre and post the election period in 2026) and beyond as we progress to introduce secondary legislation. Detailed mitigation will follow at secondary legislation stage.

Our findings from review of the Public Sector Equality Duty needs found that the installation and maintenance licence proposals do not have a direct immediate impact on people with the protected characteristics (under the Equality Act 2010). The proposals for the installation and maintenance licence detailed in the consultation document are limited to establishing a licensing regime which will grant rights and powers for things like roadworks, survey and compulsory purchase to those heat network organisations who choose to apply for a licence. None of these provisions are assessed as having an impact on people with protected characteristics.

Throughout our research we found there to be no gaps or limitations in the data or evidence gathered.