Pension Age Winter Heating Payment (PAWHP): consultation analysis

We are introducing Pension Age Winter Heating Payment (PAWHP) in winter 2024/25 as a like-for-like replacement for the UK Government’s Winter Fuel Payment. This report analyses the responses from the public consultation on PAWHP that ran between 23 October 2023 and 15 January 2024.

1. Introduction


The Scottish Government has committed to introducing the Pension Age Winter Heating Payment (PAWHP) in winter 2024/25. This will be a like-for-like replacement of the UK Government’s Winter Fuel Payment (WFP) which is administered by the Department for Work and Pensions (DWP).

PAWHP will form part of a suite of winter heating benefits delivered by Social Security Scotland, using provisions under Section 30 of the Social Security (Scotland) Act 2018 that authorise the Scottish Ministers to assist in helping an individual towards meet their heating costs during the winter months.

To ensure PAWHP is delivered safely and securely to over a million pension-age clients each winter, there has been a commitment that:

  • No one will lose out when the Scottish Government takes responsibility for PAWHP.
  • There are no plans to change the current eligibility criteria.
  • There are no plans to change the amount paid.
  • The payment will not be means tested or taxed.

The Scottish Government is also considering improvements that could be implemented before or after PAWHP launches and how it could be developed in the longer term.

A public consultation on PAWHP ran between 23 October 2023 and 15 January 2024. Containing 21 questions, the consultation aimed to gather views on the proposals for a like-for-like transfer of the benefit, the eligibility criteria, and the value, form and timing of the payment. The questions also explore whether the proposed approach meets the needs of those it is intended to help and the impact the policy might have on various groups, including those not on the gas grid.

The findings from the analysis will be used by the Scottish Government to:

  • Inform the drafting of PAWHP regulations, which will be scrutinised by the Scottish Commission on Social Security (SCoSS) before being laid in parliament.
  • Highlight and overcome any issues which need to be considered as part of the transfer to PAWHP.
  • Understand how PAWHP could be developed in the long term.

Respondent profile

In total, 906 consultation responses were received[1]. Almost all were submitted via the online consultation platform, Citizen Space. Those received in an alternative format, for example, an email or PDF document, were reviewed separately by the research team. Individuals provided 881 responses to the consultation, representing 97% of the total sample; the remaining 25 responses (3%) were from organisations. To aid analysis, organisations were grouped on the nature of their work, as shown below.

Sectoral Classification

Number of respondents % of total sample
Individuals 881 97
Organisations 25 3
Health / disability / age organisations 8 1
Poverty / fuel poverty organisations 5 1
Local authorities 3 <0.5
Miscellaneous organisations 9 1

Analysis approach

The Lines Between was commissioned to provide a robust, independent analysis of the responses to the public consultation. The main purpose of consultation analysis is to understand the full range of views expressed, and where possible using closed questions to quantify how many people held particular views. This report provides a thematic analysis of responses based on the analysis approach outlined below.

Quantitative analysis

The analysis of responses to each question begins with a summary of the closed question data illustrating the range of opinions held by respondents. As not all respondents answered each question, each table in this report shows the number and percentage of responses among those answering each question and broken down by individual and organisation responses and by organisation type. Please note that figures in the tables may not add to 100% due to rounding. A full breakdown of the number and percentage of responses to each question can be found in Appendix A.

Qualitative analysis

Qualitative analysis identifies the key themes across responses to each question. The research team developed a draft coding framework based on a review of the consultation questions and a sample of responses. During the coding process, new codes were created if additional themes emerged.

In a small number of instances where alternative format responses contained information that did not align with specific questions, analysts exercised judgment about the most relevant place to include this material for analysis purposes.

Where appropriate, quotes from a range of participants are included to illustrate key points and provide useful examples, insights and contextual information.

Reflecting the large number of people who took part, it is impossible to detail every response in this report; a few organisations shared lengthy submissions reflecting their specific subject matter expertise. These responses are referenced where possible. Full responses to the consultation, where permission for publication was granted, can be found on the Scottish Government’s consultation website.

When reviewing the analysis in this report, we would ask the reader to consider:

  • Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct or known interest. This self-selection means the views of respondents do not necessarily represent the views of the entire population.
  • Where differences between the views of individuals and organisations were evident in qualitative responses, these have been noted. If no specific differences are highlighted then a theme was raised by a mix of respondents, though the composition of the sample means the vast majority were typically individuals.
  • Some respondents have possibly not fully read or engaged with the consultation paper, leading to answers which do not directly address the questions, or comments which suggest respondents have misinterpreted the question or misunderstood the nature of the proposed changes. While all comments have been included in the analysis and all themes presented in this report, we focus on those directly answering each question.
  • Similarly, many respondents repeatedly raised the same issues or suggestions at multiple questions, regardless of the specific focus of the question. These views are all included in this report, but analysts exercised judgment about the most relevant place to include each theme to avoid repetition.
  • In a few instances, highlighted in the report, qualitative comments from individuals do not align with their response to the quantitative questions. For example, a respondent may agree in principle but use their open comment to caveat their agreement or suggest an alternative approach. Similarly, in Q9b, some respondents agreed with the proposed approach but left comments implying they disagreed.

Weight of opinion

This report presents the themes identified in responses from most to least commonly mentioned. All themes, including views shared by small numbers of respondents, are covered; an insightful view expressed by a very small number of participants is not given less weight than more general comments shared by a majority. Similarly, all responses have an equal weighting. We recognise this means a response from an individual has the same weight as the response from an organisation which may represent many members, but this approach ensures all views are presented.

Qualitative analysis of open-ended questions does not permit the quantification of results. However, to assist the reader in interpreting the findings, a framework is used to convey the most to least commonly identified themes in responses to each question:

  • The most common / second most common theme; the most frequently identified.
  • Many respondents; more than 50, another prevalent theme.
  • Several respondents; 30-49, a recurring theme.
  • Some respondents; 10-19, another theme.
  • A few / a small number of respondents; <10, a less commonly mentioned theme.
  • Two/one respondents; a singular comment or a view identified in two responses.



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