Tackling fuel poverty - periodic report 2021-2024: engagement responses

Organisations

Respondent: The Scottish Fuel Poverty Advisory Panel

Due to Scottish Government accessibility requirements and to ensure retention of the full content within their response, the Scottish Fuel Poverty Advisory Panel response can be found on their website.

Respondent: Energy Action Scotland

Fuel Poverty Strategy

The benchmark figures for fuel poverty in the Scotland of 2019 were 24% of households, in 2024 it is now 31 to 33% of households. Fuel poverty rates have changed significantly up and down as energy prices have increased and decreased during 2022-2024. Since 2018/19 there has been no revision of the local authority data for fuel poverty, but extrapolating Scotland level trends and increases fuel poverty rates across Scotland are likely to range for something in the region of 1 in 2 to 1 in 5 households in fuel poverty depending on geography and demographics.

[Image provided showing a map of fuel poverty by local authority was removed as it did not meet the accessibility requirements].

There are also many households in Scotland whose energy is unregulated because it is LPG, oil or solid fuel or provided by some other mechanism including heat networks.

In Scotland the current Energy Company Obligation spend is currently around 10-11% of rUK spend. If Scotland had secured a similar proportionate spend, as it did for Warm Home Discount, it is likely that investment would have fallen to 9.4% of GB totals.

Scottish Government identified in its actions that it would increase the take up of Area Based Schemes from 2021 onwards. Since 2021, in the three years of the Fuel Poverty Strategy there has been an underspend of 50%, money we fear will never be caught up.

Comment On Improving Access to Affordable Energy

Scottish Government has continued to lobby for change and has engaged with charities and other organisations to influence the UK government in areas that are reserved.

There are currently no significant beneficial changes to the UK energy market that are benefiting households in Scotland.

Households with electric heating experience the relatively highest bills to heat their homes and are still most likely to be in fuel poverty.

During the peak of the cost-of-living crisis, third sector organisations arguably did more to promote the efficient use of heating systems than government funded programmes. Many were out in their communities ensuring that people understood how to maximise the energy efficiency of their heating systems producing materials and communicating in local media outlets.

The imminent radio teleswitch remains a significant issue affecting more than 200,000 households in Scotland with electric heating and there is the possibility that we will lose Scotland specific tariffs to be replaced by Economy 10 and Economy 7 tariffs which for many households creates the potential for additional detriment.

Scottish Government has expressed strongly its desire for there to be a lower cost tariff option of those households in greatest need. This is a position supported by charities working across Scotland indeed across the GB. However, there remains no social tariff to support the lowest income households or vulnerable households to access fundamentally lower cost energy to support their health and wellbeing. In the absence of such an option fuel poverty rates are unlikely to fall significantly.

Energy companies continue to direct struggling customers to advice and support services, adding to the workload of third sector support organisations. Advice service additionally burdened with higher operating costs as a result of the UK Government’s decision to increase Employers National Insurance in its budget of October 2024. Energy suppliers continue to provide a low level of customer satisfaction and performance, they continue to fail to provide specialist staff who can resolve issues. This results in wasted hours of third sector staff time and provides additional stress for those seeking help. Energy company call centre staff often won’t accept mandates from housing providers to speak on behalf of their clients and they continue to push people with no internet access online for help and AI chat bots.

There has been a notable lack of education for tenants on new technical equipment installed in the home. New tariffs are inaccessible where there is no smart meter signal, yet housing providers win awards for their installation despite the fact that people are colder and poorer as a result.

At UK level there has been an equalisation of costs between direct debit households and prepayment meter households which has resulted in improvements for prepayment meter households, however tempered by much higher energy costs generally. Ofgem publishes data which shows that prepayment metre household self-disconnection has been increasing.

It says notable in the Fuel Poverty Strategy but there is little emphasis or recognition of the additional challenges faced by disabled people or people who have essential medical equipment at home. [see Alliance contribution]

It is positive that the Heat In Buildings Strategy and related legislation remains in process. This has the potential, if done well, to support people out of fuel poverty. However, both the Heat And Buildings Strategy and the Fuel Poverty Strategy have potential for conflict. There are targets to be met for NetZero by 2045 and there are fuel poverty targets to be met by 2040. It remains unclear how these targets work together.

The continuing failure of the energy industry to install and maintain smart meter at scale and pace is making life difficult for households and housing providers alike.

• Installations are rife with issues which the household is expected to rectify at their own cost
• Some households require several meter changes because of repeated technical faults and installation errors
• Many remote/ rural households have been waiting months and even years for faulty or old meters to be replaced and cannot access affordable tariffs during this time
• Energy companies can make housing providers wait for many months before a meter is ‘wiped down’ ready for a new tenant, particularly where debt has been accrued by a previous tenant. The provider bears the cost of the empty unit which is fit for habitation.

Dual metering is not included in the price cap and forces households to pay two daily standing charges for electricity which means they face charge of over £1.20 per day in comparison to £0.90 per day for a gas and electric household. For those that qualify for a Warm Home Discount payment from a supplier it means that through charges they are contributing £32 to receive a £150 payment in comparison to a gas household in receipt contributing £16 as the social levy is applied to electric accounts.

Topping up pre-payment meters is increasingly challenging in remote/rural areas where post offices and pay points are closing down and public transport services are reduced and expensive.

Comment On Targeting of Support

The Fuel Poverty Strategy has not resulted in better targeting of support to fuel poor households. When Scottish Government provided funding, but it did not seek to provide that in an equitable manner with proper targeting and/ or scaled support reflective of the circumstances of individual households. Funding was typically provided on a universal basis with no adjustment for the factors that affect fuel poverty ranging from heating type, to the needs of households that may have necessitated being warmer for longer consistent with the Enhanced Heating Regime identified in the Fuel Poverty Act.

The Scottish Government strategy in 2021 identified changes that would be made to the Cold Weather Payment system. In 2022 a new payment was created, The Winter Heating Payment, which now makes a £50 (annual uprated) payment to eligible households, a replacement for the previous £25 per week payment for each week of cold weather extremely cold weather.

Changing this payment has introduced disadvantage to households that previously received higher payments in periods of extreme weather. There was no mitigation provided to support those households in those locations, where extreme weather was most common, that now miss out.

UK Government decision continues to have huge impacts on households already in fuel poverty in Scotland. The removal of the budget associated with the Winter Fuel Payment, to be rolled out in Scotland as the Pension Age Winter Heating Payment, will potentially affect over 800,000 households of older people in Scotland. Almost 250,000 of these pensioners are on very low incomes, many should but are not in receipt of Pension Credit. The loss of income to these households during winter 24/25 will push many households into poverty or deeper into fuel poverty than before. Health colleagues tell us that it is likely that during the winter months as older people are now less likely to be able to their heat their homes to the level they have in the past this will result in more GP visits, potentially more unplanned hospital admissions and avoidable winter deaths.

It is disappointing that no impact analysis has been completed to understand the effect of the removal of this funding in the UK or in Scotland.

The end of the Home Heating Fund delivered by housing associations, which was not replaced by anything similar, has had a huge impact on both households and those organisations who support them.

Increased digitisation is a real barrier to many people. People tend to access help and support locally.

Comment On Raising Income

It should be recognised that to reduce fuel poverty as measured for the fuel poverty metric it matters how resources are applied. Rising energy costs have had a significant impact, increasing fuel poverty. Therefore, raising income does less for the fuel poverty metric than reducing consumption or reducing the cost of energy. Both are necessary given the increasing gap between income and energy affordability progress in reducing fuel poverty requires careful consideration in the distribution and application of public funds.

Raising income is an important part of the solution to reduce fuel poverty. The introduction of the Child Winter Heating Assistance is welcome. This payment does support households who have additional needs as a consequence of disability. However, the additional funds available to disabled households do not go far enough to support those households with the additional costs associated with disability and the energy consumption requirements within that.

The fuel poverty strategy identified a number of areas where Scottish Government was supporting households. Since 2021 there have been other changes, including to income tax and its is unclear what impact that this has had on fuel poverty when it clearly affects household income. It is important to understand the impacts that this policy change has had.

Energy Industry spending to support low income households through the Warm Home Discount spending in Scotland is now lower than it was in 2019. The number of eligible households has remained relatively static however the allocation of funding is significantly lower now than it was in 2019/20. Scotland now secures 9.4% of GB spending with us, prior to this Scotland secured in the region 12-13% of GB spending. This is a direct result of the divergence of approach for delivery across GB introduced by the UK Government which allocated budget on a electricity metering proportion basis rather than a social need basis. Scotland did not have equivalent data.

In a Fuel Poverty Strategy the Scottish Government indicated that more housing would be built to much higher standards. It isn't clear what impact there has been on housing as a consequence of falling budgets Scottish Government indicated the 110,000 houses would be complete by 2032. It is not clear what progress has been made in meeting this target nor what consequential impact there has been on fuel poverty.

Comment On Advice And Support

Energy Action Scotland members tell us that they have been overwhelmed by calls from the public for help. Other members are helping thousands of people every single week they are doing more with the same for more for less in real terms as the cost of living has impacted on charities and organisations alike.

It is fair to see the awareness of services has increased. It would be surprising if awareness of Home Energy Scotland and of Advice Direct Scotland and of Citizens Advice Scotland and indeed of Energy Action Scotland has not increased with the public.

Charities have been on the frontline of providing support information and advice to the public across the cost of living crisis and previously during COVID-19.

Fuel poverty now effects between 800 - 900,000 households. Fuel poverty is not significantly falling, it is and has been increasing.

Energy prices are the single biggest factor affecting the number of households in fuel poverty. High energy costs look set to remain.

Each year Energy Action Scotland has helped to brief or train over 350 frontline workers helping people with their issues we also have helped train 150 to 200 people to gain City and Guilds qualifications. Our members report that turnover in advisers has increased with staff members feeling overwhelmed by demand and by the limited ability to help those in need.

Hillcrest Housing Association have 3.5 FTE advisers and the financial gains for tenants in 2023/24 was £1.38 million.

AliEnergy cover the Highlands and Argyll & Bute.

Year	FTE	Staff Costs	No. of Cases	Client Gains (estimated)
2021-22	5	£279,963	1,378	£200-250k
2023-24	9	£523,736	2,586	£1.2-£1.5m
2024-25	9	£517,152	1,004 to end of Oct	~£500k up to end of Oct

During the same time there has been a loss of capacity across the advice sector. There have been cuts to Community Link Workers in primary care practices which were a vital route for some households.

There have been some positive pilot work, the Energy System Catapult for example. Yet winter deaths in 2022 to 2023 were a 30 year high.

The Scottish Welfare Fund could work better on the efficiency of goods that that it provides to households. That means it currently remains the only significant source of crisis funding available to support people with their energy bills following the removal of the funds from the Fuel Insecurity Fund.

There are significant household deficits which are not recognised in our fuel poverty statistics or story.

Households energy debt in Scotland has been rising. A GB level there is £3.7 billion worth of domestic energy debt, the Scotland share of the debt is likely to be in the region of £400 million This is unlikely to be the full level of energy debt as it does not recognise debt that may exist in the unregulated energy market for households with alternative energy for heating or those with debts to other third party energy providers. Energy debt keeps people in fuel poverty and must be tackled. It is also important to note that emergency credit on prepayment meters (which must be repaid) is not included in the debt figures which further emphasises the under estimating nature of debt figures.

There are significant household deficits which are not recognised in our fuel poverty statistics or story.

Crisis support (like the Fuel Insecurity Fund) is a vital part of a strategy as is longer term support to identify the causes of fuel insecurity and move a household out of the crisis cycle. It also vital to acknowledge that another energy crisis could occur and that a plan must exist to ensure that people’s health and wellbeing is protected. Particularly now that all existing safety nets have now been removed.

It is still vital to provide basic energy goods to support struggling or fuel poor households. These include items like radiator foils but also personal items like duvets.

People are finding that their smart meter has reversed without their knowledge and is now a prepayment meter meaning that they can return home and find that they have no energy. Energy companies then inform people they must download an app where often a household has neither a smartphone nor Wi-Fi access.

Comment On Monitoring

The Scottish House Condition Survey is a vital annual report that provides information on the progress being made across housing and with special regard to fuel poverty. However it has not been produced in a consistent since 2019. There has been no local authority data available since 2019. It also important to note that survey does not contain any aspects that would reflect the additional energy needs of some households to sustain life. It focuses on warmth and a small allowance for a typical households domestic appliance needs rather than all/ holistic energy requirements.

Energy Performance Certificate reform has yet to yield any changes that can improve the way in which households might be prioritised for help but there is a general misalignment of dates for changes and consultations. It can be difficult to understand the consequential and potentially unintended consequences when the whole picture is not available.

Comments on the Cost of Living

It is important to note that for young people living alone, on Universal Credit of £80 per week, their daily standing charge is £8 per week

Who will deliver for Scottish Government? Third sector organisations are currently undertaking the work but constantly seeking funding to continue to deliver. Local authorities funding is increasingly threatened yet they still rely on the third sector to deliver services

Comments on Home at the Centre of Wellbeing

Remote/ rural resident wanted a HES grant and loan but couldn’t use a local plumber who was not on accredited list therefore EST wouldn’t allow this as they only recommend tradespeople from the central belt none of whom could schedule the work for many months

‘NetZero versus fuel poverty’ is still a huge issue and there are practical examples of where the inherent conflict can be seen.

Installing heat pumps without retrofit – some social landlords are no longer installing them because while this decision is detrimental to their achievement of the Energy Efficiency in Social Housing Standards (which doesn’t care about affordability, comfort or wellbeing) they are better for tenants.

Hillcrest Housing Association based in Dundee was the UK’s third largest builder of new social housing last year. They recently undertook a £1.2million retrofit project in Cairnie, Arbroath.

Using match funding from Social Housing Net Zero Heat Fund from Scottish Government, 23 homes have been provided with:

• Full external wall insulation
• Triple glazing
• Solar PV panels
• Storage battery
• Air source heat pump
• Air Quality environment sensors

Respondent: Health and Social Care Alliance Scotland (the ALLIANCE)

Barriers facing disabled people and people living with long term conditions in terms of being able to heat their homes.

Higher energy bills are one of the many additional costs facing disabled people and people living with long term conditions. The exact reasons for higher energy consumption vary from person to person, but can include difficulty keeping themselves warm due to their condition, the need to operate assistive or life-sustaining equipment, and to keep medication at safe temperatures. This expenditure is not optional, and therefore fuel poverty is a serious threat to their health and wellbeing.

In 2022, the Health and Social Care Alliance Scotland (the ALLIANCE) published our ‘Disabled People, Unpaid Carers and the Cost of Living Crisis’ report.^[1] Through surveys and direct engagement with disabled people, people living with long term conditions, and unpaid carers, we heard about some of the specific challenges people were facing at the beginning of the crisis.

One respondent explained that it took many hours to charge their powered wheelchairs and their bath raiser, but that they could not manage without them. Another participant said they were charging their powered wheelchair less often and thus leaving home less often, and explicitly identified this as negatively impacting on their human right to equal participation in society.

Others noted the impact of the cold on their conditions, such as worsening chronic pain. Some people were cutting back on food too, in some cases prioritising children or someone they cared for over themselves. Participants who represented third sector organisations said they had experienced a notable increase in people contacting them seeking food bank referrals.

Although energy bills are now well below their peak, they remain significantly higher than they were before the cost of living crisis. This is especially true for households that already had higher energy bills, who are hit hardest by increases. As such, the challenges identified above continue to impact many disabled people and people living with long term conditions.

Impact of actions taken by Scottish Government since 2021.

The ALLIANCE have repeatedly expressed concerns, including in our 2022 report and in our response to the Council Tax freeze in the 2024-25 Scottish budget^[2], that some of the Scottish Government’s direct reactions to the cost of living crisis were poorly targeted. Choosing to deliver cost of living support through the Council Tax system, through the £150 rebate to all Band D households and the freeze, meant that significant sums were made available to people who didn’t have as much need of them, whilst proving inadequate to fully support those who did.

We noted that for the same initially estimated cost as the Council Tax freeze, the Scottish Government could have funded a targeted payment of nearly £200 to anybody receiving any disability, carer or energy social security payments. This would have offered a higher level of support to all households who qualified for the payment (approximately £130 on average for Band D), relative to an anticipated 5% increase in Council Tax that the freeze was modelled against.

Given that the largest component of the cost of living crisis was the increase in energy bills, it was disappointing that the Scottish Government did not target emergency interventions at those likely to be facing the highest bills and thus at greatest risk of fuel poverty. The impact of these interventions in terms of reducing or alleviating fuel poverty will therefore have been relatively limited. As such, we would argue that these decisions were not in line with the Scottish Government’s commitments under the Fuel Poverty Strategy.

Contact.

[Redacted]

Alliance Scotland Website

About the ALLIANCE.

The Health and Social Care Alliance Scotland (the ALLIANCE) is the national third sector intermediary for health and social care, bringing together a diverse range of people and organisations who share our vision, which is a Scotland where everyone has a strong voice and enjoys their right to live well with dignity and respect.

We are a strategic partner of the Scottish Government and have close working relationships with many NHS Boards, academic institutions and key organisations spanning health, social care, housing and digital technology.

Our purpose is to improve the wellbeing of people and communities across Scotland. We bring together the expertise of people with lived experience, the third sector, and organisations across health and social care to inform policy, practice and service delivery. Together our voice is stronger and we use it to make meaningful change at the local and national level.

The ALLIANCE has a strong and diverse membership of over 3,600 organisations and individuals. Our broad range of programmes and activities deliver support, research and policy development, digital innovation and knowledge sharing. We manage funding and spotlight innovative projects; working with our members and partners to ensure lived experience and third sector expertise is listened to and acted upon by informing national policy and campaigns, and putting people at the centre of designing support and services.

We aim to:

• Ensure disabled people, people with long term conditions and unpaid carers voices, expertise and rights drive policy and sit at the heart of design, delivery and improvement of support and services.
• Support transformational change that works with individual and community assets, helping people to live well, supporting human rights, self management, co-production and independent living.
• Champion and support the third sector as a vital strategic and delivery partner, and foster cross-sector understanding and partnership.

Respondent: Existing Homes Alliance

Introduction

The Fuel Poverty Act 2019 set targets and reporting requirements whereby the Scottish Government is required to publish three-year periodic reports on progress.

The Scottish Government is currently consulting with a limited number of stakeholders to inform the forthcoming first periodic report. Although the Existing Homes Alliance has not been invited to submit a view, we are submitting this paper as we believe we have significant expertise to offer, and as one of the main external stakeholders involved with the passage of the Fuel Poverty Act in 2019, we have a strong interest in its successful implementation.

The Scottish Government is seeking views on the effectiveness of actions set out in the Fuel Poverty Strategy and areas where further action is required. Since the publication of the strategy, fuel poverty rates have been rising, making meeting the statutory targets even more challenging. This review must respond to that situation by redoubling efforts in devolved areas.

On reviewing progress, we do not believe that the Scottish Government has fully utilised all of the levers at its disposal to tackle fuel poverty.

We acknowledge the impact of the UK Government’s decision to end universal Winter Fuel Payments on the Scottish Government’s budget. The Alliance recently wrote to the Cabinet Secretary for Social Justice suggesting that the Scottish Government could use its fuel poverty programmes to, at least in part, offset the impact of this decision for those most in need.

Although the operating environment is challenging, with some of the drivers of fuel poverty sitting out with the control of the Scottish Parliament, the Scottish Government could and should be doing more to tackle poor energy efficiency as a driver of fuel poverty. This driver is the focus for the Existing Home Alliance, which argues for improved energy efficiency of Scotland’s housing stock to tackle both fuel poverty and climate change.

Therefore, our submission focuses on the effectiveness of the Strategy actions in addressing the poor energy efficiency driver of fuel poverty and identifies further actions required by the Scottish Government to reduce/mitigate fuel poverty in Scotland.

The actions to tackle poor energy efficiency as set out in the Fuel Poverty Strategy can be summarised as:

• Continue to support fuel poor households through fuel poverty and energy efficiency programmes - Warmer Homes Scotland (WHS) and Area Based Schemes (ABS); and
• Consult on, develop and introduce regulations to improve the energy efficiency of homes.

We believe that insufficient progress has been made in tackling poor energy efficiency as a driver of fuel poverty and the Scottish Government must take the following actions as a matter of urgency to address poor energy efficiency as a driver of fuel poverty:

• Provide adequate resource to advice services, including the protection of Home Energy Scotland advice services, with increased awareness raising to ensure those in need are able to access support.
• Protect and scale up fuel poverty programmes (Warmer Homes Scotland and Area Based Schemes) so they get closer to meeting the scale of need.
• Ensure ECO funding is being maximised in Scotland by facilitating information sharing.
• Introduce a Heat in Buildings Bill with clear minimum energy efficiency standards to reduce energy demand in homes;
• Include in the Bill a requirement that the regulations contribute to meeting fuel poverty targets and is overseen by the Fuel Poverty Advisory Panel.

Effectiveness of Scottish Government fuel poverty and energy efficiency programmes in tackling poor energy efficiency

Scotland has excellent fuel poverty programmes that have been the envy of other parts of the UK and Europe. While funding for these schemes has been largely protected over a period of financial pressure, the programmes still do not fulfil their potential for a variety of reasons.

The Existing Homes Alliance carried out a rapid review^[3] of Warmer Homes Scotland, Area Based Schemes and the Social Housing Net Zero Heat Fund in 2023. The review identified strengths and areas for improvement.

Warmer Homes Scotland

WHS is widely believed to be a highly successful programme that enables vulnerable households to benefit from measures to tackle fuel poverty. In some areas it is used to augment ABS projects, expanding the reach of the programmes and creating economies of scale.

WHS delivers projects effectively across the whole country and the widened eligibility criteria introduced in 2023 have been welcomed, with stakeholders identifying that households who were formerly on the margins of eligibility are now eligible for support. It was, however identified through this research that some households may still fall through the cracks, for example parents with shared custody of a child.

One of the reasons for the success of the programme is felt to be its simplicity – the focus on individual households means there are none of the complexities that come with multi-property programmes. It was, however, recognised by some that this could mean some opportunities for efficiency could be missed. For example, there may be opportunities for contractors to identify neighbouring households that could benefit from similar measures.

Whilst WHS clearly contributes to tackling energy efficiency as a driver of fuel poverty, it is recognised that tackling energy efficiency alone does not insulate households from fuel poverty. However, as fuel prices increase, the benefits of improving energy efficiency, thereby reducing the amount of energy needed to heat the home, also increase.

Some stakeholders felt there was a lack of transparency historically, making it difficult to establish success in terms of outcomes for customers, citing a focus on reporting on outputs rather than outcomes. It was also suggested that a reliance on EPCs for establishing eligibility can potentially exclude households on the basis of information that is incorrect. It also underestimates the additional power requirements of people with disabilities (e.g. mobility aids, oxygen or dialysis machines) which risks excluding vulnerable households from the scheme.

The process for transitioning to the replacement scheme resulted in the programme being effectively closed for six months, meaning fuel poor households were not able to access the support they needed and resulting in a significant backlog that had to be addressed when the new programme commenced.

Warmer Homes is also widely perceived to be “a drop in the ocean” compared to overall need. There is a widespread view that the programme could be relatively easily scaled up, and that with certainty of funding, industry would respond to ensure sufficient supply chain capacity.

Recommended areas for improvement in EHA Rapid Review (2023):

• Increase the scale of the programme – the review found that the WHS works and is transforming lives, but the current scale is insufficient to meet demand.
• The programme could be improved by greater awareness raising and ensuring a reliable pipeline of work through a more responsive and flexible approach to marketing.
• There are opportunities to create efficiencies by enabling installers to generate demand and deliver small area-based projects, particularly in remote, rural or island locations.
• Ensure greater transparency, along with a focus on regional performance and achieving outcomes within performance monitoring and reporting.

Since the review was published, there have been improvements in the marketing of the scheme, however demand has increased significantly and there is now a very real risk of the programme being effectively closed to new applicants due to insufficient resources to meet demand.

Indications are that the funding for 2024/25 has, in effect, been spent, just as we enter the winter months. There is now a risk of fuel poor households being left without working or effective heating over the coldest period of the year.

In addition to impacting on fuel poor households, the effect of this lack of funding will be that installers will be required to lay off staff due to lack of work. This, at a time when we should be supporting installers to grow their businesses to ensure we have the workforce required to upgrade Scotland’s homes to be net zero by 2045.

On the one hand, the Scottish Government is seeking to support supply chain growth by funding training, and on the other hand it is removal the pipeline of work.

Area Based Schemes

Our rapid review found that the ABS programme is successfully removing energy efficiency as a driver of fuel poverty for those who participate in the scheme. Case studies and anecdotal evidence show that households that have participated in ABS projects benefit from warmer homes, lower bills, as well as better physical and mental wellbeing and greater satisfaction with their neighbourhood.

One of the reasons cited for the success of the programme is its longevity – it has essentially been a 10-year programme and skills and knowledge have grown over that time which should, in theory, result in more efficient delivery of the programme.

It is widely believed that ABS is the right approach, but that there are issues with process and practice that must be addressed in order for it to be as effective as possible.

Analysis of ABS funding allocations and spend^[4] shows that, since its launch, the overall ABS budget has largely been spent, with minimal underspends of less than 3%. However, what is clear from the analysis is that some parts of the country are spending their full allocation and are indeed able to absorb underspend from elsewhere, whereas some local authorities have consistently been underspending their allocations. Some of these underspending council areas have high levels of fuel poverty, but even those with relatively lower levels of fuel poverty at a local authority level, have known pockets of deprivation and hardship, where households could be benefiting from lower bills and warmer, healthier homes.

Some stakeholders identified gaps in data which means that we are reliant on anecdotal evidence. There is a perception that, while some local authorities target areas most in need, others may focus on areas where they have a lot of stock, to support their own capital programmes. While often these areas will overlap with areas of high fuel poverty, there is a risk that areas without council stock, but with high levels of fuel poverty and deprivation, will be left behind.

This lack of consistency in terms of approach and levels of expenditure is potentially being exacerbated by a lack of coordination and oversight at a national level. There appears to be relatively limited opportunities for sharing expertise and learning from those performing well.

It was also noted by a number of stakeholders that, even though homeowners can access interest free loans via HES to participate in an ABS scheme, the scale of contribution from owners towards the cost of works can be prohibitive for some, resulting in homeowners who are at risk of fuel poverty being unable to take part – which can make the scheme itself not viable.

While the Fuel Poverty Strategy includes an action to increase the number of ‘whole house’ retrofits to fuel poor households and adopt a ‘zero emissions heating first’ approach, anecdotal evidence suggests that the majority of ABS projects remain focused on single measure interventions, largely external wall insulation (EWI).

This means opportunities are being missed to minimise disruption and install clean heating solutions at the same time as the energy efficiency works are being carried out.

One of the biggest barriers to the ABS programme fulfilling its potential is the short-term nature of funding. The current annual approach means that funding allocations are usually announced in early summer (in 2024 programme budgets were not confirmed until September) with a requirement to spend by the end of the same financial year. Projects then need to be procured, leaving a short window for actual delivery – which coincides with winter and associated weather risks for delivery.

The Scottish Government has indicated that there would be a move to longer term funding arrangements and in February 2023 agreed in principle to publish three-year ABS funding assumptions, however this has not come to fruition. This is not just a barrier, but a huge missed opportunity to give industry some longer term certainty, enabling businesses to invest in training, skills and scaling up.

Recommended areas for improvement:

• Ensure early visibility of multi-year funding allocation to enable longer-term strategic planning by local authorities.
• Facilitate collaborative procurement and longer-term relationships with supply chains to encourage investment in growth and skills.
• Strengthen performance monitoring, incentivise strong performance and facilitate sharing of best practice and lessons learned, to address the issue of underperforming local authorities.
• Ensure local authorities are clear about which costs are eligible for ABS funding, in particular in relation to enabling costs such as loft clearance.

Energy Company Obligation (ECO)

There is a risk that ECO funding is not being maximised in Scotland, due to ECO rule changes and confusion regarding the extent to which it can be blended with other funding (e.g. ABS).

Although in theory, blending of funding is still possible on a ‘whole house' project, ECO rules would require contractors to be ‘ECO approved’ and many SMEs do not have the capacity (or incentive) to seek this. These changes and the lack of certainty mean that ECO funding is being underutilised and energy companies are struggling to spend ECO in Scotland.

There is also a need to develop skills and training within the supply chain to ensure the quality and capability of ECO installers is improved.

Although ECO is not a Scottish Government programme, there are actions the Scottish Government could take to increase ECO spend in Scotland:

Recommended areas for improvement:

• Engage with energy companies and organisations that are effectively utilising ECO funding (such as Scarf, Wise Group and Energy Agency) to explore how ABS and ECO funding can work together to maximise the reach of area-based projects and plugs gaps in eligibility.

Developing and introducing regulations to tackle the poor energy efficiency of homes

The Fuel Poverty Strategy included a number of actions relating to the introduction of energy efficiency regulations, including:

• Introduce regulations requiring private rented sector properties to meet a minimum EPC C, where technically feasible and cost-effective, by 2028;
• Regulate for all buildings across all tenures to achieve a good level of energy efficiency by 2033 and use zero emissions heating by 2045.

The consultation on proposals for a Heat in Buildings Bill was published in November 2023, significantly later than anticipated, and the consultation analysis is yet to be published.

Although the Programme for Government for 2024/25 included a Heat in Buildings Bill, this has still not been introduced. The cost of these delays is continued uncertainty for homeowners, landlords, tenants and industry about the content and timetable for introduction.

It is now a matter of urgency that the Scottish Government introduces a Bill that clearly sets out a standard that will ensure that energy efficiency is no longer a driver of fuel poverty.

This must include private rented homes meeting at least EPC C equivalent by 2028 and all other homes meeting that standard by 2033.

While the key driver for the Heat in Buildings Bill is to reduce carbon emissions from heating, we believe that this legislation provides an important opportunity to help alleviate fuel poverty. Therefore we recommend that that Bill includes text that makes clear the regulations should contribute to the achievement of Scotland’s statutory fuel poverty targets. There is a similar provision in the Heat Networks (Scotland) Act. This provision would guide the design and implementation of the regulations including financial support and guidance, and the use of exemptions and cost caps.

We believe that there should be explicit consideration of the Bill’s contribution to meeting fuel poverty targets within the primary legislation and the Bill and implementation of the subsequent Act should be subject to scrutiny by the Scottish Fuel Poverty Advisory Panel.

We also believe that to ensure a just transition, the costs of upgrading homes to meet the new standard must be fully met for households in fuel poverty.

Conclusion

In conclusion, although many of the drivers of fuel poverty are out with the control of the Scottish Government, we do not believe that the Scottish Government has made full use of its powers and the policy levers at its disposal.

We urge the Scottish Government to take the following actions:

• Protect Home Energy Scotland advice services, with increased awareness raising to ensure those in need are able to access support.
• Protect and scale up fuel poverty programmes (Warmer Homes Scotland and Area Based Schemes) so they get closer to meeting the scale of need.
• Ensure the Area Based Scheme programme fulfils its potential, through multiyear funding and more effective performance management of programme.
• Ensure ECO funding is being maximised in Scotland by facilitating information sharing.
• Introduce a Heat in Buildings Bill with clear minimum energy efficiency standards to reduce energy demand in homes;
• Include in the Bill a requirement that the regulations contribute to meeting fuel poverty targets and is overseen by the Fuel Poverty Advisory Panel;

We are now at a critical point in life of the Fuel Poverty Strategy and the Scottish Government has difficult choices to make in the coming weeks. If the right decisions are made, Scotland can make substantial progress in ending the shame of fuel poverty.

However, if services are cut and fuel poverty programmes held back from meeting need, not only will thousands of households continue to unnecessarily suffer the health and wellbeing impacts of cold and damp homes, but opportunities for economic growth and the creating of green jobs will be squandered.

Respondent: Energy Saving Trust

What barriers or challenges might:

a) individuals who are living, or have lived, in fuel poverty,

b) disabled people,

c) people with long-term illness,

d) older people, and

e) individuals living in rural areas,

f) other protected characteristics (i.e. race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment)

currently face in Scotland in terms of being able to heat their homes according to their needs?”

There are a number of barriers or challenges that these groups might currently face in Scotland in terms of being able to heat their homes according to their needs. We note that the UK Government has recently published research that was undertaken on behalf of the Committee on Fuel Poverty and which provides useful evidence on the challenges that fuel poor households face when making decisions about consumption and as such might be of interest to the Scottish Government^[1] in the compilation of the periodic report.

In the context of responding to the questions in this engagement exercise Energy Saving Trust’s expertise relates particularly to barriers associated with people’s ability to afford their energy bills. These barriers are well documented, and Scottish Government data indicates that progress has been made on some of them over recent years. They include:

• Energy costs. Whilst inflation has fallen back from its peak in October 2022, households continue to experience the effects of rising prices and issues around energy affordability.
• When the energy price cap was set in October 2022, energy prices had almost doubled based on the same point the previous year. Despite falls in the price cap since then, average bills for typical annual consumption under the quarterly energy price cap from October 2024 are 38% higher than in winter 2021-22 (£1,717 and £1,248 respectively under new TDCVs (Typical Domestic Consumption Values))^[2]. The price cap is set to increase by a further 1.2% in January 2025.
• Fabric inefficiency. Energy inefficient homes require more energy to heat to a given temperature than energy efficient homes. While there continues to be welcome progress in the number of homes reaching a good level of energy efficiency in Scotland^[3] a substantial proportion of homes in Scotland do not achieve an EPC rating of C – 50% of homes in the PRS, 35% of homes in the social rented sector and 52% of owner occupied homes do not achieve this standard.
• Ability to use heating system efficiently. Where heating systems are not used efficiently this can result in more fuel being used than necessary to keep the home at a given temperature. Research shows that few people really understand their controls and many simply just don’t use them^[4]. We note that the Warmer Homes Scotland programme endeavours to ensure that people are able to use any new heating systems installed under the programme. However, the number of fuel poor households is considerably larger than the number of people who have benefitted from Warmer Homes Scotland and as such there will be many households who would benefit from additional support to help them use their heating systems more efficiently. Advice is provided to registered social landlord tenants by their housing office or specific energy advice service, whether internal or contracted to an outside advice provider to a greater or lesser extent depending on skills and capacity. Home Energy Scotland offers this advice to all tenures. It is hard to ascertain the extent to which advice is acted on by all members of the household or acted on over time/information retained. Capacity to retain and act on information is affected by mental health, mental ‘busy-ness’/bandwidth, language skills/accessible language and format.

Stress, anxiety and trauma impact the way people consume information and make decisions - it’s not only about getting advice, it’s also having the capability, and confidence, to use the advice.

• Lack of choice about heating system in some locations, building types and tenures. For a variety of reasons not all households are able to take advantage of heating systems that are more efficient and/or cheaper to run. This includes (but isn’t limited to) many flatted properties and homes in the private rented sector (as without the landlord’s permission the householder has no ability to change the heating system they are living with).
• Volatility of fuel oil and LPG prices which can make it extremely difficult for people to budget for their energy use.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty for:

a) disabled people,

b) people with long-term illness,

c) older people,

d) other protected characteristics (i.e race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment)

Why or why not? Please explain your answer.

In Energy Saving Trust’s opinion actions that have been undertaken by the Scottish Government since 2021 have helped to improve fuel poverty or helped to alleviate the impacts of fuel poverty for the groups outlined above. Below we provide a summary of the fuel poverty alleviation related activity that Energy Saving Trust has delivered on behalf of the Scottish Government and the impacts that this has had.

For any households identified as potentially fuel poor, Home Energy Scotland advisors will:

• Signpost to Department for Work and Pensions (DWP) for a benefit check, or signpost to Citizens Advice Scotland (CAS) for benefit check support.
• Support householders to ensure the tariff they are on is the most efficient and effective for their needs. For those who can manage switching themselves Home Energy Scotland show householders where to access Ofgem approved switching platforms. Those who need support are signposted to the resources of partners (e.g. CAS) to see the range of tariffs and options available.
• Help householders to access Warm Home Discount and refer householders for support from local agencies (e.g. Care and Repair), local in-home energy advice and advocacy services and for money advice.
• Refer householders to energy crisis support schemes where available. Referrals were made during 2022 and 2023 to Fuel Insecurity Fund funded support including Fuel Bank Foundation’s pre-payment meter voucher scheme, Fuel Bank Foundation’s HEAT fund (for non-standard heating crisis support), and the Advice Direct Scotland administered Home Heating Support Fund.

In 2022-3 there were 11,661 referrals and signposts from Home Energy Scotland for crisis support rising to 15,904 referrals and signposts in 2023-4. from Home Energy Scotland for crisis support.

Home Energy Scotland has provided support to people in several ways relevant to the needs of disabled people, those with long-term illness and older people.

We work with a number of partner organisations that work to specifically support these groups. Partnership working can take several forms, but the purpose is to encourage people who would benefit from the support Home Energy Scotland can provide to engage with the network.

The following are some examples of this work.

• Energy advice stands at flu clinics in partnership with NHS Lothian. These were targeted at the cohorts of vaccine recipients with the highest level of vulnerability and specifically included frail elderly people, those with chronic health conditions and disabled people.
• Attending information sessions being organised by support groups for their clients to tell them about the support we can provide and encourage them to engage with Home Energy Scotland. Partner organisations inviting us to deliver these events include Alzheimer Scotland, Food Banks, Fair Start Scotland providers and NHS organised events in several Health Board areas.
• Organisations using the online Home Energy Scotland referral portal to make direct referrals to Home Energy Scotland. In this context a referral means passing us the contact details of people seeking support for our advisors to contact them back. Between 1 April 2021 and 31 March 2024 more than 560 organisations used the referral portal to make referrals for more than 31,000 vulnerable people. Organisations specifically supporting people identified by the categories above who used the portal during this period include:
• Aberlour Family Support Service
• Age Scotland
• Alzheimer Scotland
• Barnardo’s
• Care and Repair
• Chest Heart and Stroke Scotland
• Children 1
• Community Links Workers (multiple local programmes)
• Deaf Action
• East Ayrshire Women’s Aid
• Maggie's Centre Aberdeen
• MECOPP (Minority Ethnic Carers of Older People)
• MND Scotland
• Parkinsons UK
• Penumbra
• Quarriers
• The Welcoming Association
• Visibility Scotland

Case studies which provide more information about Home Energy Scotland working in partnership with East Ayrshire Women’s Aid and MND Scotland can be found here: News and case studies | Home Energy Scotland.

Partner organisations are also able to take advantage of training provided by Home Energy Scotland to upskill their staff and volunteers in energy efficiency, heat pump and electric heating, and other home energy topics to better advise their clients and members.

Another significant area of Home Energy Scotland’s work that contributes to the support of the groups specified above is Warmer Homes Scotland referral. Home Energy Scotland is the only way for people to access Warmer Homes Scotland - this ensures that all applicants have received energy-saving advice, and can be re-contacted by Home Energy Scotland after any insulation or heating has been installed to give advice relevant to their changed situation.

The Warmer Homes Scotland programme began using revised criteria in April 2023. Between 2 April 2023 and 31 March 2024. The table below lists the main recorded benefit which conferred eligibility on people who didn’t meet the criteria requiring additional vulnerability.

Primary benefit	As %
Adult Disability Payment	13.96%
Personal Independence Payment (PIP)	10.40%
Attendance Allowance	8.01%
Universal Credit	8.01%
Council Tax Reduction (excl 25% discount, e.g., students or single persons)	5.87%
Child Tax Credit	5.35%
Carer’s Allowance	4.87%
Pension Credit - Guarantee - you will not be eligible if you receive only Pension Credit - Savings	4.55%
Income-related Employment and Support Allowance (ESA)	3.52%
Scottish Child Payment	3.43%
Constant Attendance Allowance	2.56%
Child Disability Payment	1.84%
Disability Living Allowance	1.46%
Employment and Support Allowance (ESA)	1.35%
Attendance Allowance - higher rate (£82.30/week)	1.12%
Disability living allowance - higher rate	0.99%
Industrial Injuries Disablement Benefits	0.97%
Working Tax Credit	0.80%
Attendance Allowance - lower rate (£55.10/week)	0.79%
Severe Disablement Allowance	0.78%
Housing Benefit	0.57%
Disability living allowance - lower/medium rate	0.27%
Income-based Jobseeker’s Allowance (JSA)	0.27%
Income Support	0.24%
War Pensions Mobility Supplement	0.11%
Child Disability Payment - Higher Rate	0.10%
Armed Forces Independence Payment	0.06%
Universal Credit (an amount for a child, housing costs, or childcare)	0.05%
Disability living allowance (under 16) - lower/medium rate	0.04%
Universal Credit (income in assessment period <= £1,260)	0.04%
Child Disability Payment - Lower or Medium Rate	0.03%
Disability living allowance (under 16) - higher rate	0.03%
Pension credit	0.03%
Attendance allowance (unspecified rate)	0.02%
New style jobseeker's allowance	0.01%
Working Tax Credit - S4 (income less than £18,165)	0.01%

Being aged 75 or over and having broken or no heating is also an eligible characteristic of a household and 22.69% of referrals were for people experiencing this circumstance.

Home Energy Scotland Energycarers also contribute to the support of the groups specified above. Home Energy Scotland Energycarers are specialist energy advisors who provide an enhanced level of handholding, advocacy and support, delivered through home visits or remotely, for very vulnerable households to help them achieve affordable warmth. The service is available to those with issues relating to physical or mental health, disability, family circumstances, low income and expensive heating. These audiences are more likely to be in fuel poverty and struggle to use the freephone service, website or email advice. To ensure that clients receive a high-quality service with a “whole house” approach, Energycarers have specific training for the energy efficiency assessment of properties, to enable them to model the impact of different measures on the comfort and affordability of the home heating. In some cases where the household cannot afford to heat the home to a ‘standard’ heating pattern, Energycarers focus on solutions to keep the main living space and person warm, rather than the entire home.

As part of enabling affordable warmth for these households, support includes helping them to deal with structural dampness, condensation and disrepair, including seeking funding for repair and improvement work, advice and support on dealing with fuel supplier issues and contacting and engaging other support agencies.

Home Energy Scotland works with local energy advice organisations, rather than displacing them, so it will always look to access support through local partner organisations before arranging a home visit. If no partner can help and a visit would be helpful, an Energycarer visits the householder, sometimes with a relative or carer present, to look at how their home uses energy and see what could be improved.

It is also worthwhile noting that:

• Home Energy Scotland uses Language Line Solutions to provide translation of written materials into different and formats (e.g. braille or large print) and to provide three-way telephone interpretation. Other local and specialist services are used as appropriate – e.g. Deaf Action; local advice services provided in BAME community settings.

• The Home Energy Scotland House Style Guide provides guidelines for tone of voice, punctuation, how to include links, abbreviations etc to make sure all our written communications are easily accessible.

• Energy Saving Trust endeavours to make the Home Energy Scotland website more accessible by using:

• Easier-to-read colours
• Larger fonts
• Plain English
• Keyboard only navigation

Our accessibility statement can be found here on the Home Energy Scotland website – as well as highlighting what we are doing to make the website more accessible the statement also highlights the sections of it that aren’t accessible and the action we are taking to tackle this.

The Scottish Government also funds Energy Saving Trust to deliver a number of other activities, some of which will have helped to improve fuel poverty or helped to alleviate the impacts of fuel poverty in the groups above, including:

• Providing an information and analysis service, based on the Home Analytics and HEED databases, to the Scottish Government, local authorities housing associations and community groups to help design energy efficiency projects to tackle fuel poverty and inform policy.
• Providing support to local authorities and housing associations to access ECO funding for fuel poverty projects. The Scottish Government funds Energy Saving Trust to work with local authorities and housing associations to help them take a strategic approach to sustainable energy and ensure that the sector takes full advantage of the opportunities provided by ECO, GBIS, SEG, Scottish Government programmes and other funding initiatives. The requirements for the Energy Efficiency Standard for Social Housing (EESSH) and the proposed Net Zero Standard for social housing continue to drive demand from social housing providers for advice on funding support to help achieve the required targets across their housing stock. This programme supports the unlocking of substantial amounts of funding for local authority and registered social landlord programmes, supporting works in all tenures, including the delivery of the ECO and GBIS Flex eligibility scheme by local authorities. The funding levered in by local authorities and registered social landlords which we worked with in 2022-23, was more than £2.9 million and in 2023-24 was almost £20million.
• Maintaining a website to engage with householders and promote energy and carbon saving actions including providing information on efficiency schemes and on improving the energy efficiency of homes and reducing fuel bills.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland) helped reduce the impact of the following drivers on fuel poverty in Scotland?:

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

Why or why not? Please explain your answers, making reference to which Scottish Government actions since 2021 you feel have been the most or least helpful in tackling each driver.

a) Poor energy efficiency?

In Energy Saving Trust’s opinion actions undertaken by Scottish Government since 2021 have helped reduce the impact of poor energy efficiency on fuel poverty in Scotland. The Scottish Government’s national (Warmer Homes Scotland) and local (Area Based Schemes) fuel poverty and energy efficiency programmes have improved the energy efficiency of a substantial number of homes in Scotland. As we note in our response to question 1 above there continues to be welcome progress in the number of homes reaching a good level of energy efficiency in Scotland^[5] - and fuel poverty programmes will have played a role in this progress.

b) High fuel prices?

In Energy Saving Trust’s opinion actions undertaken by the Scottish Government since 2021 have helped reduce the impact of high fuel prices on fuel poverty in Scotland. In terms of the action that Energy Saving Trust is funded by the Scottish Government to take in relation to helping to reduce the impact of high fuel prices on fuel poverty the most relevant work that Home Energy Scotland undertakes is referring householders to energy crisis support schemes where available. During 2022 and 2023 referrals were made to Fuel Insecurity Fund funded support including Fuel Bank Foundation’s pre-payment meter voucher scheme, Fuel Bank Foundation’s HEAT fund (for non-standard heating crisis support), and the Advice Direct Scotland administered Home Heating Support Fund.

In 2022-3 there were 11,661 referrals and signposts from Home Energy Scotland for crisis support rising to 15,904 referrals and signposts in 2023-4. from Home Energy Scotland for crisis support.

c) Low income?

In Energy Saving Trust’s opinion actions undertaken by the Scottish Government since 2021 have helped reduce the impact of low income on fuel poverty in Scotland. In terms of the action that Energy Saving Trust is funded by the Scottish Government to take in relation to helping to reduce the impact of low income on fuel poverty the most relevant work that Home Energy Scotland undertakes signposting householders to the Department for Work and Pensions for a benefit check or to Citizens Advice Scotland for benefit check support. Data for the number of householders that Home Energy Scotland has signposted for benefit checks over the last 3 years is as follows:

• 2021-22 - 8,151
• 2022-23 – 10,176
• 2023-24 – 17,799

We also note that the Scottish Government’s implementation of additional Winter Heating Payment benefits through Social Security Scotland for children/disabled/pension age households is welcome as it provides dependable support consistently to those eligible, without the need for a householder-driven application.

d) Inefficient use of heat in the home (household behaviour)?

In Energy Saving Trust’s opinion actions undertaken by the Scottish Government since 2021 have helped reduce the impact of inefficient use of heat in the home (household behaviour) on fuel poverty in Scotland. In terms of the action that Energy Saving Trust is funded by the Scottish Government to take in relation to helping to reduce the impact of inefficient use of heat in the home (household behaviour) on fuel poverty the most relevant work that Home Energy Scotland undertakes is the provision of behaviour change advice. Data for the number of householders that Home Energy Scotland has provided behaviour change advice to and the energy savings this has generated over the last 3 years is as follows:

2023-24

• Advice interactions: 489,080
• Estimated energy savings over lifetime (TWh): 3.46
• Estimated energy savings annually (GWh): 185

2022-23

• Advice interactions: 495,620
• Estimated energy savings over lifetime (TWh): 3.13
• Estimated energy savings annually (GWh): 232

2021-22

• Advice interactions: 424,083
• Estimated energy savings over lifetime (TWh): 2.67
• Estimated energy savings annually (GWh): 188

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

The further action that Energy Saving Trust thinks is required from the Scottish Government for the purposes of reducing/mitigating fuel poverty for vulnerable households in Scotland includes:

• Continuation of funding and support for retrofit insulation and heating through Warmer Homes Scotland.
• Continued support for the Home Energy Scotland advice network – to provide householders with an easy to access route to advice, retrofit funding and support. We also think that the provision of advice and support for retrofit insulation and heating should remain a crucial component of any funding provided to householders for these measures.
• There are opportunities for Social Security Scotland (SSS) to refer/signpost their clients to Home Energy Scotland for assessment for Warmer Homes Scotland. At present, when someone is awarded a Scottish state benefit no referral is made to Home Energy Scotland, though this is an ideal time to do so, as they are likely to be on benefits that would qualify them for Warmer Homes Scotland. Child Winter Heating Assistance, Child Disability Payment and the Low Income Winter Heating Assistance (LIWHA) benefit, are all administered by SSS. If SSS could identify and refer or signpost recipients of SSS-administered winter heating benefits (and others, e.g., Best Start Grant), to Home Energy Scotland for advice and support including assessment for Warmer Homes Scotland, this would help to ensure that those most in need of support are aware of what is available and are supported to access it.
• The Scottish Government should continue to encourage Ofgem and the UK Government to urgently implement solutions that address the cost of energy to consumers through UK Government policy levers and regulation.
• Ensuring that measures to tackle crisis situations – for example fuel vouchers and other forms of emergency credit (including schemes that pay suppliers directly) are only used in very limited situations and that Scottish Government action continues to focus on retrofit and behaviour change which will deliver long term energy bill savings for people in Scotland. We note that attempts to provide meaningful advice and support for long term solutions are sometimes lost in the process of meeting immediate need and Home Energy Scotland sees some households seeking financial support repeatedly without pursuing solutions to reduce wasted energy. Such solutions are not sustainable and do not address the root causes of fuel poverty.
• The Scottish Government should work with the UK Government and Ofgem to provide a single access point for ECO/GBIS so that Home Energy Scotland advisors could confidently check eligibility criteria and availability which would allow them to advise people to access these schemes where appropriate.
• The Scottish Government should continue to work to maximise the amount of ECO and GBIS funds that are spent in Scotland This should include working with the UK Government and Ofgem to ensure that ECO and GBIS can be used concurrently with Scottish Government funded programmes such as ABS and WHS. We note that there is likely to also be scope to increase the amount of ECO funding spent in Scotland.
• The Scottish Government should also continue to work constructively with Ofgem, the UK Government, Energy UK, energy suppliers and other stakeholders to ensure that as many RTS meters are replaced in advance of the RTS switch off. Replacement rates of RTS meters fall well short of the rates required to ensure that all RTS meters are replaced by June 20205 and there’s a considerable risk that this could cause additional hardship for many people in Scotland who are already living in fuel poverty and that it could push more people into fuel poverty.

Do you have any evidence or data in relation to your answers to the above questions that you are able to provide? If so, please outline below and provide direct links where possible.

The data that we have in relation to the answers to the above questions is included in the body of our responses to each question.

1 See: Understanding the challenges faced by fuel poor households

2 See: Summary of Changes to Energy Price Cap 1 October to 31 December 2024 (ofgem.gov.uk)

3 See: Heat in Buildings: Progress Report 2024

4 See: Understanding the challenges faced by fuel poor households

5 See: Heat in Buildings: Progress Report 2024

Respondent: MECOPP

What barriers or challenges might Gypsy/Travellers currently face in Scotland in terms of being able to heat their homes according to their needs?

The main barrier facing many in the community is affordability and financial issues when it comes to being able to heat their homes. For instance, for many members of the community, they do not have access to mains gas supplies. This is particularly prevalent for those living in rural areas. This can lead to the requirement for many to purchase gas cylinders which are often more expensive and can see higher fluctuations in price due to not being subject to the Ofgem energy price cap.

MECOPP also have supported members of the community who are reliant on fuel and energy cards which they normally purchase from site managers. There was an instance where members of the community were unable to purchase these during a holiday period and were left without energy during the winter^[5].

For some there are barriers in getting the necessary support due to barriers in accessing information. Some in the community have lower literacy levels and/or lower levels of digital access. This can be a significant barrier in accessing many of the support mechanisms available.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty for Gypsy/Travellers?

There has been improvement for some but not all members of the community.

Why or why not? Please explain your answer.

The strategy makes reference to the £20 million Gypsy/Traveller accommodation fund in chapter 3. This has led to some progress in improving the standards of some sites for members of the community in Scotland. Many of the sites have been in very poor conditions, below the minimum site standards and work by MECOPP has shown the poor standards and provided recommendations to improve these^[6]. Some issues that exist include issues with damp/mould in amenity blocks, which is directly related to fuel poverty issues. It is clear that while there will be some improvements for a small number of the community, much more needs to be done.

There is also a capacity issue for members of the community. While the Joint Scottish Government/COSLA Gypsy/Traveller strategy recognises the importance of provision of capacity, the amount of pitches available has reduced in recent years^[7]. This has included when sites have been redeveloped, and with lower capacity this means more members of the community being less able to access suitable accommodation needs. This means for some, there has been less avenues to escape from fuel poverty.

This is also dependent on the type of housing that members of the community inhabit. There will be differential impacts on those living in ‘brick and mortar’ housing to those living on sites for instance.

There have been some schemes that have provided some level of support to members of the community who both have awareness as well as access to them. This includes the Cash-First approach that has alleviated impacts slightly, as well as warm homes discounts and winter fuel grants. However, the impact of inflation on energy prices has blunted the impact of many of these schemes.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”) helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

Why or why not? Please explain your answers, making reference to which Scottish Government actions since 2021 you feel have been the most or least helpful in tackling each driver.

a) In terms of energy efficiency, for those living on sites that have not seen improvements, there has been very little difference. However, work taken on those areas which have had improvements funded by the Scottish Government has been welcome and has improved site standards and we would urge further capital spend to support improved standards at sites across Scotland.

b) Much of the focus of the strategy was the impact of sub-metering for many members of the Gypsy/Traveller community. However, due to gas cylinders not being subject to the Ofgem energy price cap, this has had no impact on those using gas cylinders for their heating and this has been extremely expensive for many during the Cost of Living Crisis.

c) As previously discussed, for members of the community, there has been some grants/benefits that have supported those in low incomes. This includes Cash-First, Winter Fuel Grants etc although as previously mentioned, the impact has been reduced particularly due to high energy prices.

d) We have no information on this.

What further action do feel is required from the Scottish Government for the purposes of reducing/mitigating fuel poverty for Gypsy/Travellers households in Scotland.

There needs to be more focus on individual needs depending on housing and fuel types and geographical area. Funding to upgrade heating systems would make a significant improvement, and this should be included alongside future work to improve the standards of sites. This should also look at how heating costs in particular can be reduced.

For those dependent on using gas cylinders, there must be recognition that the prices can be more variable and therefore more likely to suffer sudden increases in costs. There should be work to help ensure that they are maintained at affordable prices for the community.

There needs to be a focus on helping to improve household incomes, recognising the intersectional issues facing many members of the Gypsy/Traveller community.

Do you have any evidence or data in relation to your answers to the above questions that you are able to provide? If so, please outline below and provide direct links where possible.

2024 MECOPP Paper on Maintenance at Gypsy/Traveller sites with lived-experience as part of the evidence

2024 MECOPP Community Health Worker Service Report

Respondent: Tenants Together Scotland

Background to Tenants Together Scotland (TTS)

Tenants Together is a national network of tenants committed to empowering the tenants of today and tomorrow, ensuring their voices are heard and influence decisions within the Scottish social housing sector, to protect tenants’ rights and make a difference.

We believe in the power of working together and true collaboration runs through our organisation. We work in partnership with the Scottish Government and key decision makers, tenants, service users, RSLs and local authorities, across the sector, to achieve a collective goal – to improve the lives and wellbeing of tenants.

TTS Response for Fuel Poverty Report – Online meeting, Monday 14^th October 2024

Concern from TTS regarding a lack of clarity on the consultation and what stakeholders have been invited to give their views. Feels like a closed consultation and members of the public have not been able to feed into this.

What barriers or challenges might people living in fuel poverty currently face in Scotland in terms of being able to heat their homes according to their needs?

From a rural perspective and those in social housing a lack of insulation and suitable heating systems are a barrier, and where new heating systems going into uninsulated homes this is having a negative impact as people are being taken off the gas network and put onto an electric tariff which costs more and is putting people into fuel poverty.

Biggest challenge is the cost of energy, costs have gone up a lot compared to peoples income. We should not be talking about fuel poverty when energy companies are making so much money. More needs to be done to reinvest their profits back into schemes to promote energy efficiency.

One of the challenges is the difficulty in moving to a new energy supplier and the uncertainty of the whole system (feels like you are taking the risk), also costs more for those not on direct debit, lack of redress, power needs to be taken away from energy companies and the SG need through their policies and pressure on central Government to focus on the consumer. Tenants are confused by the role of Ofgem and there is need for them to explain more clearly how they support consumers.

Current confusion for tenants regarding winter payments has not helped people budget appropriately for the winter ahead. There are real concerns for many as we head into the winter period.

A Government that is not taking leadership on fuel poverty and achieving net zero is also a barrier. Tenants can’t afford to pay more rent to bring homes up to net zero, so who is going to fund this? There needs to be agreement on how this will be done and funded and Government needs to set a clear path to achieve fuel poverty targets that is costed.

What barriers or challenges might people living in rural areas currently face in Scotland in terms of being able to heat their homes according to their needs?

As above

What barriers or challenges might people with protected characteristics (i.e age, disability, race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment) currently face in Scotland in terms of being able to heat their homes according to their needs?

Disabled people and older people most affected by fuel poverty (see question 7). The homes they live in need more heating and those that have medical equipment use more energy. Inclusion Scotland research has confirmed this. Tenant representatives have heard of those who choose paying their rent and having food over heating their home. With the changes to the winter fuel payment some are missing out as they just miss the threshold of qualifying of this.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty for

a) People currently in fuel poverty?

b) People in fuel poverty in rural areas specifically?

c) protected characteristics (i.e age, disability, race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment)

Why or why not? Please explain your answer.

Feeling that more people across protected characteristics, those already in fuel poverty and in rural areas are now in extreme fuel poverty. People on low income but not on benefits need more support, this has the added consequence of penalising those who are working.

Need to get energy companies to fulfil their ECOs from their profits to reinvest in social housing this should be happening and isn’t.

Concerns from tenants on the push to decarbonise social housing and retrofitting of homes when general costs and energy costs are going up. Needs to be more leadership from the Scottish Government on this. Those in older social rented properties are worried that their landlord may seek to dispose of these homes. Needs to be a space to talk about these issues in an open and transparent way.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland) helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

Why or why not? Please explain your answers, making reference to which Scottish Government actions since 2021 you feel have been the most or least helpful in tackling each driver.

Feeling that the current Fuel Poverty Strategy isn’t a firm plan with evidence of where the money is coming from. Tenants would like to know the “How” – the actions in strategy are going to be achieved?

Many older types of social housing are not built in a way that would enable them to become more energy efficient. Government needs to focus on the current needs of those older and disabled people living in inappropriate housing rather than focussing on a net zero target.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

More needs to be done to reduce bills. More needs to be done to make pricing structures more easy to understand. UK and Scottish Government need to work together and there needs to be more powers for local authorities to support the most vulnerable in communities to provide winter payments that actually support people. Households need to have the powers to create their own energy. Example of Councils refusing to allow some property owners to add additional wind turbines

Social housing landlords need to be able to partner with energy companies to support tenants who may suffer from fuel poverty and make their homes more energy efficient. Examples were highlighted of the good work of Home Energy Scotland supporting tenants to save costs on their fuel bills. Social landlords should have more support from Government to tackle fuel poverty amongst their tenants as they are best placed to know those tenants who are in fuel poverty. Also encourage all social landlords to have income maximisation officers. Those tenants who are in fuel poverty should be prioritised for upgrades for new more energy efficient heating systems.

More also needs to be spent by the Scottish Government on the aids and adaptions budget for vulnerable tenants which social housing landlords get allocated as this has an impact on fuel poverty. For example, a lack of bathroom adaptations means having to bath rather than shower, unable to leave property due to unsuitable access to your home (no ramp) so unable to make use of lunch clubs or warm space.

Do you have any evidence or data in relation to your answers to the above questions that you are able to provide? If so, please outline below and provide direct links where possible.

Disabled People and Fuel Poverty

• Analysis by Scope in 2018 – before the recent huge rise in energy costs – suggested that 4.1 million households containing disabled people spent over £1,500 a year on energy.
• In comparison, at that time. the average UK household spent £1,200.
• Of these, 790,000 spent over £2,500 a year, over double the average household spend.
• The Health, Disability and the Energy Crisis report, based on a YouGov survey commissioned by Consumer Scotland, found that:
• 52% of Scots disabled people reported that they were unable to heat their homes to a comfortable level compared with 36% of non-disabled people.
• 47% of Scots disabled people reported that they were struggling to keep up with their energy bills compared with 29% of non-disabled people.
• 47% of Scots disabled people reported that they had cut back on food compared with 32% of non-disabled people.
• 72% of Scots disabled people reported the energy crisis had an impact on their mental health compared with 64% of non-disabled people.
• 68% also said the energy crisis was having an impact on their physical health compared with 54% of non-disabled people.

Medical equipment costs

• Many disabled people use medical equipment – ventilators, oxygen concentrators, dialysis machines or other devices – to manage their condition and symptoms at home.
• Compared to an average household, powering these devices alone might add anywhere from 13% to 32% onto the cost of an average energy bill.
• Research by Marie Curie (in England and Wales) found that a person’s energy bill can increase by as much as 75% after a terminal illness diagnosis.
• This means that many terminally ill people were paying as much as £3,500 pa for energy last year.
• Research by Children’s Hospices Across Scotland showed that families with terminally ill children faced similar costs in Scotland.
• As a consequence 90,000 terminally ill people died in poverty last year.

Some Solutions

• Take-up: Benefits, money and fuel poverty advice in health settings & schools – particularly “special schools” for those with ASN should become standard and receive long term, secure funding.
• Additional investment in social housing. High rents in the private rented sector and higher mortgage costs means that there’s an even greater need for good quality, accessible, energy-efficient housing which is genuinely affordable.
• Increase the Winter Heating Payment to £100. The advantages are that no separate claim would have to be made and over half of the 400,000 eligible households contain a disabled adult and/or child.
• Implement and roll-out the Warm Homes’ Prescription model. As a preventative measure this would protect disabled people’s health and prevent them from being hospitalised at great expense to the NHS and risk to themselves.
• Meet the fuel costs of those using medical equipment at home.

Inclusion Scotland (1/4/24)

Respondent: The Wise Group

What barriers or challenges might people living with long term illness currently face in Scotland in terms of being able to heat their homes according to their needs?

Reduced household income: Long-term illness can lead to an inability to work therefore making it difficult to afford the necessary fuel costs.

Families where a member has a long-term illness and is unable to work often face the arduous task of covering significant bills pertaining to their overall health, while simultaneously grappling with the continually escalating fuel costs.

We see customers where their health has depreciated as a result of rising fuel prices, placing additional strain on families already struggling due to lost income and increased healthcare expenses. Living in cold homes, unable to afford fuel costs, leads to stressful circumstances, worsens health conditions, and causes individuals to cut back on essential needs, including food and medical equipment.

High energy costs: Individuals with long-term illnesses often face increased heating needs, making them more vulnerable to the rising costs of energy, leading to higher utility bills that they may struggle to pay.

Maintaining a warmer home is frequently a medical necessity for those with certain chronic conditions. As energy costs soar, the financial burden on these individuals intensifies. The need for continuous heating leads to higher utility bills, which can consume a significant portion of their already strained budgets. Many of these individuals are on fixed incomes, such as disability benefits or pensions, which do not always keep pace with inflation and the escalating price of utilities.

In severe cases, inadequate heating can exacerbate health issues, potentially leading to hospital readmissions, additional medical expenses, and a decreased quality of life. This situation underscores the need for supportive measures, such as energy subsidies or tailored financial assistance, to help those with long-term illnesses cope with the financial demands of their health-related heating needs.

Disconnection/Fuel Debt: Hospitalisation may result in individual/household not being able to manage their home's energy needs effectively

Hardship can be exacerbated by illnesses or unexpected turns of health, causing complications like disconnection or spiralling fuel debts. As a result health conditions can push households further into fuel poverty.

The consequences of underutilised or disconnected energy supply can be devastating, prolonging the healing process and further amplifying the monetary strain for hospitalised individuals and their families. Growing energy debts, fear of disconnection and rationing practices are implications we have seen many customers experience.

Inadequate insulation: Homes that are not well insulated require more energy to heat, which can be particularly challenging for those with long-term illnesses who need consistent warmth to manage their conditions.

People with health conditions require a consistent and comfortable indoor temperature to manage symptoms effectively. However, without proper insulation, maintaining such an environment becomes both difficult and costly. Heat tends to escape through poorly insulated walls, roofs, and windows, leading to increased energy consumption as heating systems work harder to compensate for the loss. This not only drives up utility bills but also places an added burden on those who are already dealing with health issues.

The impact extends beyond financial strain; again it can also exacerbate health problems. For instance, we see customers with respiratory issues whose symptoms have worsened as a result of the cold drafts and fluctuations in temperature that come with inadequate insulation. This creates a vicious cycle where the need for heat is greater, yet the ability to afford and maintain it is compromised by the inefficiencies caused by poor insulation.

Increased Energy Needs: Having a health condition often requires additional heating or electrically powered medical equipment, which exacerbates fuel poverty.

For example, individuals dependent on dialysis at home typically incur elevated energy costs, multiplying their financial burden and pushing their household over the brink. The onset of fuel poverty, especially for those with health needs, is not just a matter of financial strain but also bears severe and rapid health implications. For some, the strain forces them to unplug their fridges or freezers, or not heat or reheat food until it's adequately hot. This can lead to immediate health complications and long-term effects, highlighting how health conditions can intensify the effects of fuel poverty. Consequently, dealing with the issues around health and fuel poverty can be a significant step in tackling the broader concern of fuel poverty.

What barriers or challenges might disabled people currently face in Scotland in terms of being able to heat their homes according to their needs?

High energy costs: Disabled individuals may have a fixed or limited income, which could make the rising costs of energy disproportionately burdensome for them to heat their homes adequately.

Typically, those with disabilities may rely on a fixed or limited income. Consequently, when energy prices escalate, the portion of their income that must be allocated to heating and powering their homes increases disproportionately. For disabled individuals, maintaining an adequately heated home is not just a matter of comfort but often a necessity for health and wellbeing. However, with energy costs surging, the financial strain can be severe, forcing them to make difficult choices between heating, eating, or other essential needs.

Moreover, energy efficiency improvements, which could offer long-term savings on bills, are often out of reach due to their high upfront costs. This leaves households trapped in a cycle of high costs and energy inefficiency, exacerbating the financial burden.

Increased energy needs: Some disabled people may require a higher indoor temperature or specific heating equipment due to their condition, leading to higher energy consumption and bills.

Some disabled individuals face unique challenges that necessitate a warmer living environment, which in turn can contribute to greater energy usage resulting in more substantial utility bills.

Additionally, specific disabilities may demand the use of specialised heating equipment that is designed to cater to the unique needs of these individuals. Such equipment could include electrically powered wheelchairs with heating elements, bed warming systems, or other therapeutic devices that provide necessary warmth but also consume a significant amount of energy.

Inadequate housing insulation: Disabled individuals may reside in older or poorly insulated homes that are difficult and expensive to heat, due to potential mobility issues that limit their housing options.

The issue of insulation is compounded for disabled individuals who may have mobility impairments as they often have a limited selection of housing options available to them, as many properties are not equipped with the necessary accessibility features. Consequently, they might find themselves with no choice but to reside in homes that offer substandard thermal protection.

The impact of living in a poorly insulated home is multifaceted. Not only does it lead to higher energy bills due to the increased demand for heating, but it can also have adverse effects on health. Disabled individuals, who may already be dealing with health concerns, can experience exacerbated symptoms or discomfort as a result of living in a cold environment. The financial strain of affording adequate heating, coupled with the potential health implications, highlights the critical need for improved housing solutions and options for disabled individuals, including better insulation and accessibility features.

What barriers or challenges might individuals with other protected characteristics (i.e race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment) currently face in Scotland in terms of being able to heat their homes according to their needs?

Language barriers may prevent individuals from ethnic minorities or those whose first language is not English from accessing information about available support services for heating their homes or understanding their energy bills and contracts.

These barriers can also complicate their understanding of energy bills and contracts, potentially leading to financial disadvantages and reduced access to necessary home heating resources. When people do not fully understand the details of their energy contracts or the intricacies of bills, they may inadvertently fail to take advantage of cost-saving measures or government-funded assistance programs intended to help them manage their heating expenses more effectively.

Moreover, the complexity of energy-related documentation, which often includes technical language and legal terms, can be particularly challenging. This complexity is exacerbated for those who are already struggling with a language barrier. Without adequate translation services or materials provided in multiple languages, many individuals might not be fully aware of their rights, available discounts, or methods to contest discrepancies in their bills. As a result, these vulnerable groups could experience higher costs, potential legal issues, or inadequate heating in their homes, which can have further implications on their health and wellbeing during colder months.

Discrimination or unconscious bias in the provision of services could lead to some individuals being less likely to receive the help they need to heat their homes, either through direct refusal of service or through less tangible barriers like poor customer service.

Biases might be based on race, socioeconomic status, age, or other factors, and can result in individuals or communities being less likely to receive the help they need to heat their homes. This can occur through an outright direct refusal of service. However, it can also happen through less obvious means, such as poor customer service, overly complicated application processes for assistance, or lack of information dissemination in certain areas.

The consequences of these barriers are not merely discomfort but can lead to serious health risks associated with living in cold homes. The issue could also have broader societal impacts, perpetuating cycles of poverty and inequality.

Single parents may be more vulnerable due to lower household income, could have to resort to extreme measures such as rationing food over energy to afford heat for their homes and children.

Women, particularly single mothers, face economic disadvantages due to being in lower paid and/or part-time roles. As a result, single mothers often have less disposable income, which can make it challenging to manage everyday expenses effectively. Among these expenses, heating costs are significant. The reduced financial flexibility due to lower earnings forces many single mothers into tough choices between heating their homes and other critical needs such as food and healthcare.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty for a) People with long term illness? b) Disabled people?

Increased investment in home energy efficiency programmes:

The Scottish Government's commitment to improving the energy efficiency of homes helps reduce heating costs, which can be particularly beneficial for people with long-term illnesses or disabilities who may spend more time at home.

Enhanced insulation, better heating systems, and other energy-saving measures can make a profound difference in the lives of those with chronic health conditions or disabilities. With these improvements, the Scottish Government not only helps to mitigate the financial challenges faced by these individuals but also contributes to creating healthier living conditions.

c) Other protected characteristics (i.e race, religion or belief, sex, sexual orientation, pregnancy and maternity, marriage and civil partnerships, gender reassignment). Why or why not? Please explain your answer.

In your opinion have actions undertaken by Scottish Government since 2021 (such as those outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”) helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Various large scale programmes including Area-Based Scheme and Warmer Homes Scotland have improved the energy efficiency of homes. However, there is still more to do to ensure no one lives in a home they cannot afford to heat.

Due to the age, type and quality of our housing stock, this continues to be a significant challenge in driving up the scale and pace of energy efficiency improvements to people’s homes. Additionally where homeowners are required to contribute financially, there is limited priority/urgency for them to do so.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

Focus on the need for a comprehensive review and update of the existing Fuel Poverty Strategy, ensuring it aligns with the latest developments in the energy sector and addresses the recent surge in fuel poverty.

Addressing the recent rise in fuel poverty requires a comprehensive review and update of the current Fuel Poverty Strategy. It is essential that revisions to the strategy consider the latest evolutions in the energy sector. Furthermore, reform should explicitly target the needs of vulnerable households.

Increase funding for energy-efficient home upgrades specifically targeting vulnerable households, such as improved insulation, double glazing, and efficient heating systems.

To address the pressing need for environmental sustainability and to support those in economically precarious situations, it is essential to enhance funding for energy-efficient home upgrades, particularly focusing on vulnerable households. By targeting vulnerable households, this would help alleviate the burden of high energy costs, which disproportionately affect those with limited income.

By facilitating access to these upgrades, we can ensure that the benefits of green technology reach those most vulnerable in society. This approach not only promotes social equity but also contributes to the broader goal of reducing our carbon footprint. The investment in such energy-efficient measures creates a win-win scenario: improving the quality of life for individuals while advancing environmental stewardship.

Expand eligibility criteria for existing fuel poverty reduction programs to include a broader range of vulnerable/at risk groups

Where programs target a narrow segment of the population, other groups who are equally in need of assistance may be overlooked. By broadening the scope to include a wider range of vulnerable groups, we can ensure a more comprehensive approach to eradicating fuel poverty and ensure assistance reaches those who need help.

Families on the cusp of eligibility thresholds can often struggle to meet basic needs, including maintaining adequate heating in their homes. By making them eligible for fuel poverty reduction programs, we can alleviate some of their financial burdens and improve their overall quality of life.

Local Authorities

Respondent: Aberdeenshire Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

The housing stock within Aberdeenshire Council is geographically challenging; consisting of lots of different construction types within off gas areas, many of which are in remote rural locations. Around half the domestic properties in Aberdeenshire are not on the mains gas network so rely on electric heating or oil. People in Aberdeenshire may face issues with building structure being inherently draughty, particularly solid granite buildings which are prevalent in the area. Some of our settlements are very sparce and often make up the remainder of existing local authority housing. This can be difficult to find economies of scale however, the house types can meet the criteria for upgrading the thermal comfort of the resident’s properties. The ability to insulate these properties can be costly and done wrongly can cause unintended consequences such as damp. Around 40% of domestic buildings in Aberdeenshire are of solid wall construction so this is quite a widespread issue.

We work closely with our Stock Improvement Team to deliver mixed tenure schemes to ensure some consistency in upgrading properties with energy efficiency measures. The split in energy efficiency contractors into political areas for Local Authority stock can prove challenging for us at times.

As will be the case across the country, rising fuel prices also make heating properties adequately more challenging.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

b) Increase local incomes in your area

c) Reduce energy costs in your area

d) Support people to heat their homes efficiently in your area (behaviour)

Aberdeenshire's Local Housing Strategy 2024 - 2029 considers these points as main drivers to help reduce fuel poverty. Aberdeenshire Council strive to contribute heavily to each of these areas through the Fuel Poverty Team and in partnership with our key stakeholders.

The Local Heat and Energy Efficiency Strategy (LHEES) was approved at the end of June and further work is being undertaken to prepare a detailed delivery plan which will highlight specific areas for improvement and potential solutions across our locality. This work is to be completed by summer 2025. Though the delivery plan will identify areas for improvement and potential investment, the LHEES itself is not a funded mechanism and will rely on promotion of owner occupier funding improvements, ideally assisting those responsible for allocating ABS funding and we will work with other stakeholders to realise the ambitions.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

The efforts of teams certainly have a benefit for the residents of Aberdeenshire. Year on year, our Fuel Poverty Team help to alleviate the impacts on fuel poverty. Area Based Programmes with a procured framework of contractors for the installation of energy efficiency measures are a large part of our efforts. We have been very successful on an annual basis with spending our full allocation from Scottish Government. Our involvement in the ECO4 flex scheme with partners, SCARF, is proving successful in helping residents improve the energy efficiency of their homes and lower their heating costs, increasing their thermal comfort and lower carbon emissions.

From an LHEES perspective, as stated above, a detailed action plan is being developed and therefore the strategy has not yet had any direct impact. We would hope that once actions are identified and implemented, they will assist in the alleviation of fuel poverty in the area.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

Aberdeenshire Council assist resident to access schemes such as ABS programmes, ECO4 flex and Energy Savings Trust loans. These allow for energy efficiency measures to be installed in qualifying properties to improve the energy efficiency.

b) High fuel prices?

Aberdeenshire Council work with residents and stakeholders to help with reviewing energy tariffs and finding a solution that is beneficial to the client. We can also provide assistance with community oil buying groups or pre-paid meter vouchers for those that meet qualifying criteria.

c) Low income?

Aberdeenshire Council work with residents and stakeholders to help with income maximisation. Those with fuel debt can also be provided with advice and assistance to address the issue and for those that meet criteria, voucher schemes are also available for those on a low income.

d) Inefficient use of heat in the home (household behaviour)?

Aberdeenshire Council work with residents and stakeholders to help with energy efficiency advice. Residents can access this information via surgeries held by SCARF and other partners and can also arrange a home visit to discuss household behaviours and get advice on how to change these to reduce energy use.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

As mentioned at question 1, the geographical area of Aberdeenshire along with house types can be a challenge to tackling fuel poverty in the area. Rising prices of everything from insultation materials to replacement windows as well as the cost of fuel can hinder progress. The criteria of ABS programmes such as Council Tax Banding, some health-related cases prevent some residents from being able to access funding.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

It would benefit Aberdeenshire Council to be allocated funding over a longer period rather than just one year; for example, a three-year programme. This would allow for programmes to be more consistent in terms of procurement and planning. The timing of the allocation and approval of grant can prove difficult for different stages/operational matters such as marketing, sign up and building warrant.

Given high energy prices faced by Aberdeenshire residents, it is important to ensure that the principles of a just transition are maintained and Aberdeenshire benefits from the energy the area generates.

Respondent: Comhairle nan Eilean Siar

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs.

Households in the Outer Hebrides are facing higher costs of living (Highlands and Islands Enterprise | HIE. ) The present cost of living crisis is having a disproportionately high impact on island communities such as those in the Outer Hebrides. Household energy costs are already higher in island areas, where houses are generally larger, older, poorly insulated, difficult, and costly to retrofit with insulation. Across the Hebrides there are few properties connected to the network LPG for gas boilers, and a high reliance on kerosene for oil boilers or electric heating for storage / infra-red heaters.

Property characteristics such as age, built form and poor energy efficiency compared to the national average are barriers to people being able to heat their homes as required in the Outer Hebrides. Indicators of poor energy efficiency, including percentage dwellings with uninsulated walls, percentage dwellings with loft insulation <100mm and percentage dwellings with EPC F-G, are all higher in the Outer Hebrides than the national average.

Those in fuel poverty often do not have the financial means to improve the energy efficiency of their homes, potentially leading to self-rationing and further degradation of properties and associated health risks. Many older and traditional properties are not suitable for heat pumps without costly, deep retrofit renovations. Older households are more likely to live in extreme fuel poverty, as they have fixed incomes and tend to live in hard-to-treat properties.

The Scottish House Condition Survey 2017-19 gave an Outer Hebrides median fuel poverty gap of £1,430, highlighting it was higher in owner-occupied, larger houses. This, along with higher living costs, makes it extremely difficult to address fuel poverty and extreme fuel poverty. The survey showed that locally 48% of dwellings failed the Scottish Housing Quality Standard "Energy Efficient" criterion. The distinct adverse weather conditions in rural areas, with wet and increasingly windy weather are more prevalent in the Outer Hebrides.

The issues described above (hard-to-treat construction types, older properties, and weather-related damage) equate to higher costs for retrofitting rural homes. The dispersed nature of the housing stock, largely detached, does not allow for aggregation of properties through energy efficiency programmes to provide economies of scale, as is the case for whole terraced streets or neighbourhoods in urban areas. Scottish House Condition Survey provides an estimate of how many people are in fuel poverty overall, it does not allow for targeting specific households or areas. Fuel poverty data is only available at the Local Authority level.

The LHEES Delivery plan focuses on using the evidence-base from the LHEES to better target energy efficiency in key priority areas to reduce fuel poverty.

The Fuel Poverty Survey carried out by Tighean Innse Gall showed that there was a high level of fuel rationing, leading to households being too cold. Another issue for our island areas is the lack of island proofing in the use of the Scottish Index of Multiple Deprivation (SIMD) as the main tool to highlight areas of deprivation and therefore support funding claims. None of the 15% most deprived data zones are in the Outer Hebrides. The index looks at concentrations of multiple deprivation but deprivation in rural areas is not clustered and can be spread over considerable distances, often found adjacent to affluence. Not all deprived people live in deprived areas, and not everyone living in a deprived area is deprived. There are no indicators used which are relevant to Fuel Poverty, cost of living or house condition, for example the two indicators in the Housing domain are number of people in households that are overcrowded and number of people in households without central heating.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to: a) Improve energy efficiency in your area b) Increase local incomes in your area c) Reduce energy costs in your area d) Support people to heat their homes efficiently in your area (behaviour).

a) Improve energy efficiency in your area:

In December 2023, the Comhairle published a Local Heat and Energy Efficiency Strategy and Delivery Plan, which sets out the long-term plan for decarbonising heat and improving the energy efficiency of buildings across the Outer Hebrides. Fuel Poverty reduction is at the heart of the Comhairle nan Eilean Siar Local Heat and Energy Efficiency Strategy (LHEES). The vision of our LHEES is that: “Highly energy efficient buildings throughout our islands reduce Fuel Poverty, enabling the transition to decarbonised heat and decreasing our buildings’ contribution to climate change.” As Fuel Poverty and Extreme Fuel Poverty are higher than in any other Local Authority in Scotland, reducing energy efficiency as a driver of Fuel Poverty is the highest priority set out in our LHEES.

An article in the Herald in May 2024 revealed that Scottish islands and rural areas have led the way on heat pump installations. Using the most recent data from Microgeneration Certification Scheme (MCS), The Herald created a map showing the rise in heat-pump households in different Local Authorities. Approximately 35% of the 4,923 households heated by electric now have air source heat pumps, the majority of which are likely to be Hebridean Housing properties.

The Scottish Energy Statistics Hub Scottish Energy Statistics Hub shows that the Outer Hebrides had the second highest rate of ECO measures in 2023 Q1.

[The graph provided showing the Local Authority ECO measures per 1,000 households was removed as it did not meet accessibility requirements. It can be accessed via the link provided above on Scottish Energy Statistics Hub and navigating to the local authorities tab].

This shows that, although there is a high rate of energy efficiency work being carried out in the Outer Hebrides, there continues to be a huge issue with Fuel Poverty and Extreme Fuel Poverty.

The Comhairle has supported The Energy Advisory Service (TEAS) with grant funding of £39K per annum to assist with the delivery of its services and in meeting the objectives of the Local Housing Strategy (LHS). TEAS, delivered by Tighean Innse Gall (TIG), a local housing development agency, provides an energy advice service to the local community, along with training to individuals and community groups, with a view to improving the awareness of energy efficiency matters.

In 2021, TEAS secured £211K ECO funding to support HEEPS, and from 2021 to date, the table below details the grant support received, client financial gain, and different energy efficiency activities engaged in, that the Comhairle helps to enable.

Grant support for prepayment vouchers	£174,170
Charitable funding to enable energy efficiency works	£987,345
Client financial gain	£536,207
Enquiries responded to (telephone and otherwise)	4,943
Signposting to HEEPS & Warmer Homes Scotland	521
Signposting to Financial Inclusion and MacMillan Benefits, other partner agencies and utility companies	526
Small energy measures installed	235
Community Engagement events	38
Number of homes supported by vouchers	711

The Comhairle has also secured funding to deliver the Heat and Energy Efficient Programme Scotland: Area-Based Scheme (HEEPS:ABS to 2021, HEES:ABS is current programme) in the Outer Hebrides. These schemes have assisted with solid wall, loft, underfloor insulation, ventilation and heating system upgrades.

HEEPS:ABS was delivered by TEAS until 2021. Unfortunately, TIG was forced to restructure its business model at that point and measures ceased. Works via this Scheme did not pick up again until the 2023/24 programme, when Warmworks, the Comhairle’s newly appointed managing agent for HEES:ABS, delivered £426,315 of energy efficiency measures to households throughout the Outer Hebrides. Work has continued and a successful bid was made to deliver £1.6m of measures with respect to the 2024/25 programme.

b) Increase local incomes in your area:

The Comhairle Financial Inclusion Service data provided below is likely to be moderately lower than the actual data: Lewis and Harris service area received 530 referrals for the period from 23 December 2021 to present resulting in financial gains of approximately £996,516.03.

The Uist and Barra service area received 162 referrals for the period 23 December 2021 to present resulting in financial gains of approximately £442,792.08.

Referrals and financial gains with respect to the Macmillan Benefits Service are: 542 referrals resulting in gains of £2,681,502.05.

The monies gained by the service for their clients make a big impact on their financial ability to heat their homes and feed themselves, and a good working relationship exists with Home Energy Scotland and Tighean Innse Gall. For example, if an award is gained for a benefit that fits in with the qualifying criteria to enable a heating upgrade, a referral is made to Home Energy Scotland with the client’s permission. The biggest difficulty with this is that most people do not want to move from oil or gas heating to electric, due to the cost of electric. The service used to be able to facilitate a heating upgrade, replacement boilers etc. to cancer patients in the Western Isles through funding from SSE/OVO which made a huge difference to people with a cancer diagnosis as one of their highest additional costs is heating. Unfortunately, the Scottish Government now permits upgrades only for electric heating which clients are not keen to pursue due to the costs associated with electricity at present.

The Comhairle delivered an ESF Poverty and Social Inclusion programme through local agencies over the period December 2021 to June 2023 supporting Social Inclusion (33 Households), and Fuel Poverty (25 Households), and the Financial Inclusion Service outcomes. The Financial Inclusion Service is now funded through the UK Shared Prosperity Fund until March 2025.

The Comhairle supported a local Food Bank over the reporting period through an allocation of c£240K through either legacy COVID-19 funding, Health and Social Care (HSC) department funding, or the Islands Cost Crisis Emergency Fund. This funding supported families with food and fuel vouchers. HSC department also provided support separately for fuel and food for a time early in the reporting period but there are no figures available for this. Free School Meals have been awarded to 1035 pupils and 1583 received Clothing Grants totalling £209,940.

A large percentage of the local workforce works in the public sector. Of the 13,800 workforce, 6,400 people worked for the public sector in 2023, approximately 46% of the workforce. Given the constraints with budgets, increasing incomes is extremely difficult. Approximately 20% of the working population are self-employed. 1.8% are in receipt of out of work benefits, in comparison to the Scottish average of 3.2%. The Outer Hebrides working age population is in decline; the Outer Hebrides has the 3^rd lowest percentage of those aged 16-64, as the population aged 65 and over continues to grow.

c) Reduce energy costs in your area:

In partnership with Orkney and Shetland Councils, the Comhairle continues to lobby Government and OFGEM regarding fuel prices, seeking a lower ‘islands tariff’ for areas that contribute, or will contribute, significant amounts of renewable electricity to the UK Grid but are high in Fuel Poverty. Once renewable electricity is being produced at scale in the Outer Hebrides, from 2030, there will be the potential to trade some of this electricity directly to island consumers at discount.

d) Support people to heat their homes efficiently in your area (behaviour):

Advice and support from TEAS – home visits and surveys are carried out. Advice and support from the Comhairle’s Empty Homes Officer regarding bringing empty properties back into use, including how they can be efficiently insulated and heated is provided.

The Comhairle Financial Inclusion Team make referrals to Tighean Innse Gall for energy advice and to any schemes that are being funded. These can be for energy efficient white goods or help with heating costs. Through the Macmillan Benefits Service some of the referred cancer patients received much assistance from the Heat Support Fund, but the Scottish Government has not provided funding this year which is disappointing coupled by the loss of the Winter Fuel Payment.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve Fuel Poverty OR helped to alleviate the impacts of Fuel Poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Fuel poverty is endemic in the Outer Hebrides – Na h-Eileanan an Iar has the highest levels in Scotland so it is difficult to understand the impact these measures have had, when we are starting from a very low baseline, and the Comhairle have not had the budgetary capacity to carry out a private sector house condition survey since 2015. Measures installed via schemes such as HEEPS:ABS and HEES:ABS etc., should help households, but Fuel Poverty is very complex when you have low incomes, many old, poorly insulated buildings, and high fuel costs to contend with.

Energy-efficient systems such as air source are only truly efficient when installed in new, well-insulated buildings, or when there has been a whole house retrofit and homes have been insulated prior to the heating system being installed.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on Fuel Poverty in Scotland?: a) Poor energy efficiency? b) High fuel prices? c) Low income? d) Inefficient use of heat in the home (household behaviour)?

a) Poor energy efficiency:

Publishing the LHEES, which sets out the long-term plan for decarbonising heat and improving the energy efficiency of buildings across the Outer Hebrides, is a positive step towards reducing the impact of poor energy efficiency as a driver of fuel poverty in Scotland.

The LHEES Delivery plan focuses on using the evidence-base from the LHEES to better target key priority areas; engagement and alignment with existing programmes such as the Island Centre for Net Zero and Carbon Neutral Islands; and development of a portfolio of projects. Full implementation of the strategy would see a fabric first approach embedded into all energy efficiency and heat decarbonisation projects identified; and potential impacts on fuel poverty, including fuel bills and costs, fully assessed for each specific project and programme prior to delivery, to ensure fuel poverty reduction objectives are met.

[The map provided of ‘Average Energy Efficiency Score of Local Authorities’ was removed as it did not meet accessibility requirements. The data source quoted was ‘Ahlrichs et al. (2022)’].

The Local Authority, in partnership with other agencies, is working tirelessly to increase the energy efficiency of the housing stock. This is evidenced by the number of ECO measures which have been carried out, however, as shown in 3.6 above the condition of the housing stock in the Outer Hebrides is poorer than those in other areas.

The Comhairle Building Standards team continues to enforce rigorous energy efficiency standards paving the way for the introduction of Passivhaus, the global gold standard in energy efficiency. The ECO4 programme, offering energy efficiency measures to eligible households, will soon be available in the Outer Hebrides following a delay in rollout caused by staff shortages.

b) High fuel prices:

As in 2 c) above: In partnership with Orkney and Shetland Councils, the Comhairle continues to lobby Government and OFGEM regarding fuel prices, seeking a lower islands tariff for areas that contribute, or will contribute, significant amounts of renewable electricity to the UK Grid but are high in Fuel Poverty. Once renewable electricity is being produced at scale in the Outer Hebrides, from 2030, there will be the potential to trade some of this electricity directly to island consumers at discount.

c) Low income:

The Comhairle received Islands Cost Crisis Emergency Funding from the Scottish Government in 2022/23, 2023/24 and 2024/25 to assist with the cost of living crisis, and funding distribution in our communities included allocations towards fuel / food vouchers, lower cost food market/food service to vulnerable people, top ups to Free School Meal payments, Warm Spaces Hubs, support to those on CTR. Signposting to different bodies and financial gains received via the Financial Inclusion service and the Macmillan Benefits service.

The results from the Annual Survey of Hours and Earnings (ASHE) for 2024 show that the average gross weekly earnings in 2024 for all employee jobs in the Outer Hebrides was £607.10, in comparison to the Scottish average of £687.90, and was the 4^th lowest weekly pay out of the 32 local authority areas. Gross disposable household income in the Outer Hebrides was £20,233 in 2022. The Scottish average was £20,854. The Outer Hebrides had the 13^th lowest GDHI out of the 32 local authority areas.

In addition, there is the higher cost of living. The present cost of living crisis is having a disproportionately high impact on island communities such as those in the Outer Hebrides. One reason for this is that household energy costs are already higher in island areas, where houses are generally larger, older, poorly insulated, difficult, and costly to retrofit with insulation. This is in addition to the higher energy costs that households are required to pay. The higher cost of living is highlighted in the Minimum Income Standard report - Highlands and Islands Enterprise | HIE. and in - The cost of remoteness: Reflecting higher living costs in remote rural Scotland when measuring fuel poverty.

The minimum cost of living in remote rural Scotland is between 15% to 30% higher than urban areas of the UK. Rural households face increased costs across a range of goods and services. Weekly food costs are approximately up to 4% higher for remote rural communities and up to 13% on the Islands. The cost of food is not significantly higher in rural chain supermarkets. However, prices in local convenience stores (which many remote communities rely upon) are up to 44% higher in remote rural regions and 27% higher in the Islands compared with equivalent products in the supermarket. The most significant additional cost for rural households is the cost of transport. The Outer Hebrides has the highest transport poverty in Scotland according to Sustrans. Fuel spend on transport is often not considered within fuel poverty definitions or policy.

The continuation of the 5p per litre Rural Fuel Duty Relief on petrol duty is important in assisting weekly household income, as reliance on the car is high due to limited public transport options, but prices in Uist and Barra tend to be a lot higher, thus making the rebate less effective.

d) Inefficient use of heat in the home (household behaviour):

The Comhairle Empty Homes Officer has been able to advise on behaviours which are as simple as closing doors to retain heat in different rooms, when using an air source system.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

The age, built form, and poor energy efficiency of the domestic housing stock in the Outer Hebrides compared to the national average is a significant challenge for delivery of the Comhairle’s LHEES and reduction of fuel poverty. PAS2030, Skills and Supply Chain pose further challenges, with additional certification requirements and technical specification issues with the new standard hindering energy efficiency works over the reporting period.

Costs and available funding remain a challenge to removing energy efficiency as a driver of Fuel Poverty, and significant additional funding will be required to remove energy efficiency as a driver of Fuel Poverty in the islands.

Ofgem has a lack of current knowledge of the accurate consumption data for the households that are not connected to mains gas. The usage figures used for the Energy Price Cap for the “Average UK Home” are 12,000kwh of Gas and 2,900kwh of Electric. This is not representative of usage in the Outer Hebrides and there is no allowance made for the much higher electricity usage in the Outer Hebrides, other than saying individual households may pay more than the Energy Price Cap. An extra locational premium is added to Standing Charge and Unit Price and this, coupled with increased energy usage on account of poorly insulated stock and climatic exposure, can result in an Energy Price Cap twice that of the “Average UK Home”. There is also no cap on the price of unregulated heating oil, which is the main heating source for households in the Outer Hebrides. The SHCS has not been updated since the 2017-19 version, with the next 3-year average results for local authorities available in 2026. The survey carried out by TIG has revealed how difficult the situation is and how much the numbers of houses in Fuel Poverty have increased.

Fuel Rationing - In 2023, The Energy Advisory Service (TEAS), the charity arm of Tighean Innse Gall (TIG), received funding from British Gas Energy Trust to undertake a survey into the affordable warmth of homes in the Outer Hebrides. In total, 2,043 households responded to the survey, which represents around one in six of approximately 12,000 occupied homes throughout the Islands. TIG’s findings indicate that many householders cannot afford to heat their homes and are self-rationing their consumption. This means that the levels of Fuel Poverty are likely to be underestimated owing to the cost-based calculations used in the survey and may actually be higher than indicated. This is of concern as reported data is already significantly higher than Scottish averages. A considerable proportion of individuals, despite allocating substantial resources, are still unable to achieve a satisfactory level of comfort in their homes, and almost one fifth of respondents reported that they were unable to heat all the rooms in their home, choosing to heat the main living spaces only, and for restricted periods. These patterns underline the balance between sufficient warmth and managing costs.

House Condition in the Outer Hebrides & Heating Type - In 2016, the Comhairle carried out a comprehensive Private Sector House Condition Survey which revealed that private sector homes, which account for 75% of the housing stock, consisted mainly of large detached 2-storey dwellings and bungalows, 70% of which were built in the years after the Second World War, and comprises very few semi-detached, terraced or tenement properties. This impacts greatly on their energy efficiency as all external walls are exposed to harsh weather conditions, and frequently subjected to strong winds and heavy rainfall. A large percentage of owner-occupied dwellings were Scottish Housing Quality Standard (SHQS) non-compliant with as much as 22.8% in need of either urgent or major repairs at the point of survey. The main SHQS failures in owner-occupied properties were due to energy efficiency.

The TIG Survey highlights those dwellings constructed before 1919, in addition to those constructed between 1950 to 1975 and 1976 to 1991, exhibit the highest Fuel Poverty rates, varying from 52% to 66% and 44% to 52% for Extreme Fuel Poverty. Of the householders who insulated their properties in the last decade, 66% was loft insulation, with internal wall insulation and room-in-roof insulation notably less frequent, at 31% and 25% respectively. As 90% of the Outer Hebrides do not have access to the mains gas grid, there is a high reliance on oil central heating. The table below shows that of the 12,717 occupied households that responded to questions on central heating in the 2022 Census, 37.4% have oil central heating, 17.2% have electric (including storage heaters), 12.5% have gas, 12.2% have some type of renewable heating, 14% have two or more types of central heating, and 3.5% have no central heating.

[The following table was removed and re-inserted in word format to meet accessibility requirements]

Central Heating in Household	Number	Percentage
No central heating	447	3.5
Gas central heating: total	1,589	12.5
Gas central heating: mains gas	1,235	9.7
Gas central heating: Other gas (including liquid petroleum gas and biogas)	354	2.8
Electric (including storage heaters) central heating	2,186	17.2
Oil central heating	4,759	37.4
Solid Fuel (excluding wood)	309	2.4
Wood or Biomass (including logs, pellets, chippings) central heating	101	0.8
Other renewable energy source (including electric and air heat pump systems)	1,450	11.4
District or communal heat system	6	0.05
Other central heating	68	0.5
Two or more types of central heating	1,800	14.2

Of the respondents to the TIG Survey, 67% of those households with electric heating are in Fuel Poverty with 56% in Extreme Fuel Poverty. Oil central heating is lower with 52% in Fuel Poverty and 40% in Extreme Fuel Poverty. Gas shows the lowest rate of Fuel Poverty with 59% in Fuel Poverty and 37% in Extreme Fuel Poverty.

Hebridean Housing Partnership (HHP) carries out a house condition survey on the affordable housing rented stock approximately every five years, but there is no up-to-date information on private sector house condition, which impacts negatively on the data the Comhairle has available for forward planning. It is worth noting that the Crofter Housing system means that a higher proportion of the population is in (Government supported), private sector crofter housing when, in a non-crofting area, they would be in social rented housing with a more effective house condition safety net.

Household Characteristics - While the majority of the homes in the Outer Hebrides are owned, whether outright or with a mortgage, there is a percentage of social renters that rent from HHP and a smaller group that rent from private owners. TIG’s survey highlighted that social renters faced the highest risk of fuel poverty, with 78% categorised as fuel poor, followed by private renters at 55%. Owners with mortgages exhibited lower rates, though still high at 41%.

Those who owned their homes outright were also susceptible to extreme fuel poverty, with a rate nearly double that of those with mortgages, at 41%. This could be attributed to the presence of a significant proportion of homeowner pensioners, who are also considered an at-risk group. Single pensioners faced the highest risk, with 65% categorised as fuel poor, reflecting their heightened vulnerability as persons with a limited fixed income who do not have the financial support of a second occupant. Families with children followed at 56%, while pensioner couples followed with 47%. These trends suggest that households with fixed or limited income sources, like pensioners living in older properties, and those with additional financial responsibilities, such as families with children, face significantly higher risks of fuel poverty compared to economically active adults without children, who tended to have the lowest rates.

A significant finding was the substantial percentage of households with disabilities estimated to be fuel poor (81 - 92%), and among them, 62 - 63% were categorised as extremely fuel poor.

As expected, Fuel Poverty rates exhibited a steady decline as net income increased, highlighting the correlation between income and fuel poverty. Rates surpassed 97% for individuals earning less than £16,500, while those with incomes exceeding £40,000 experienced rates below 2%.

Data - The impact of the COVID-19 Pandemic on the Scottish House Condition Survey (SHCS) has meant that it is running several years late at Local Authority level, and it will not be directly comparable to the 2019 survey. The Comhairle relied on this to provide comparable data on Fuel Poverty and many other measures on private sector housing.

Funding - Capital funding for private sector repair grants ceased in 2013/14, and locally we are seeing the impact of that now through a deterioration in the housing stock. There has been a recent increase in the number of elderly / vulnerable homeowners presenting as homeless owing to their home being in disrepair, which includes no heating, broken heating, no insulation, draughty and leaking roof structures and windows.

It is impossible to heat a home efficiently when it is in poor repair, and it is very difficult to tackle these issues at source when there is no funding available. The burden then falls on the Comhairle’s Homelessness Services Team and Health & Social Care Service.

TIghean Innse Gall (TIG) Restructure - TIG was forced to restructure its business model in 2022, and make 14 staff members redundant, owing partly to the impact of the COVID-19 Pandemic slowdown, but also the PAS2030:2019:2035 standard, which had to be met for all energy efficiency works from 30 June 2021, and which was costly and required a substantial amount of off-island re-training.

Delivery of the 2020/21 HEEPS:ABS programme (which was extended to October 2021 due to the COVID-19 situation) was already running below anticipated spend due to issues relating to the Pandemic. With the implications of the new PAS requirements the out-turn for 2020/21 the 2021/22 HEEPS:ABS programme ground to a halt until PAS issues were resolved. The programme did not pick up again until a new delivery partner was appointed in 2023.

TIG has effectively been reduced to half the size it was, which limits the amount of work it can do, and puts enormous pressure on the remaining staff members. Skilled and experienced staff members were lost with the restructure, and access to HEEPS:ABS was unavailable for over 18 months.

Fuel Poverty and Private Sector Housing Team – As public sector funding declines, it is becoming increasingly challenging for Local Authorities to prioritise work around Fuel Poverty. A local response to this has been a much closer collaboration between the Comhairle and Tighean Innse Gall in the delivery of Fuel Poverty mitigation measures.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

Costs and available funding remain a challenge to removing energy efficiency as a driver of fuel poverty, and significant additional funding will be required to remove energy efficiency as a driver of fuel poverty in the islands. The fuel poverty strategy vision for everyone to have a warm, safe home that they can afford and that meets their needs, in a place where they want to live, is not currently being met in the Outer Hebrides. Traditional island homes have thick stone or poured concrete walls, and intervention with internal insulation can result in unacceptably small room sizes. The most effective treatment is external wall insulation but current funding levels cannot support the roll-out of this type of intervention at adequate pace.

It is essential that financial support is given to the households in the Outer Hebrides. Evidence is continually being provided that the Outer Hebrides has the highest rate of Fuel Poverty, and, more worryingly Extreme Fuel Poverty in the UK. An islands proofed fuel allowance is needed to address the fuel poverty gap and avoid the risk of people ‘falling through the cracks’. Evidence is available to show that it is not only the households in the lower income groups that are experiencing Fuel and Extreme Fuel Poverty, as low income may be an important driver but it is not a prerequisite. It is also clear that although there is a significant percentage of ECO works being carried out, it is still failing to have a significant impact on the percentage of those in Fuel Poverty.

Single pensioner households have an above average rate of Fuel Poverty, and the Outer Hebrides has the second highest percentage of those aged 65 and over at 27% (2022 Census). The median age has increased to 51.29 years (Scottish median age 42.88) while the female median age is 51.98 (Scottish median 43.91) and for males 50.58 (Scottish median 41.83).

In addition, there is a need to provide grants so that households can improve their energy efficiency. Although interest free loans are available, the take up is not high enough, as the cost of living is higher. In an area which is delivering increasing levels of renewable energy, it is paradoxical that residents are experiencing higher energy costs and higher living costs.

OFGEM’s Energy Price Cap continues in operation but its limited effectiveness in the island context is not always appreciated. The Energy Price Cap should have been island-proofed. The Price Cap imposes a limit on the unit cost of electricity or gas and this is multiplied by energy usage to present the typical maximum an ‘Average UK Home’ should be spending on energy. The problem in the islands is that, due to high climatic exposure and a poorly insulated housing stock, energy usage can be twice that of the ‘Average UK Home’. So, although the unit cost of energy is capped, the total cost when the rate of energy usage is applied is not capped and this can result in island energy bills much higher than the capped energy bill of an ‘Average UK Home’. The Price Cap covers only variable rate electricity and gas and does not apply to unregulated fuels like heating oil as mentioned. This is clearly of concern in the islands where so many households rely on heating oil for heating the home. It is worth noting that, a number of years ago, the Comhairle campaigned vigorously over the unacceptably high cost of road fuel in the islands. The Competition and Markets Authority (CMA) subsequently directed that the two island fuel depots, owned and run by a single supplier, should be opened up to competing suppliers and this resulted in a stabilisation of road fuel and heating oil prices. The 5p per litre Rural Fuel Duty Rebate also continues in force locally and is important in assisting weekly household income, as reliance on the car is high due to limited public transport options, but fuel prices in Uist and Barra tend to be a lot higher, thus making the rebate less effective.

Extension of this rebate to address high costs of kerosene heating oil was mooted around the time of introduction of the 5p rebate in the islands and this should be considered again for the Outer Hebrides to further the policy of island proofing, alongside islands tariffs for all other energy sources used for heating in the Outer Hebrides such as electricity and off grid gas/tanker delivered gas.

A further anomaly is the rate charged to people on prepayment meters, who by definition are under the greatest financial pressure in relation to energy costs. The rate charged in the Highlands and Islands is 62.3p per day in standing charges and 27.19p per kilowatt-hour. If people in the North of Scotland pay by direct debit they pay 59.38p per day, whereas somebody who is reliant on a prepayment meter pays 66.23p per day.

Respondent: Dumfries & Galloway Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs.

Dumfries and Galloway has traditionally faced higher levels of fuel poverty due to the rural and very rural nature of our Region. This could largely be due to the number of factors including the larger than average number of single pensioners, and older housing stock. This region is also more reliant on alternative fuels as 39% of properties are off the gas grid (17% nationally). This means that central heating is provided via more expensive options such as heating types including oil & LPG.

All of the above are further exacerbated by the starkly rising fuel costs which have occurred during the reporting period of this Report, and the region being one of the lowest wage economies in Scotland.

We know that from the analysis of Fuel Poverty Figures by the Scottish Housing Condition Survey from 2017-2019 that in Scotland the overall levels of Fuel Poverty in Scotland was 24% and within our Region was 29%.

This was followed up with a further estimate in 2022 that levels of Fuel Poverty had risen to 31% in Scotland with an estimate of 37% within our Region. This would effectively equate to 26,300 households in Dumfries and Galloway living in fuel poverty with up to 16,000 in extreme fuel poverty.

The above together with the Cost of Living Crisis which have included huge increases in energy costs are all contributing to an even greater increase in the number of households within our Region who are in desperate need of help at this incredibly challenging time.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

The introduction of Local Authority ECO4 Flex in April 2023 in Dumfries and Galloway has resulted in significant investment in the region. In year one (2023-24), 457 households received a package of ‘whole house’ retrofit measures. The total investment was £11,858,55.69, averaging £26K per household. Furthermore, this will save 2,376 tonnes of CO2 per annum for the lifetime of the measures. The typical suite of measures includes internal wall insulation, air source heat pumps, and photovoltaic panels.

Energy Efficient Scotland: Area Based Schemes (ABS) draw on a range of data sources including home analytics, the Scottish Index of Multiple Deprivation (SIMD), child poverty and the Scottish House Condition Survey (SHCS). The Dumfries and Galloway Local Housing Strategy seeks to maximise the use of funding to deliver energy efficiency measures to homes in the private sector.

As part of ABS 11 in 2023/24, Dumfries and Galloway completed 216 EWI installs with fuel bill lifetime savings of around £4.2m and CO2 lifetime savings of 7.4 tonnes. The programme was supported by funding from the Scottish Government totalling £3,164,644.00.

The Scottish Government allocated the region £2,364,468 for 2022/23. A total of 175 properties received external wall insulation, including 166 privately owned homes and 9 private rented properties.

The Scottish Government allocated £2,379,370.00 for the 2021/22 scheme. Delivery of this budget was impacted by increased costs, negotiations with contractors and discussions with the Scottish Government.

While experiencing challenging times, 134 homes in the private sector benefitted from solid wall insulation (SWI). Of these, 115 properties were owner occupied and 19 privately rented.

In the first eleven years of ABS, there have been more than 2,419 energy efficiency measures installed across Dumfries and Galloway with a total spend of £23.6m. These measures will save over 91,121t of carbon in their lifetime and result in fuel bill savings in excess of £26.7m at current prices. The ongoing programmes will further improve these outcomes, while also providing wider health, climate change and regeneration objectives.

b) Increase local incomes in your area

Within Dumfries & Galloway, we have a wide range of Projects which increase local incomes. Our two main Projects are our Dumfries & Galloway Financial Wellbeing & Revenues

Project	Income Generated 2021-2022	Income Generated 2022-2023	Income Generated 2023-2024
Dumfries and Galloway Council Financial Wellbeing and Revenues Services	£3,321,000.00	£4,084,000.00	£4,816,000.00
Dumfries and Galloway Citizens Advice Service	£6,707,191.21 96% of Target	£8,134,180.84 116%	£9,519,299.45 136%
Total Income Generated	£10,028,191.21	£12,218,180.84	£14,335,299.45

The above overall total for Income Maximisation for the Reporting Period of our Report is £36,581,671.50.

c) Reduce energy costs in your area

Further to the delivery of the ABS and ECO4 schemes highlighted above, the Council continues to work in partnership with the Energy Agency and Home Energy Scotland. These organisations are able to provide advice and guidance to all householders to help reduce fuel bill costs. In many cases, this can be basic advice on use of heating controls, highlighting minor measures that can be carried out such as draught proofing, and signposting to funding opportunities available in individual circumstances.

Emergency Energy Payment Assistance Programme

Dumfries & Galloway Council have allocated funding to the Emergency Energy Payment Assistance Programme which aims to provide emergency help in a variety of forms to all of residents within our Region. All of the following outcomes have been achieved over the reporting period of this Report:

April 2022-March 2023

Emergency Energy Payment Assistance Scheme

• 489 Private Sector Tenants have been supported with Emergency Energy Fuel Vouchers
• 656 Registered Social Landlord Tenants have been supported with Emergency Energy Fuel Vouchers
• 135 Households received deliveries of a Winter Supply of Briquettes
• Over 1,500 people supported with their fuel issues. Many of those included people in rural areas who rely on other fuel types to heat their homes. The Lemon Aid Fuel Poverty Project Team worked closely with local agencies to source funds to help people top up on oil and ‘Calor’ gas solutions.
• Helped reduce fuel debt within our Region by £126,243. This is vital to ensure those who were close to going off supply or had already gone off supply have a longer-term fix to ensure they can keep their Electricity on. Debt and debt reclaim amounts are the main reason for people going off supply.
• Referred 396 people to other support organisations in the area, this will ensure they receive wider support in other poverty areas alongside the fuel support we provide ensuring we tackle poverty and inequality with a holistic approach.
• RSL’s have reported that this Project has provided the opportunity for tenants who are struggling with various forms of poverty to reach out for support for the Emergency Vouchers. This initial interaction has then led to more in-depth support being provided to tenants who would otherwise not have approached their housing provider.
• 135 Homes were provided by Winter Fuel (Briquettes, Kindling, Coal etc) for the winter months through the Winter Warmth Project.

April 2023-March 2024

Emergency Energy Payment Assistance Programme

• In total, 1,918 Vouchers have been issued to individuals and families who are struggling with Fuel Poverty within our Region.
• 421 of these have been issued to Private Rented Sector Tenants
• 427 of these have been issued to Loreburn Housing Association Tenants
• 1,070 of these have been issued to a combination of Wheatley Group Tenants, Cunningham Housing Association Tenants, Home Housing and Irving Housing Association Tenants throughout our Region.

The Lemon Aid Fuel Poverty Project are part of Cunningham Housing Association and deliver dedicated support to any resident within our Region who is struggling with Fuel Poverty.

In terms of the additional support which the Lemon Aid Fuel Poverty Project has delivered throughout our Region and through both initial contact with Tenants who they are directly supporting through our Project and also through referrals from other Project Partners / organisations within Dumfries and Galloway, the following have all been achieved:

• Total No. of people given advice & support to = 4,275
• No. of people reconnected after Self Disconnection = 347
• No. of people with complex issues/restricted meters assisted = 1,768
• No. Of Fuel Vouchers / Energy Top Up’s provided = 1,539 (please note that the Lemon Aid Fuel Poverty Project can also access energy vouchers from other sources)
• Amount of Financial Gain / Debt Reduction Achieved = £284,572
• Home Advice Visits Completed = 149
• Outreach Sessions / Events Attended = 91
• Referrals from Partner Agencies = 596
• No. of People Referred to Partners / Support Agencies from Lemon Aid Fuel Poverty Project = 306

The Hub – Warm Winter Fuel Project

• 155 Homes within our Region benefitted from the delivery of Winter Briquettes which helped to their fuel bills over the winter months.

April 2024 – March 2025

Emergency Energy Payment Assistance Programme

£100,000 of Poverty and Inequalities Policy Development Funding has again been allocated to our Emergency Energy Payment Assistance Programme. To date, we have received in results from the Lemon Aid Fuel Poverty Project for the time period of 1^st of April 2024-31^st August 2024:

• 1406 people supported in 5 months
• £69,896 of fuel debt reduced/removed altogether over the 5 months.
• 347 fuel vouchers distributed, that’s £17003 of fuel voucher value on top of the debt reduction.
• 103 people who had disconnected their energy, assisted to re-connect, and then provided with ongoing support.

This one Project alone has resulted in financial gain / fuel debt reduction of a total of £480,711.00 within the Report reporting period.

d) Support people to heat their homes efficiently in your area (behaviour)

The Energy Agency is a charitable organisation providing free, impartial and expert advice to households, businesses and communities, covering energy efficiency, renewable energy and sustainable transport. Their aim is to reduce energy consumption and promote sustainability locally, thus contributing to national targets.

The Advice Centre provides free, impartial energy efficiency and transport advice to householders, community groups, businesses and the public sector. Trained advisors can help customers access grant funding, interest free loans funded by the Scottish Government and other energy efficiency offers. Our Council and Partners work together on a wide range of Projects with the Energy Agency as well as a large number of continual referrals throughout each year. We provide opportunities for face to face engagement with residents including through events such as our Dumfries & Galloway Council Poverty & Inequalities Team Warm Winter Clothes Events which are held every November.

The Energy Agency is also a joint partner on our Dumfries & Galloway Poverty and Inequalities Partnership’s Sub-Group 3 which specifically looks at reducing the costs of residents within our Region. Their results and all outcomes are reporting directly to the Scottish Government which will include all actions completed within Dumfries & Galloway.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

The delivery of the ABS scheme has made a significant difference in helping householders to reduce their fuel needs. However, this only helps impact one of the key drivers of fuel poverty. The low wage nature of the area and rising fuel costs across the board mean that reducing fuel poverty requires a multi-faceted approach.

By introducing the Local Authority ECO4 Flex scheme to Dumfries and Galloway, the Council has brought significant investment in to the region. This is targeted at vulnerable households who have health conditions exacerbated by the cold, or be on a low income. The ability to provide renewable energy sources on properties, such as PV panels, means that the cost of fuel is reduced greatly.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following drivers on fuel poverty in Scotland?:

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

Yes to all of the above. All of the outcomes and details included within our Report have helped to substantially reduce each of the above drivers of fuel poverty.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

• Factors out-with our control such as increases in Energy Price rises
• High price of fuel costs due to rurality of our Region & lack of access to cheaper fuel options
• Rising costs of Petrol / Diesel which factor into fuel poverty for travel costs
• The lower wage economy of our Region.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

• Additional increased funding for the HEEPS ABS and all other Projects including the LA ECO4 Flex Project.
• Funding for Projects such as the Lemon Aid Fuel Poverty Project to be supported within each LA in Scotland to achieve similar results to the above. The removal reduction of fuel debt within households makes a huge difference both to their financial wellbeing and also their physical and mental health wellbeing.

Respondent: East Lothian Council

Over the reporting period East Lothian Council have taken a number of steps to reduce fuel poverty. Through EES:ABS the Council have targeted properties in areas of fuel poverty with the aim of improving the energy performance within private sector homes. Total spend for these projects in 2021/22 was £781,706.70, £572,823.73 was utilised in 2022/23 with £1,000,000 spent in 2023/24.

The Council have also made significant investment in Council Housing during this time to ensure properties meet EESSH standards. There has also been an increase in the number of Council properties with solar systems which should reduce bills for tenants.

In addition the Council have funded the East Lothian Energy Advice Service throughout this period. Funding for the service was increased from £47,990 in 2022/23 to £79,579 in 2023/24 with £58,971 of funding in 2024/25. The increased funding was to reflect the difficulties many faced during the cost of living crisis and the additional resources required by the advice service.

The service provides behavioural energy efficiency advice to help reduce costs in the home; support with billing and metering issues; supplier advocacy including billing queries, lodging complaints (supplier and ombudsman) and negotiating debt repayments; support to apply to hardship funds for debt reduction; heating system advice and investigation; tariff and switching advice; holistic support to include CO awareness, Priority Services Register registrations, Warm Home Discount applications and signposting/referrals to other relevant agencies.

In recent months the Council have also made efforts to coordinate energy advice providers within the county to ensure that the advice offered by providers across the region is reaching those who need it.

As previously stated, efforts to improve energy efficient within the private sector have been undertaken through EES:ABS. This includes cavity wall, loft insulation and external wall insultation. During this period 140 private & 40 social housing homes have been treated significantly improving the energy efficiency of a large number of properties within the region. In addition, properties within the Council’s own stock have received improvements in line with guidance.

The Council is not able to directly affect high energy costs. Actions to tackle high energy costs have generally been geared towards improving energy efficiency, thus lowering energy usage and mitigating some of the increases in the cost of energy. The Council through EES:ABS have installed 82 Solar PV systems including battery and an additional four battery only systems where solar panels were already in place. This will help to reduce fuel bills in these homes and go some towards lowering energy costs.

The Council through the East Lothian Advice Service have given advice to residents in relation to how energy is used in the home. Residents can phone the Energy Advice Service for assistance in relation to energy efficiency measures. The Energy Advice Service is funded by the Council who contributed funding towards the continuation of the service.

The private sector energy team will offer householders advice where they are in targeted areas. Advice will be provided in relation to which energy efficiency measures are best suited to their home and will also signpost them to other services where appropriate for example Home Energy Scotland.

(c) the progress made in the reporting period towards meeting the fuel poverty targets (including what progress has been made in removing low levels of energy efficiency as a driver of fuel poverty).

Insultation measures have helped to lower the number of properties with power energy efficiency in both the private and social rented stock. Solar PV also enables people to lower bills in particular when combined with battery back-up. These systems can significantly lower bills and reduce fuel poverty.

Funding will be necessary from the Scottish government and ministers should ensure that local authorities are able to take a long term or at the minimum a medium term approach. Annual funding makes this difficult.

It is also essential that there is some clarity on the best construction methods moving forward. This includes finalising things like the Passivhaus standard to ensure that new homes are built to the highest possible standards and reduce fuel poverty. Some best practice for different housing types would also be beneficial, in recognition that there is not a single approach that works for every home.

Again EES:ABS and measures undertaken by the Council in our own stock have contributed towards making properties more energy efficient across all tenures. The funding of the advice service will empower people to make choices that will enable them to lower their energy usage and reduce fuel poverty. It also provides advocacy helping many vulnerable people to access support when they are in debt or have problems with their energy provider.

Progress shown in the LHS 2024-29 shows that in recent years shows that at the time of publication the Council had increased the number of properties with heat pumps to 149 with 388 properties benefitting from solar panels.

Barriers faced locally include high energy prices and poorly insulated homes. Treating homes in rural locations is also a challenge, as are traditional buildings which are listed or in conservation areas. One of the main barriers is homeowners being unable to afford or unwilling to undertake the cost of energy efficiency improvements. It has also been noted that there is often a lack of tradespeople specialising in energy efficiency retrofitting within East Lothian meaning that even those who wish to undertake the work will have problems.

Another barrier is the lack of funding and criteria for available funding being too stringent meaning many households do not qualify. Many areas within East Lothian are relatively affluent and will have a household income above the threshold to qualify for funding.

This means that a lot of work is not undertaken. High housing costs also mean that although a household may earn what is considered a reasonable income, however disposable income is not as high as would be expected meaning energy efficiency improvements take a back seat to more immediate needs such as paying the mortgage.

The lack of willingness from households to undertake improvements is another barrier. For example in some cases it has not been possible to deliver energy efficiency measures in mixed tenure blocks of flats where an owner is reluctant to undertake the work despite the willingness of other owners. Private landlords are also often less willing as they do not meet the funding criteria and will be liable for the full cost of measures. This often means that tenants in fuel poverty in the PRS are unfairly penalised.

Another challenge is the lack of direction from Government in terms or best practice. Councils are being left in limbo without clear guidance on how they should best undertake these works to improve energy efficiency and reduce fuel poverty.

Energy advice service and internal council teams including the energy team will support people to heat their homes more effectively within East Lothian. Housing officers will also offer advice to tenants living in East Lothian Council properties.

Yes, the LHEES was approved in November 2025. LHS has been published and recognises the current risk for an increasing number of households falling into fuel poverty and extreme fuel poverty. The LHS contains actions relating to improved energy efficiency which will result in lower levels of fuel poverty. Actions taken by the private sector energy team have helped to reduce fuel poverty through improved energy efficiency, reducing fuel bills and targeting those in areas where deprivation is highest.

East Lothian Council financial inclusion team offer long term solutions to financial issues, maximising income and challenging benefits decisions for those on low incomes. In addition work has been carried out to help raise awareness of Pension Credit and the link to the Winter Fuel Payment, supporting the DWP’s publicity campaign.

East Lothian Council financial support team provide assistance for more immediate needs such as the Scottish Welfare Fund, providing crisis grants and community care grants.

There are numerous challenges within East Lothian. In terms of EES:ABS one of the main challenges is getting people to sign up. A number of people do not trust the scheme and are worried about being scammed. The age group tends to be older as they often have a better chance of meeting the criteria. There is also a reluctance to change from some households for example they would prefer to stick with fossil fuels rather than switch to cleaner energy. For Council housing one of the main challenges is working with other owners in mixed tenure blocks where private owners are unable to afford or unwilling to undertake work to improve energy efficiency which would lower fuel bills and reduce fuel poverty.

As more houses are insulated locating homes that require and qualify for funding under EES:ABS becomes more problematic and time consuming.

The data available to analyse areas where measures are required is often incorrect, for example Home Analytics data is often wrong. In particular data supplied from the EPC register which is often incorrect and labels for example homes of the same construction as different construction types e.g. system built homes as traditional build with the adjoining property labelled as system built. The data often has incorrect information in relation to insulation. As the data is cloned, where one home is wrong, it can mean that the rest of the street is too.

Further action from the Scottish Government could include more regular data releases at local authority level to allow better analysis to be undertaken for example Scottish Household Condition Survey. Improved data gathering would also be beneficial as some of the information currently available is not fit for purpose. More funding for energy efficiency measures is necessary if these targets are going to be met. More forward planning in terms of funding so that schemes like EES:ABS can look to the future, with annual funding it is difficult to look too far into the future. Higher thresholds for funding measures to allow more households to qualify would also be beneficial, a one size fits all national approach is not always best. New EPC guidelines and the EPC as a live document are too other suggestions.

Respondent: East Ayrshire Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

The East Ayrshire Council Strategic Plan 2022 to 2027 highlights the cost of living combined with rising inflation, increasing fuel and food costs, interest rates and the energy price cap are having a significant impact across East Ayrshire.

The East Ayrshire Children and Young Peoples Service Plan 2023-2026, that incorporates child poverty action planning and reporting, highlights the influence of poverty on children’s health and wellbeing. Children living in poverty are more likely to have poorer health outcomes including low birth weight, poor physical health and mental health problems, with significant health impacts across their lives. The report confirms, in 2022, 19.9% of children aged 0-15 years were living in relative poverty, with 25.5% of children living in low-income families.

Age UK’s research We have to take it one day at a time into the health and care of people aged 50 and over highlights ‘[m]any had made difficult choices to cut back on heating, food and going out of the house last winter and expected to be doing the same again as the winter approached.’ It further reveals ‘people in their 50s who were really struggling to manage the onset of multiple health conditions and caring responsibilities … in many areas, people aged 50-59 years are having a particularly hard time as financial insecurity and the cost-of-living compound those health and wellbeing challenges.’

In terms of local demographic trends, the East Ayrshire Health & Social Care Plan 2021- 2030 records population projections, noting those aged 65 years and over will increase by 15.3% between 2018 and 2028. This changing demography will impact both the services and support required, with those aged 65+ living in housing rather than care home/ hospital settings increasing from 96.8% to 97.4% between 2014 and 2020.

Food poverty, physical, mental health and wellbeing, as well as caring responsibilities are therefore all impacted and present challenges to vulnerable service users where they struggle to live at home for longer, with affordable warmth.

Recent feedback from our LHEES engagement work also suggests a number of potential barriers and challenges for tackling energy efficiency and related fuel costs:

• High energy prices and ongoing volatility, with limited impact from the price cap. In particular, the relative cost of electricity and the risk of transitioning to electric powered heating systems.
• Uncertainty over the availability and eligibility of funding to carry out energy efficiency retrofit works.
• Hesitancy over moving to low carbon heating, as a result of being able to find trusted contractors and understanding how newer systems work compared to gas boilers.
• Perceptions that the cost of energy efficiency retrofit is too high or uncertainty over which measures provide the best value for investment. This is a particular challenge as property prices in East Ayrshire are generally lower than national averages.
• Incomes have been impacted by the cost of living, compounding the impacts of higher energy bills.
• 12% of homes are pre-1919 construction, which typically have low levels of insulation and high levels of ventilation. This construction type also presents particular challenges for energy efficiency retrofit.

East Ayrshire, particularly the south of the Authority, has amongst the highest rates of residents suffering from respiratory illnesses and heart disease. Medical conditions such as chronic obstructive pulmonary disease, asthma and heart conditions are exacerbated by poorly heated homes. For these people, it is particularly important to keep warm and some require specialist equipment and oxygen, which in itself leads to additional energy costs.

Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

b) Increase local incomes in your area

c) Reduce energy costs in your area

d) Support people to heat their homes efficiently in your area (behaviour)

Since December 2021 East Ayrshire Council (EAC) has been, and continues to be, proactive in taking measures to tackle climate change, improve the energy efficiency of our buildings and reduce the likelihood of fuel poverty. Priority 4 of our LHS is that “People in East Ayrshire live in high quality, energy efficient homes and fuel poverty is minimised” and this is supported through the Council’s Climate Change Strategy, Local Heat and Energy Efficiency Strategy (LHEES) and Community Renewable Energy (CoRE) project.

Our LHEES will be the primary framework for co-coordinating and developing projects specifically aimed at improving energy efficiency, particularly LHEES consideration #5, which is to reduce poor energy efficiency as a driver of fuel poverty.

Highlights of what we have achieved include:

• The Council completing its first net zero housing development in 2023, delivering 18 new homes. A further 48 new Council homes, nearing overall completion, will augment this delivery in Kilmarnock.
• Working collaboratively with East Ayrshire Health and Social Care Partnership, the Council’s first net zero assisted living housing model completed in 2023 in Mauchline.
• As of 31 March 2023, 99.52% of East Ayrshire Council’s housing stock met EESSH1.
• The ongoing commitment to the improvement of our housing stock, through replacement heating and building fabric upgrades.
• The ongoing delivery of Area Based Schemes (EES:ABS).
• The Eco4 Scheme is now operational and being managed by the Climate Change Team and the Energy Agency on a self-funding basis. An approved list of contractors is in place and to date 108 applications have been approved, 61 of these have supported residents via the low income route, with the remaining 47 supporting residents with qualifying health issues. Decarbonisation and green energy works have now been completed at 67 properties at an average cost to the energy companies of just under £21,000 and this has secured a total investment approaching £1.4 million since the scheme went live in April 2023. It is estimated that these works will save householders on average just over £2,000 per annum and deliver an area wide reduction in our carbon emissions of 420 tCO2e. With works to a further 27 properties already programmed, it is anticipated that this will bring the total investment secured within East Ayrshire to over £2 million by the end of this year.
• Working with local partners such as Citrus Energy and East Ayrshire Citizens Advice Bureau to ensure residents and tenants have access to impartial and effective advice on issues of energy and heating.

The Energy Agency also delivers a range of services in East Ayrshire, and is our current delivery agent for ECO4 through LA-Flex.

Our Climate Change Strategy includes actions aimed at changing behaviour toward energy use and understanding how resources can be used more efficiently. These will all continue to be supported and advanced through our first LHEES and Delivery Plan, which is due for imminent publication.

Looking ahead, our Housing Asset Services team are delivering domestic EnerPHit and PAS2035 pathfinders to better inform future approaches to domestic retrofit. In addition our Community Renewable Energy Project (CoRE) aims to showcase how a green recovery can transform our rural towns and villages and make our communities better connected, healthier and improve the standard of living, through a just transition, whilst supporting the creation of long-term sustainable jobs.

In September 2022 an extensive Communications Campaign was launched in East Ayrshire to help tackle the cost of living crisis and focused on the six key identified themes of Food, Money, Fuel/Energy, Community, Business and Wellbeing. In recognition of the growing crisis, a Cost of Living Officers Group was established to coordinate our local response. Following on from this, we are developing a Local East Ayrshire Anti-Poverty and Inequalities Strategy to ensure continued support across the 6 themes.

EAC also delivered a schools-based financial inclusion pathfinder project providing targeted support to families in financial difficulty. This aimed to address the wider impact of poverty on children’s health, wellbeing, education, employment and future life chances. The project is also contributing to related learning activity within schools on income and money management. As of April 2024 693 families have been supported through the schools based financial inclusion pathfinder project generating financial gains of around £1,842,314.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

In terms of our own housing stock, 689 obsolete and inefficient heating systems were replaced in 2022/23, and 145 properties had external enveloping works carried out. This will directly impact the cost of keeping these homes warm.

Area Based Schemes (EES:ABS) resulted in an estimated £117,720 in annual fuel bill savings (2022/23), with 218 properties benefitting from external wall insulation, helping to improve energy efficiency in mixed tenure buildings.

Under ECO4 an approved list of contractors is in place 108 applications have been approved to date (2023/24). Decarbonisation and green energy works have now been completed at 67 properties at an average cost to the energy companies of just under £21,000 and this has secured a total investment approaching £1.4 million since the scheme went live in April 2023. It is estimated that these works will save householders on average just over £2,000 per annum and deliver an area wide reduction in our carbon emissions of 420 tCO2e. With works to a further 27 properties already programmed, it is anticipated that this will bring the total investment secured within East Ayrshire to over £2 million by the end of this year.

In 2023/24 the Energy Agency also delivered a range of services in East Ayrshire, resulting in £309,391 overall annual fuel bill savings and 3,228 households receiving verbal advice on energy efficiency, behavioural changes, water, transport and renewables.

In terms of increasing local incomes, our Financial Inclusion Team generated £8,997,725 in total financial gains (2023/24) and a new Tenant Support Fund was created to support Council tenants and mitigate the challenges of increased living costs.

Income generated by the Universal Credit Support Team over 2023/24 totalled £496, 688.

Partner Agency Citrus Energy made financial gains/reduced debt for residents worth £427, 810. They also reconnected 750 residents to their disconnected energy supply and distributed 1893 fuel vouchers to East Ayrshire residents.

Some of the interventions delivered since December 2021, particularly around support for the cost of living, have been hugely beneficial but are not sustainable in the absence of the funding that was made available at the time.

Set in a wider national policy context of ongoing consultations and proposals to enhance housing and energy standards across Local Authority and Registered Social Landlord new build and existing stock, there is a failure to recognise the affordability impacts these proposals have on private owners, social landlords and tenants alike, particularly in areas like East Ayrshire where property values remain very low and borrowing to fund adaptations will be a significant challenge.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

High fuel prices remain an issue, despite retreating from a relative peak in 2023. From 1 October to 31 December 2024 the energy price cap is set at £1,717, representing a 10% increase over the previous quarter; increasing fuel/heat costs can undermine other efforts to tackle fuel poverty.

Whilst as a social landlord, we have addressed building fabric issues to reduce poor energy efficiency and our Financial Inclusion Team and other initiatives outlined above have been highly successful in maximising income, our LHEES data shows that the most inefficient and poorest energy performance ratings are found within those that are privately owned. Home Energy Scotland was established to address this problem, however, there is limited evidence that the incentives and funding offered by Home Energy Scotland is making any significant difference in tackling poor energy efficiency in private houses.

As part of the energy work stream in our cost of living response, a social media campaign, supported by an eco cook book and the provision of energy efficient cooking packs, which included air fryers were distributed to those most in need via our extensive network of home larders.

Our Climate Change Team will continue this behaviour change campaign to promote energy saving good practice by sharing tips and information under our ‘Powerdown’ initiative which will be promoted in our schools, workplaces and to the wider community.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

As a responsible landlord, EAC is able to directly address the ‘poor energy efficiency’ driver of fuel poverty in our own housing stock but our influence over other drivers is limited. As a local authority we have no control over the cost of energy for heating homes, which undermines other efforts to tackle fuel poverty through improved energy efficiency.

As set out in Housing to 2040, the Scottish Government’s consultation relative to a Social Housing Net Zero Standard (SHNZS) details ambitious targets across work streams and implementation timelines, with significant associated on-costs. The proposal is set against a raft of other national legislative and policy implementation implications in a wider challenging economic context across the public sector and the construction industry. To date, twelve Local Authorities have declared a housing emergency. Sustainable service delivery therefore remains a key consideration for the Council and partner social landlords in tackling fuel and other forms of poverty, seeking to mitigate unintended negative consequences for service users.

The cost of intervention at scale is also a challenge. Our LHEES estimates that 36% of homes in East Ayrshire have uninsulated walls, but the cost of intervention is high. We see a large opportunity in privately owned homes, which have generally lower levels of energy efficiency (65% of homes are owner occupied and 58% of these are estimated to be in EPC bands G-D) but owners face difficulties in justifying the capital cost of upgrade based on energy saving alone.

Identifying affected homes remains a challenge and highlights the limitations of measuring fuel poverty using aggregated data rather than identifying those actually living with it. LA’s can use data (such as Scottish Household Condition Survey results) to estimate fuel poverty, and assess the energy efficiency of a building but this doesn’t guarantee identification of homes in fuel poverty. Proxies such as SIMD can be used to estimate a likelihood but financial circumstances affect the ability of individuals to heat their homes to an acceptable standard. Such level of information is, rightly, private and not fully represented by income level alone.

Improved energy efficiency can reduce demand, but ultimately the local authority has no control over high fuel prices or how individuals use energy in their homes. Accessing income and other financial information may not be in the interest of local authorities but it highlights that outwardly similar homes can be living in very different circumstances.

Finally, funding and incentivising change requires time and a dedicated resource. To date this function has primarily rested with Home Energy Scotland. Given the new responsibilities that local authorities have around LHEES delivery plans, it may be more effective for this funding to sit with local Councils to allow for a more targeted and cost effective approach to improving energy efficiency, particularly in owner occupier homes.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

While the focus on establishing heat networks at scale is welcome, this is not expected to be a quick solution and seems unlikely to be viable at scale in rural areas. Given that 65% of homes in East Ayrshire are owner-occupied there would appear to be an opportunity to further support this tenure group in making their homes more efficient. This would reduce exposure to the impacts of high energy prices, low income and the inefficient use of heat in the home.

Alternative heat sources and housing standards that support national and local climate targets will continue to be impacted by affordability considerations; both in terms of installation/ running costs and efficient heat delivery. Without recourse to realistic, sustainable resources, social landlords, home owners, private landlords and tenants will continue to struggle to mitigate and address the impacts of fuel poverty in the short and longer terms.

The Local Heat and Energy Efficiency Strategies (Scotland) Order places a new obligation on authorities to set out a long term plan for their area but it is not clear how authorities will meet the financial ‘scale of the challenge’, which is substantial. In particular, levels of energy efficiency in private homes lag behind publicly rented homes but the current funding landscape can be unclear, particularly in terms of timing and eligibility.

We also see potential for fuel poverty to be exacerbated where heat pumps are sold into homes without a credible assessment of the fabric suitability, leading to increased heating costs compared to an efficient gas boiler. Clear standards for these types of installation would help to reduce this risk and provide confidence to homeowners, landlords and tenants. The disparity between current electricity and gas prices adds to this risk.

Heat networks – from current policy there is an ambition to rollout heat networks at scale, but authorities are having to find innovative ways to deliver heat networks that are often not replicable at scale. Business cases also typically have to be justified against a ‘counterfactual’ situation of the gas network which represents national infrastructure with decades of investment.

In Scotland, we have an abundance of green energy generation opportunities and East Ayrshire has a particular abundance of wind energy. Whilst these large scale windfarms deliver green energy at scale, there is virtually no benefit to the local communities in terms of lower energy costs. Innovation around local energy production and the potential to use local private wire systems, supplemented by battery storage to give a stable and more affordable supply of electricity to these communities would be welcomed and could offer a more sustainable alternative to district heating systems. Some funding to test alternative approaches for decarbonising rural communities would be welcomed.

Respondent: Fife Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

We have seen ongoing significant challenges for Fife tenants and residents, particularly from winter 2022/23. We have seen high levels of expressed demand for crisis support predominantly for those on lowest income, and our own research with struggling tenants has found that through the colder months many have had to resort to asking family and friends for support; changes to their behaviour (e.g. limiting the rooms they use in the house and have to heat, shifts away from home heating to personalised warmth (clothing, blankets etc), and in extreme cases difficult decisions between heating and eating. We know too that most have had difficulty in building resilience to winter cost pressures, regardless of strong local prevention work.

Greatest impacts have been on those using prepayment meters (majority of our council housing tenants) where there is no opportunity to spread costs over the year but rather most consumption and costs are over 4 or 5 months. We expect winter 2024/25 to be difficult in the face of rising fuel prices; rising home energy debt that must be serviced alongside ongoing consumption; and the ending of some national financial support schemes and the narrowing of eligibility for others.

It is worth drawing particular attention to the increasing levels of fuel debt as a particular challenge. Last year, the Council’s money advice partners Citizens Advice and Rights Fife, our local CAB, identified fuel debt as the 13th main debt factor – this year it the 4th. Discussions with Citizens Advice Scotland suggest that this reflects the position across Scotland. Whilst we cannot attribute that rise to the closure of the Scottish Government’s Home Heating Support Fund, the fact that that scheme is no longer in place limits the options to support local households. The debts involved and the scale of the debt precludes us locally offering financial solutions to alleviate that debt and instead we are ensuring that we have sufficient resources in the right place to support tenants in their discussions with energy provisions, and to ensure swift rooting to debt advice services.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland,” for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHEES). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area.

Fife Council’s Local Heat & Energy Efficiency Strategy (LHEES) and high- level delivery plan were published in November 2023. A detailed delivery plan is being developed (published by March 2025). This will collate a range of actions already being taken forward by various teams across the Council. Fife Council have also developed an optioneering model to help identify new building level actions for domestic properties. This scores various indicators aligned with Fife’s LHEES priorities including priority 2 - “Tackling Fuel Poverty, Health & the Just Transition. ” This will help ensure fuel poverty risk is considered when determining new actions.

We have developed a Fuel Poverty Composite Index which identifies the risk of fuel poverty at the datazone level (similar process to the Scottish Index of Multiple Deprivation). This uses indicators linked to heat demand and ability to pay. It will be used to help target areas for intervention, as well as informing long term preventative measures such as retrofit and heat network planning.

Fife Council currently target the measures delivered via the EES:ABS schemes based on SIMD ranking, average fuel bill and energy efficiency rating of the properties targeted. This allows us to target the investment where it will get the maximum benefit. We primarily target a fabric first approach and deliver external wall insulation to non-traditional wimpey no- fines properties, improving the energy efficiency of these homes and reducing fuel bills.

b) Increase local incomes in your area.

Community Wealth Building is covered under LHEES priority 3 – “An Inclusive Economy , Jobs & Skills.” The Council are exploring the expansion/creation of new district heat networks. These are seen as a mechanism to help increase community wealth – especially when paired with local renewable energy generation and storage.

The Council have undertaken analysis to determine domestic and total energy spend across the Council area (~£400m domestic gas and electricity spend, with total energy expenditure likely to be close to £1 billion). This money leaves the local economy. If a proportion of this spend can be internalised, using heat networks and local energy generation/storage, this could result in more money circulating the local economy, helping build community wealth.

A separate study on jobs and skills requirements for domestic retrofit, heat pumps and heat networks has also been completed for the Edinburgh and South-East Scotland City Region Deal. This provides an indication of the level of jobs and training required to meet LHEES objectives. This would have the potential to build the local skill base and improve incomes.

c) Reduce energy costs in your area.

Early in the LHEES process, Fife Council determined Fuel Poverty should be its own priority, and not solely linked to energy efficiency. This decision was made as the electrification of heating will have potential impacts on energy costs (negative and positive).

As detailed above, Fife Council are looking at the expansion/creation of heat networks. District heating is viewed as a mechanism to tackle fuel poverty at scale. To achieve this the following is being explored:

• Revising the LHEES heat network zoning approach to identify additional zones and making the original zones larger. This will help ensure social housing clusters are seen as viable areas for heat networks to supply. This work has been carried out with input from technical experts and heat network operators and will inform our requirements to designate heat network zones.
• A pilot place-based energy plan is being developed for Dunfermline & Rosyth, using Heat Network Support Unit funding. This will explore how local energy generation and storage can support a settlement wide heat network which will help reduce energy costs in the area and support future expansion of the existing network.
• The Council are also using Heat Network Support Unit funding to appoint legal support to review potential delivery bodies for heat networks and the wider energy system. All models to be reviewed will include the Council retaining some element of control to ensure the wider LHEES priorities (including tackling fuel poverty) are being met. For example, ensuring social and private housing connects to a heat network, and fuel costs for the public do not increase fuel poverty.

d) Support people to heat their homes efficiently in your area (behaviour)

Priority 4 of the LHEES – “Maximising Knowledge & Awareness” focuses on communications and behaviour change. Actions against this will be provided in the detailed delivery plan once published.

Please note the actions highlighted in 3 below.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Our local priorities include spreading of access to crisis support targeting need rather than simply expressed demand; spreading capacity amongst services and agencies to offer first level home energy advice and freeing up expert service to address more complex cases; proactive financial support for council tenants in low fuel efficient properties, those with damp and mould, and those moving into temporary accommodation; providing advocacy support for residents affected by fuel debt in brokering arrangements with home energy providers; offering warm and welcoming spaces in communities; ‘handy services’ installing energy saving measures in homes and a boiler repair scheme for home owners unable to meet costs. We plan to deploy a Fuel Poverty Composite Index (see answer below) to help with sharpened targeting of support.

While we continue to evaluate and review our actions, our view, informed by direct research, is that the support we provide is having a positive mitigation impact but not eliminating household struggles. We are presently finalising work on the social return on investment in home energy advice services and our handy services and assessing the impact of our initiative to build capacity of those services working with vulnerable households to offer first level home energy advice. We collect and use operational data to continuously review who is accessing crisis support, and much of our work is captured through report on fuel poverty indicators through the LHS.

Delivery of the LHEES is still in the planning stage. With the actions detailed in Q2, helping move the Council towards taking actions which will help improve fuel poverty over the long term.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

See Q2/3

b) High fuel prices?

See Q2/3

c) Low income?

See Q2/3

d) Inefficient use of heat in the home (household behaviour)?

See Q3

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

From an LHEES perspective the following has made delivery challenging:

• The linking of gas and electricity prices at the UK-level. This keeps gas prices artificially low. This presents a challenge for transitioning to electrified heat, as air source heat pumps will likely be more expensive than a gas boiler. The exception would be for highly energy efficient homes. However, this could exclude large portions of society who cannot afford the retrofit prior to installation of a heat pump.
• Lack of fuel poverty data - LHEES uses Home Analytics as the key domestic dataset. This has a measure of fuel poverty probability. However, this is based on the Scottish Household Condition Survey, and as such uses a small sample. As far as we can tell it has not been updated since the energy crisis and can only be used as a rough guide for prioritising action. This restricts our ability to target the most vulnerable. We also lack data on pre-payment meters (an indicator of fuel poverty risk), with the most up-to-date data being from 2017.
• Personal Data – Home Analytics is classified as personal data, and Councils are restricted in what they can show publicly. This is despite it being data tied to buildings rather than people. The ability to show building level data publicly would help in future communications/behaviour change campaigns to let people know what energy efficiency/heat decarbonisation improvements can be made to their home – helping to reduce energy bills.

Such is the scale of people facing affordability challenges and winter fuel crisis that much of our work is necessarily response to expressed demand for that support. A challenge is to better identify and target those in need and support those who are less able to navigate to available support or who generally make do, perhaps to the detriment of their own wellbeing.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

• An improved national dataset on fuel poverty probability, and other factors which impact fuel poverty such as pre-payment meters. This would further help refine LHEES planning moving forwards.
• Help in unlocking the ability to publicly show LHEES data at the building level. This would help ensure people make informed decision on how to improve their homes, thereby reducing their energy bills.
• Heat networks can help to tackle fuel poverty at scale. However, significant amounts of funding is required to undertake feasibility studies/business cases to move these forward. Funding at the moment is limited, which restricts the ability to move at pace.

Respondent: Falkirk Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

Affordability

Energy costs have significantly increased since 2019, but incomes haven’t kept pace. This has made it harder for all households, especially those with lower incomes, to afford fuel. In addition, rises in the overall cost of living have had a negative impact on people’s disposable incomes, exacerbating the problem.

Access to Information

Some people struggle to find information on heating assistance. This is often down to digital exclusion, both lack of digital skills and also lack of internet access due to cost. This can hinder people’s ability to seek help. We are addressing lack of digital skills through our libraries, with all library staff trained as digital champions. We have provided support with the cost of getting online through a cash first approach using our Household Support Fund, and digital inclusion work providing sim cards with data to low income households.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHEES). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

b) Increase local incomes in your area

c) Reduce energy costs in your area

d) Support people to heat their homes efficiently in your area (behaviour)

a) Improving Energy Efficiency

External wall insulation (EWI) has been installed in 194 private homes and new heating systems in 27 homes as part of the Falkirk Combined Heat & Power (CHP) project.

The Housing Investment Plan has enhanced energy efficiency measures through programmes of improvement, including the installation of PV Panels with battery storage in new build homes and investment in existing housing stock including new high-energy-rated gas boilers, air source heat pumps (ASHP), solar panels, and battery storage. Insulation improvements include cavity wall insulation (CWI) and external wall insulation (EWI). Other measures include replacement windows and doors programme which tenants have said have significantly reduced fuel consumption and costs.

b) Increasing Local Incomes

We have taken a strategic approach to addressing poverty through maximising household income and resources, which is reflected in our recent Building a Fairer Falkirk Strategy and also in previous strategies. Our approach places income maximisation through advice services and targeted support at its heart.

We are also focussing on the effective use of personal data to identify households missing out on entitlement to benefits and have provided direct cash support using a trusted partner referral model through our Household Support Fund.

We also created Household Support Officer posts to support our income maximisation activities, bolstering the capacity of our Community Advice Services team.

c) Reducing Energy Costs

As noted above, we have worked hard to improve energy efficiency by insulating homes and installing efficient heating systems to reduce running costs, despite rising energy prices. We have also worked in collaboration with Home Energy Scotland for the provision of energy advice to households, and in providing fuel vouchers to support those struggling to meet costs.

d) Supporting Efficient Home Heating

We provide regular staff training on understanding fuel poverty and signposting for support, with 160 frontline staff trained between 2021 and 2024. We have also provided energy advice to our communities through various channels, including our website, tenant publications, social media and leaflets.

In addition to this, community events and initiatives like our Climate Festival have helped raise awareness. We provided information on the funding available to households to support them both with their bills, and in improving the energy efficiency of their homes.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

There is no specific mechanism in place to measure fuel poverty in our area. Instead, we are reliant on data from the Scottish House Condition Survey. Although our actions have resulted in improved energy efficiency for many homes and mitigated the impact of rising costs for those in greatest need of support, the fact that energy costs remain very high when compared with their historic levels mean that many people may not recognise the impact of this work in their energy bills.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

a) Poor Energy Efficiency

The installation of improved insulation and installed energy-efficient heating in council-owned homes, and external wall insulation and upgraded heating systems in privately owned homes have had a positive impact on the energy efficiency of those properties.

We have also provided updates and presentations to private sector landlords on improving the energy efficiency of privately rented homes, helping lower bills and improve energy efficiency for private sector tenants.

b) High Fuel Prices

Whilst we cannot influence the cost of fuel, our work to maximise incomes and improve the energy efficiency of homes has helped to mitigate the impact of higher costs.

c) Low Income

As noted above, we have worked hard to increase household incomes through income maximisation work. The benefit gains achieved for households through our Community Advice Services, Advice and Support Hubs and partners such as Citizens Advice Bureau help improve their resilience in the face of high energy costs. We have also provided direct cash support through our Household Support Fund and additional help including access to fuel vouchers n(primarily through our Support for People contact line).

d) Inefficient Use of Heat in the Home (Household Behaviour)

Staff training has been provided to ensure advice can be provided to our tenants on energy- saving practices. This includes training on the effective use of air source heat pumps (ASHP) and electric wet heating systems. This has supported our tenants to make more efficient use of their energy.

We have also linked in with Home Energy Scotland for the provision of advice, as well as providing advice through various channels, including our own web pages, tenant publications, and social media.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

Rising Fuel Prices

The significant increases in the cost of domestic fuel presents a major barrier. Many more people are presenting looking for support with debt incurred due to rising costs.

Staff Capacity

There is limited staff capacity to support initiatives which can help address fuel poverty.

Customer Demand

We continue to experience extremely high levels of demand for support, and repeated requests for support from the same people. This indicates the difficulties people face as they have to spend a higher proportion of their income on fuel.

Engagement and Identification

There are difficulties in identifying and engaging with many of those most in need, especially those who face barriers to digital inclusion due to cost and/or lack of digital skills.

Funding Issues

Funding to support initiatives is limited and is often offered on a competitive basis. Unsuccessful funding applications have prevented us from doing more to support those in need of help.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

• Subsidise or regulate fuel costs – implement measures to control or reduce the costs of domestic fuel.
• Funding – ensure ongoing funding for vulnerable households is provided through Home Energy Scotland (HES). Also continue to provide funding for the Area Based Schemes, Social Housing Net Zero Fund, and grants/loans administered by Home Energy Scotland.
• Negotiate with utility companies – work with utility companies to redirect funding and reduce fuel costs for struggling households.
• Review Winter Fuel Payment Criteria – reconsider the qualifying criteria for the Winter Fuel Payment to best support those in need.

Respondent: Glasgow City Council

What barrier or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

There are several barriers/challenges that households living in Glasgow currently face in terms of being able to heat their homes according to their needs:

• Increase in energy costs has pushed more households into fuel poverty. Concerns relating to people on lower incomes, families, pensioners and people with disabilities. Increase in standing charges.
• Energy debt.
• The associated impact that the removal of the Winter Fuel Payment is expected to have on pensioners.
• Condition of housing stock particularly homes that are in poor condition or not insulated. Glasgow has a high proportion of homes in disrepair and high energy, difficult to treat properties in multi-owned buildings.
• Levels of poverty – Impact of inflation on household income.
• Existing funding criteria for the Scottish Government’s Area Based Schemes (ABS) Programme including restricted funding access for private landlords towards installing energy efficiency measures. This impacts on the delivery of measures in mixed tenure blocks. The ability of owners to afford to participate in ABS projects.
• Lack of tariffs available for low -income households and customers who use pre-payment meters. Inability to access off-peak cheaper energy. Disproportionate standing charge costs for low energy use households.
• Inefficient direct electric space and hot water heating systems.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

• Delivery of the ABS programme. In line with Scottish Government guidance, the Council identifies households meeting the Scottish Government’s ABS criteria in geographical areas that are:
  • Within the lowest 25% Scottish Index Multiple Deprivation (2020).
  • In Council Tax Band A-C and Tax Band D in certain conditions.
  • Where people are living with conditions vulnerable to the cold.
  • Undertaking an analysis of potential approaches to deliver a large-scale housing retrofit programme across Glasgow to improve the energy efficiency and decarbonise homes leading to fuel poverty and carbon emission reductions. This is being delivered by the Council’s Housing Retrofit team and a particular focus is being channelled to find solutions for “hard to treat” properties such as pre-1919 tenements and fuel poor households.
  • The Affordable Housing Supply Programme has delivered hundreds of affordable homes to Passivhaus and the sustainability criteria outlined in the Glasgow Standard. Delivering new energy efficient and well insulated homes reduces energy bills and fuel poverty.

Development of the city’s Local Housing Strategy and Local Heat and Energy Efficiency Strategy. Both are strategic documents that outline the city’s focus on sustainability and improving energy efficiency and standard of housing stock. Local Housing Strategy priority 2 outlines “Improving the energy efficiency of Glasgow’s homes, reducing fuel poverty and supporting a Just Transition to Net Zero through decarbonising domestic heating and energy.” The Local Housing Strategy is closely aligned with the Council’s Local Heat and Energy Efficiency Strategy.

b) Increase local incomes in your area

• The Council created ‘Glasgow Helps’. This service provides a range of areas including welfare rights and initiatives that could help residents increase their household income.
• Glasgow’s PRS Housing and Welfare Hub - The Private Rented Sector (PRS) Housing and Welfare Hub is a holistic and multi-agency support service that works with partners to support tenants, particularly families, residing in the private rented sector many of whom are at risk of homelessness and living in poor quality housing. A priority of the Hub is to provide support to families that are living in poverty, which has been exacerbated by welfare reforms, the cost-of-living crisis and housing emergency in Glasgow.

c) Reduce energy costs in your area

• Energy efficiency improvements to reduce energy demand and thereby energy costs are outlined in Section 2 a. The Council’s Local Heat and Energy Efficiency Strategy (published in 2023) outlines intentions to accelerate the deployment of district-scale heat networks in Glasgow in an effort to reduce heating-based emissions and tackle fuel poverty. However, reducing fuel poverty via heat pump supplied district heating remains challenging in the UK given the high cost of electricity relative to gas. In light of this, Glasgow City Council is exploring approaches that could enable the use of lower cost electricity to run district heating, creating a local landscape where heat via district heating can be offered at a price lower than a gas boiler. This could reduce fuel poverty for those connected.
• The Council owned Dalmarnock Village district heat network provides heat and hot water to hundreds of homes at affordable rates indexed to the price of gas to mitigate higher energy costs and fuel poverty.

d) Support people to heat their home efficiently in your area (behaviour)

• Promotion of services provided by Home Energy Scotland and the Wise Group and publishing advice on the Council’s webpage. Information relating to reducing energy costs is also provided to residents through the Council’s ABS programme.
• Work with partners through the Retrofit Advisory Group and heat pump accelerator group to monitor and evaluate the impact of retrofit measures. This includes installing sensors to capture data and carry out engagement and surveys with residents to understand the impacts of behaviour and choice on monitored outputs.

In your opinion, have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Yes. The outcomes from all workstreams outlined in section 2 have either had a direct positive impact on residents’ fuel bills or will establish future outcomes that will have a direct positive impact. However, due to the increase in energy costs, it is forecast that more households are living in fuel poverty than during 2021. If GCC had not delivered these successful outcomes, the blight of fuel poverty in the city would undoubtedly be higher.

Evaluation of the ABS programme has confirmed that residents have lower energy bills and improved well-being because of the energy efficiency measures. Although vital, the programme remains small scale (6,000 private properties improved between 2013-2024). An expanded programme would extend its reach and further mitigate fuel poverty. Between 21/22 and 23/24, energy efficiency measures have been installed to a total of 632 privately owned properties and 2,498 RSL owned properties through the ABS programme.

There are 59 RSLs that own housing stock within the city. RSLs continue to maintain and improve the condition of their existing housing and develop new energy efficient homes through the Council’s Affordable Housing Supply Programme. Between 2020/21 and 2023/24, the Council worked with RSLs to complete 2,852 affordable homes. New build homes assist in reducing levels of fuel poverty as they incorporate high quality sustainability design standards. Households then experience the benefits of lower energy consumption and lower fuel bills. As outlined in the Council’s new Strategic Housing Investment Plan (25/26 to 29/30) there are opportunities to potentially support the development of 6,637 new affordable energy efficient homes, which will contribute towards reducing fuel poverty.

RSLs also provide wider role support that includes energy advice/support to tenants. This support includes applying for support such as fuel grants.

A Council survey of Glasgow RSLs in September 2023 confirmed the majority have made substantial in roads to achieving the Energy Efficiency Standard for Social Housing (EESSH & EESSH2), which will have contributed towards reducing the number of households exposed to fuel poverty. Most RSLs are waiting for confirmation of the new Social Housing Net Zero Standard before implementing further energy efficiency and decarbonisation measures.

RSLs are primarily focused on alleviating fuel poverty before decarbonisation and are delaying installation of electrified forms of heat to avoid exacerbating fuel poverty. They wish to adopt a fabric first approach to facilitate fuel poverty reduction and but are unable to afford the often-substantial costs based on their current rental income and borrowing limitations. Additional grant funding is required to support fabric first programmes for low-income households in the social rented sector, and a new grant funding regime to support energy efficiency measures for multi-owned buildings with low-income households.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

Yes.

• Improving the energy efficiency of housing through the ABS, RSL investment programmes and the city’s Affordable Housing Supply Programme will reduce the amount of energy used by households and fuel poverty.
• Working with partners such as Home Energy Scotland and the Wise Group to raise awareness of initiatives and advice to residents. A One Stop Shop network is an aspiration to encourage and support households of all tenures to carry out energy efficiency and clean heat measures.

b) High fuel prices?

The Council has no control over the levels of inflation that have resulted in high fuel prices nor the pricing of energy. During this period, support and advice has been provided by a range of Council Services including Financial Inclusion and Glasgow Helps and as outlined previously partners.

The Council will continue to tackle the challenge of high fuel prices through the development of heat networks, the development of community generated energy, providing advice to residents and housing providers on making best use of tariffs to optimise running costs and where solar PV, battery and thermal storage can reduce fuel costs.

c) Low Income?

During this period, support and advice has been provided by a range of Council Services including Financial Inclusion and Glasgow Helps to help low-income households maximise income through work and benefits. As outlined previously, the role of Glasgow’s PRS Housing and Welfare Hub is key in supporting families living in the city’s private rented sector who receive low incomes through housing advice, assessment of income and expenditure, welfare rights and addressing issues relating to property conditions.

Glasgow City Council also offers Welfare Rights and Money Advice support to low-income households. This will maximise household income through unpaid benefits, access grant support and support low-income households into work.

d) Inefficient use of heat in the home (household behaviour)

Yes.

Via advice services delivered by Home Energy Scotland and the Wise Group, linked via GCC webpages, advice directly provided by the Affordable Warmth Team and by advice given from the PRS Housing and Welfare Hub and Glasgow Helps to sign post enquiries to the relevant organisations.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

GCC, similarly to some other local authorities, has, and continues to experience, a range of challenges associated with maximising the draw down of available ABS grant funding from the Scottish Government. The delivery challenges that relate to Glasgow include:

• The single year allocation of grant funding and expected delivery timescales – Delivering the ABS programme over a 12-15 month period is challenging. This is due the time required to develop programmes, prepare and assess tender documentation, with support from the Council’s Corporate Procurement and Legal Services, appoint contractors and gain statutory consents before starting work on site. NRS Housing also has to establish interest from owners and landlords in areas and assess project viability. The Scottish Government has indicated that the allocation of single year funding will continue at present.
• Grant eligibility for private landlords – Private landlords may be eligible for fabric measures through the ABS programme if the landlord has three or less properties in their ownership. In this instance, they are eligible for a full ABS grant for one property in Scotland. Local authorities are required to seek a contribution from landlords for a second or third private rented property.

Landlords who have four or more properties are not eligible for ABS grant funding, which has implications for delivering measures in mixed tenure blocks of flats. There are currently 39,916 private landlords registered in Glasgow.

• Financial contributions from owner occupiers/private landlords – Owner occupiers/landlords are required to contribute financially towards the delivery of works. The ability or willingness from owner occupiers/landlords to pay the required financial contribution can be a barrier to progressing delivery. This has a disproportionate impact in mixed tenure blocks.
• Changes to funding rules – Department for Energy Security & Net Zero (DESNZ) (previously BEIS), which is the UK Government Department responsible for ECO funding, issued guidance preventing blended funding between ECO4 and any other public funding such as ABS.
• Cost of delivery – The previous tendering exercise highlighted an increase in the cost of project delivery for ABS projects in Glasgow. Costs are linked to high inflation experienced in the construction sector. Delivery risk and project viability issues were discussed with the Scottish Government to ensure projects were supported and could progress.
• Progressing works in blocks of flats (such as 4 in a block and tenemental properties) – Title Deeds require all owners to participate. Given the scheme is not mandatory, there is a lack of willingness from some owners and private landlords to participate, which impacts on delivery. When residents seek legal advice this increases delivery timescales.
• Specification of works required – The specification of works to improve the energy efficiency of some archetypes in Glasgow through the ABS programme can be complex. Investigating and agreeing measures requires additional time and increases costs.
• Essential Repairs – There is an increasing need to consider necessary repairs before undertaking the installation of EWI to protect the integrity of the investment works. Areas of concern include, but are not limited to, roofs, soffits, facias and balconies. Owners may decline to participate due to affordability.
• PAS 2035 Standard – PAS 2035 offers a framework for identifying and installing retrofit measures to existing buildings in the UK. The Scottish Government has set out in ABS guidance their expectation that local authorities broadly comply with PAS 2035. The new specification requires local authorities to agree their approach, work with design teams, contractors and owner occupiers/landlords to consider measures that meet the specification in relation to the property. This requires additional engagement and consideration, particularly between local authorities and contractors and owners/landlords.

The Council would be willing to discuss these challenges with the Scottish Government in further detail.

The cost of energy at present and the proportion of households with low incomes is a strategic challenge that will require a long-term approach to resolve.

What further action do you feel is required from the Scottish Government for the purposes of reducing/mitigating fuel poverty for vulnerable households in Scotland?

Suggested further actions include:

• Initiatives that would enable a reduction in energy usage and costs.
• Increasing the ABS programme and amend the ABS programme guidance to enable more private landlords to participate in projects and subsequently allow measures to be installed in more blocks of flats.
• Liaise with UK Government and Ofgem to reconfigure and align the grant eligibility criteria of ECO4 to provide the flexibility and ease required to deliver local authority determined retrofit programmes targeting affordable warmth and decarbonisation goals.
• Establish a Retrofit Grant Fund for all housing tenures. This is needed to deliver the measures that would enable climate change targets to be achieved, improve housing stock and energy efficiency and reduce fuel poverty for vulnerable households. This fund would enable the repair and retrofit of existing housing across all property types and tenures and be managed by the local authority, (potentially adopting an approach similar to the delivery of the Affordable Housing Supply Programme).
• Engagement with Ofgem to encourage energy utility companies to provide “social” or low-cost tariffs for low-income households and households on pre-payment meters. Households who most need low-cost and agile tariffs are least able to access them.
• Explore and consider removing the standing charge from pre-payment meter households or introduce progressive taxation policies that tax higher energy use but limit tax on low use.
• Increase financial grant support for solar PV and battery storage.
• Grant fund the roll out of smart technology to enable curtailed energy to be provided free of charge to low-income / fuel poor households using inefficient direct electric heating.
• Consider some form of carbon tax or energy company windfall profit tax to support delivery of a national retrofit programme and one stop shop network, similar to the SEAI model in Ireland.
• Liaise with UK Government to reduce the cost of electricity through levy reduction and reform of the electricity market.

Respondent: The Highland Council

A report under subsection (1) must also set out, with respect to meeting the 2040 target in relation to each local authority area in Scotland—

a) the steps that have been taken during the reporting period for the purpose of meeting that target,

Highland Council has published a number of strategies and policies including;

• Net Zero strategy which provides a framework for reducing carbon emissions across the Council estate and helps to prepare for the unavoidable impacts of climate change.
• Local Heat and Energy Efficiency Strategy (LHEES) and Delivery Plan which underpin an area-based approach to heat and energy efficiency planning and delivery.

The Highland Local Housing Strategy 2023-2026 which aims to expand availability of good quality affordable housing to enable people to live, work and study more comfortably across the Highlands and support the local economy, connect communities, and re-populate rural areas.

• Our Future Highland 2022-2027 which sets out the programme of Highland Council for the five-year period up to 2027. It makes commitments to secure social and economic transformation on behalf of Highland communities.

The Council has published a Statement of Intent (SoI) for Energy Company Obligation Flexible Eligibility (ECO4 Flex) and the Great British Insulation Scheme flexible Eligibility (GBIS Flex) which supports Highland households to access funded energy efficiency works (subject to eligibility).

Leveraging UK Government, Scottish Government and private sector investment to deliver energy efficiency projects targeting low income, vulnerable households classed as extreme fuel poor (i.e. EES:ABS & ECO)

b) the progress made in that period towards meeting that target, and

Alignment of strategies and delivery plans with Council policies and externally funded projects.

Poor energy efficiency has been identified as a driver of fuel poverty, LHEES analysis has identified areas for prioritisation for projects which can support households in fuel poverty.

c) the steps that the Scottish Ministers propose to take or consider should be taken in the next reporting period in order to meet that target.

Unable to comment at this time.

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs.

Highland residents face significant challenges heating their homes, including lack of fuel choice (66% of highland domestic properties are off gas), higher energy prices and harsher weather conditions.

The below graph shows a significant number of Highland households have oil and electric primary heating, with a number of households with secondary heating which is often solid fuel. Additionally, 78% of properties have an EPC rating D-G and therefore likely to have a higher energy consumption/ cost more to heat and in need of energy efficiency improvements.

[Graphs provided showing EPC Band and Primary Fuel Type were removed as they did not meet the accessibility requirements].

Scottish Government statistics estimates 33% of Highland Council households are in fuel poverty, compared to the Scottish average which is 24%, however based on information available this.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

Highland Council has published several strategies and policies including; Net Zero Strategy and its Local Heat and Energy Efficiency Strategy (LHEES), The Highland Local Housing Strategy 2023-2026 and Our Future Highland 2022-2027, which all outline fuel poverty and actions required to tackle fuel poverty and provide warm, affordable and energy-efficient homes to our community.

Highland Council has leveraged external funding including Energy Efficient Scotland: Area Based Scheme (EES:ABS), Energy Company Obligation (ECO) and SSE Renewable grant funding to fund energy efficiency improvements to Highland homes, funding is focused on low income, vulnerable and fuel poor households.

For the period December 2021 to June 2024 Highland Council has leveraged circa £14m of external funding to deliver energy efficiency measures to Highland privately owned and rented properties. Over the last 2 years 85% of households have been classed as extreme fuel poor.

b) Increase local incomes in your area

Energy efficient projects will have a positive impact on the local economy, utilising local merchants and contribution to the hospitality sector. Some jobs will be created in the region and some works sub-contracted to local contractors.

c) Reduce energy costs in your area

Externally funded projects improve the energy efficiency of properties and the potential to reduce energy costs prior to energy price rises.

To have a positive impact tackling and reducing fuel poverty, projects must adopt the whole house retrofit approach (insulating, upgrading heating and installing solar PVs), the challenge with this approach is the lack of available funding.

d) Support people to heat their homes efficiently in your area (behaviour)

EES:ABS and ECO funded projects provide households with more efficient heating systems, mainly an air source heat pump.

Highland Council has several teams, including Climate Change & Energy Team and the Welfare Support Team who provide advice and support to Highland residents and manage energy efficiency projects. Additionally working with partner organisations including Home Energy Scotland, ALIenergy and Citizens Advice Bureau.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

EES:ABS projects and ECO funded works have had a positive impact for Highland residents and have the potential to reduce fuel poverty. However, the cost of living crisis and energy price rises has offset the impacts of energy efficiency works and avoided households going further into fuel poverty.

Due to limited external funding available impacts have been at a very small scale, projects moving forward need to be WHR to have a significant impact, interventions required to address higher energy costs faced by Highland residents is required to take people out of fuel poverty.

Additional Scottish Government funding would be beneficial and is required to tackle fuel poverty.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Yes, 1,337 owner occupier and privately rented properties have received energy efficiency measure for the period December 2021 to June 2024.

The scale of works undertaken has been limited due to the funding available.

b) High fuel prices?

No – more UK and Scottish Government action is required to address the issues within the energy sector, including future protection against utility bill rises.

There is currently discussions at both UK Government, in relation to ‘Energy Rebates: Highlands and Islands’, and Scottish Government seeking a review and of higher energy costs faced by Highland residents.

c) Low income?

Child poverty plan and maintaining low council rents.

d) Inefficient use of heat in the home (household behaviour)?

Somewhat – more funding is required to help local authorities and local agencies deliver energy advice and support.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

• Challenging geography and the diverse nature of the region – Highland is a diverse region with scattered settlements and very remote and rural areas which brings several challenges. The Highland Council covers 33% of Scotland’s landmass and is 11.4% of the UK landmass, making it larger than Wales and almost the size of Belgium. There is 238,060 people living in the Highland.
• Lack of fuel choice – 61% of Highland households are off gas, with a significant number of households still reliant on solid fuels for heating their home.
• Grid capacity and infrastructure – Highland also faces significant constraints in transmission and distribution networks. Existing infrastructure struggles to accommodate the increasing demand for energy, especially from renewable sources.

There have been a number of instances where work has been delayed to Highland residents in fuel poverty as there was insufficient capacity to install an ASHP and/ or solar PV.

• Higher energy costs – Highland residents pay the highest energy costs per unit in the UK, on average 4p per unit more, despite a wealth of renewable energy produced in the region.
• Insufficient funding – Highland Council actively seeks and leverages externally funding to improve energy efficiency of domestic properties across the region however availability and lack of certainty in relation to funding has limited the scale and scope of works. It also makes it difficult to plan and execute the delivery of works as outlined in the Council’s LHEES. Additionally delays awarding government funding has had significant impact on Highland residents and put jobs at risk for staff supporting those in fuel poverty.

Improve national funding to support energy efficiency and heat decarbonisation projects, and supporting activities (fuel poverty, data collection, modelling, and analysis; funding for community organisations).

• Cost of living crisis - People across Highland are being affected by the most severe economic crisis in a generation. The effects of this are being seen as households are having to make difficult choices, there is increasing reports of Highland residents having to choose between purchasing food or adequately heating their homes.
• Energy cost rises – In October the energy price cap increased by 10%, this is expected to have a significant impact on fuel poverty rates and expected to draw householders deeper into fuel poverty.
• Lack of supply chain - Increase the number of green skilled jobs (and supporting roles), to help close the skills gap.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

• Additional funding and enhanced rates to support those in fuel and extreme fuel poverty.
• UK Government & Ofgem to provide lower energy rises.
• Support the role out of training in Scotland – support training on national levels and introduce Scottish training grants. Training grants for green skills are currently available in England for English registered companies.
• Increase the number of green skilled jobs to – support and incorporate training, upskilling and support mechanisms are available to develop supply chains. This will support with a pipeline of projects within given timescales.

Respondent: Moray Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs.

At a macro-economic level, significant increases to the cost of fuel since the 2019 Act and within the term of the three year period from 23 December 2021 stands out as the most considerable single factor affecting households. In particular the cost of electricity remains at an elevated level and have a disproportionate impact on households who don’t have gas heating.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

Targeted improvement of properties continues to take place under area based schemes, which have been a successful approach to improving energy efficiency and reducing bills by the range of interventions adopted. Similarly, within the social sector there has been considerable work to bring properties up the Energy Efficiency Standard for Social Housing (EESSH) and ensuring the specification of new-builds meets the equivalent of EPC or better. Actions arising from the LHEES (2023-2028) are at the earlier stage of rollout, with a detailed delivery plan which sets out seven priorities for Moray:

• Building sustainable and climate resilient communities;
• Maximising knowledge and awareness and ensuring certainty of success;
• A just transition for the energy system;
• Supporting a wellbeing economy, jobs and skills;
• Tackling fuel poverty and improving health;
• Improving the energy efficiency of buildings; and
• Decarbonising building heat sources.

b) Increase local incomes in your area

Within the fourth priority (supporting a wellbeing economy, jobs and skills), LHEES actions include a short-term action to provide business support to new start-ups and existing businesses in Moray, as well as long-term actions to provide a programme of support to green start-ups and work with employers and industry associations to connect individuals with green jobs and learning opportunities. These in addition to the range of employability and income maximisation assistance provided by the Council and partners.

c) Reduce energy costs in your area

A fabric first approach to property improvement is the principal means by which energy costs are being reduced at present, with insulation, heating system replacements and LED lighting/solar PV being provided under both area based schemes and social housing upgrades. Work is also progressing on the feasibility of a heat network in Elgin.

d) Support people to heat their homes efficiently in your area (behaviour)

Other initiatives include provision of education and resources to empower people to use energy more efficiently and make informed choices about energy consumption.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

The actions undertaken by Moray Council since 2021 have certainly improved the situation for individual households, however when considering the aforementioned significant increase in utility costs and particularly electricity, there has clearly been a nationwide increase in the proportion of household income now required to meet a minimum standard of living.

Whilst we continue to adopt a strategic approach to improving this, many of the policy drivers behind the unit cost of utilities is beyond the control of local authorities, and indeed the devolved settlement.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Yes

b) High fuel prices?

Yes, but within the limits of what is feasible at the local level.

c) Low income?

Yes, but as above the overall impact has been negative.

d) Inefficient use of heat in the home (household behaviour)?

Yes, but there remains work to do.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

Per the above, the biggest single factor is the prevailing unit cost of energy.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

A continuation of funding streams and consideration of expansion of these to accelerate the fabric first approach across tenures would be of benefit and constructive engagement with the UK government regarding the cost of national infrastructure improvements, fiscal framework for the funding of renewable generation and ultimately the unit cost to the consumer, would be beneficial.

Respondent: North Ayrshire Council

A report under subsection (1) must also set out, with respect to meeting the 2040 target in relation to each local authority area in Scotland—

a) the steps that have been taken during the reporting period for the purpose of meeting that target

The North Ayrshire Council Plan (2023-28) explains how the Council will meet our communities needs and expectations over the next 5-years, building on work previously undertaken to create the Council vision “A North Ayrshire that is Fair for all”. Commitment is highlighted through the climate change strategic priority action: “Reducing the carbon footprint of our estate through rationalisation utilising a locality-based approach and taking a fabric first and low carbon energy generation approach to homes and buildings. To monitor and track our progress with this action when our homes and buildings are well insulated and energy efficient, making them cheaper to heat and reducing their emissions.” This action is reported on a six monthly basis.

The Council’s Sustainable North Ayrshire Strategy 2024-27 contains actions to work towards reducing fuel poverty and supporting a just transition, in a way that is fair and inclusive, therefore contributing to our socio-economic duty. The cost-of-living crisis has exacerbated the major challenges of fuel poverty and access to affordable warmth across North Ayrshire. It is essential we continue to access all funding streams such are Area Based Schemes, ECO4 Flex and GBIS, Island programmes, Carbon Neutral Islands etc. supporting residents to increase the energy efficiency in their homes, and to make heating more affordable. Such action links to directly to promoting wellbeing, a key priority within the Council Plan.

The Council published its Local Heat and Energy Efficiency Strategy (LHEES) and Delivery Plan in January 2024. Our LHEES helps us understand where efforts to reduce emissions and reducing fuel poverty are best focussed. Our LHEES Strategy sets out the changes and costs required in our buildings to decarbonise heat and improve their energy efficiency by installing a range of interventions.

The interventions would ensure that there is a reduction in energy use and cost to reduce the impact on homes that are at risk of fuel poverty. The Delivery Plan sets out our pathway to decarbonise heat and energy efficiency improvements for the next five years.

The Council is also developing a pan Ayrshire Energy Masterplan which will help the three Ayrshire local authorities to deliver on net zero aspirations, which will support LHEES delivery. Providing the opportunity to plan for robust low carbon energy infrastructure that will support Ayrshire's clean growth aspirations by helping to transform energy systems towards net zero. The three Councils are working to develop an investment strategy and policies to help the private and public sector meet energy and carbon reduction targets. The masterplan will be used to inform future decision making relating to; energy use and working towards a just transition to net zero.

The Local Housing Strategy (2023-28) aims to eradicate fuel poverty and support the Council’s aim to achieve net-zero carbon status by 2030 by building energy efficient council houses.

The Council’s Strategic Housing Improvement Plan (2024-29) sets out the priorities for affordable housing investment in North Ayrshire. This includes the building of 123 new energy efficient homes at Flatt Road, Largs which formally opened in in 2022 following a £20m Council and £7m Scottish Government investment. The new homes include Biomass district heating, heat interface units, smart dual zone temperature controls, solar PV, water saving taps and toilets, low energy LED lighting and mechanical ventilation. Annual operating costs for the district heating scheme from the Council’s Housing Revenue Account (based at 2021/22 figures) was £36,825. The council’s £194.5 million housebuilding programme, which is supported by funding from the Scottish Government, is making a significant difference across North Ayrshire, and providing a catalyst for the regeneration of towns and communities. Around 885 new build homes have already been delivered, with plans for a further 730 homes. An example is Afton Court, Stevenston opened in 2024, from investment of £1.34m from North Ayrshire Council and £0.66m from the Scottish Government for the construction of six amenity bungalows.

The bungalows have enhanced building insultation, air source heat pumps and solar voltaic panels. We are monitoring the energy use of 2 new homes within Afton Court to establish what the positive impacts/differences of the renewable appliances are.

North Ayrshire Council’s percentage of Council houses that are complaint with the Energy Efficient Standard for Social Housing (EESSH) in 2021/22 was 97.70%, 2022/23 was 98.10% and in 2023/24 was 97.90%. Scottish Housing net Zero Standard in Social Housing will replace EESSH2 and will align with the reform of Energy Performance Certificates. Installation of External Wall Insulation (EWI) on to 77 Council houses in 2022/23 cost North Ayrshire Council £1,460,943. Solar Photovoltaic panels were installed on 366 Council houses for the same year costing the authority £1,603,657 from Capital budgets.

b) the progress made in that period towards meeting that target,

The Council’s Strategic Housing Improvement Plan (2024-29) sets out the priorities for affordable housing investment in North Ayrshire. Around 885 new build homes have already been delivered, with plans for a further 730 homes.

The Council has created two unique 'Sustainable Demonstrator Homes' at the Dickson Drive development which showcase the latest design and technology. These homes also set a benchmark for building sustainable properties at a local and national level, meeting the highest sustainability ratings

North Ayrshire Council’s percentage of Council houses that are complaint with the Energy Efficient Standard for Social Housing (EESSH) in 2021/22 was 97.70%, 2022/23 was 98.10% and in 2023/24 was 97.90%. In 2022/23 wall insulation was installed for 77 houses and PV for 366 houses.

Energy Smart (emergency response) £2.176m package to support households with the cost of living crisis was launched in August 2022. The scheme aims to support North Ayrshire residents by reducing fuel poverty and increasing affordable warmth whilst reducing carbon emissions. The programme has three elements:

• Partnership with Energy Agency to signpost households to free and impartial advice through the Home Energy Scotland helpline
• Creation of a £0.45m fund to offer one-off emergency payments towards energy bills for low-income families
• Creation of a £1.7m fund to carry out home improvements to improve energy efficiency and reduce energy bills

Area Based Scheme (ABS) (Private Homes) Scottish Government Grant: from 2021 to 2024 over £2 million (this programme was impacted by covid) in funding has been brought to North Ayrshire through ABS. With External wall insulation and solar PV making a great difference to families in or at risk of fuel poverty. Further funding of £1,794,576 has been allocated for 2024/25 to instal energy efficiency and decarbonisation projects for Privately-owned homes in North Ayrshire. Over the last 13 years the Council has delivered energy efficient measures to almost 3000 homes facing fuel poverty or hard to heat properties through ABS.

ECO4 and GBIS Flex

North Ayrshire Council publish its first Statement of Intent (SoI) for ECO4 Flex in May 2023. This allowed the council to work in partnership with local installers to support low income and vulnerable households to insulate and decarbonise their homes. In January 2024 the Council published its current SoI to include the UK Governments Great British Insulation Scheme (GBIS) the eligibility scope for energy efficiency funding.

To date for both schemes:

• 28 properties have had works completed
• 122 measures installed (inc. IWI,CWI, loft ins, roof ins, Solar PV, programmers, TRV’s , boiler upgrades and 1^st time central heating.
• £771,951 in funding to North Ayrshire
• 198.53 tones of carbon savings, and
• £81,234 of annual bill savings

Carbon Neutral Islands (CNI) Cumbrae

The CNI project provides an opportunity to demonstrate the low carbon energy potential of islands as hubs of innovation in relation to renewable energy and climate change resilience. This will also positively impact on island economies, facilities and general wellbeing by allowing for reinvestment in the communities. Funding applications are ongoing, our current funding bid focused on installing solar PV to both private dwellings and community buildings, to reduce carbon emissions and increasing household resilience.

North Ayrshire Council Local Heat and Energy Efficiency Strategy (LHEES) and Delivery Plan helps us understand where efforts to reduce emissions and reducing fuel poverty are best focussed. Our LHEES Strategy sets out the changes and costs required in our buildings to decarbonise heat and improve their energy efficiency by installing a range of interventions. The interventions would ensure that there is a reduction in energy use and cost to reduce the impact on homes that are at risk of fuel poverty. The Delivery Plan sets out our pathway to decarbonise heat and energy efficiency improvements for the next five years.

The Council’s Sustainable North Ayrshire Strategy 2024-27 contains actions to work towards reducing fuel poverty and supporting a just transition, in a way that is fair and inclusive, therefore contributing to our socio-economic duty. Our progress is measured and reported internally on a quarterly basis.

North Ayrshire Council Plan (2023-28) has a climate change strategic priority. Within the priority there is an action: Reducing the carbon footprint of our estate through rationalisation utilising a locality-based approach and taking a fabric first and low carbon energy generation approach to homes and buildings. This action is reported on a six-monthly basis.

c) the steps that the Scottish Ministers propose to take or consider should be taken in the next reporting period in order to meet that target.

N/A

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

Cost of living crisis. Increased energy costs. Hard to treat properties. Off gas properties (rural and island communities), installer transportation and worker accommodation costs for island communities, Council budgets.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

See Annex A, Part 2, responses to questions a & b for Area Based Schemes, Strategic Housing Improvement Plan, Housing Strategy, EESSH, ECO4 Flex, Energy Smart and LHEES.

b) Increase local incomes in your area

Area Based Scheme grants, ECO4 Flex and Energy Smart (Council funded) programmes to support energy efficiency measures and one-off emergency payments.

c) Reduce energy costs in your area

We do not have influence over energy costs in our area but provide support to our residents via Energy Smart one-off emergency fund payments and advice to reduce energy bills.

d) Support people to heat their homes efficiently in your area (behaviour)

North Ayrshire Council offer: Area Based Scheme, ECO4 and Great British Insulation Scheme(GBIS), Council house fabric and heating improvements (EESSH).

Energy Smart partnership with the Energy Agency to signpost households to free and impartial advice through the Home Energy Scotland helpline, Council one-off emergency payments towards energy bills for low-income families and funding for home improvements to improve energy efficiency and reduce energy bills.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Yes

The Council’s Strategic Housing Improvement Plan (2024-29) sets out the priorities for affordable housing investment with around 885 new build homes have already been delivered. The Local Housing Strategy (2023-28) aims to eradicate fuel poverty and support the Council’s aim to achieve net-zero carbon status by 2030 by building energy efficient council houses.

North Ayrshire Council’s percentage of Council houses that are complaint with the Energy Efficient Standard for Social Housing (EESSH) for 2023/24 was 97.90%. In 2022/23 the Council installed External Wall Insulation (EWI) costing £1,460,943 and £1,602,657 on Photovoltaic Panels on Council houses cost the Council £1,603,657 from Capital budgets. This was for wall insulation for 77 houses and PV for 366 houses.

Area Based Scheme (ABS) (Private Homes) Scottish Government Grant: from 2021 to 2024 over £2 million (this programme was impacted by covid) in funding has been brought to North Ayrshire through ABS. With External wall insulation and solar PV making a great difference to families in or at risk of fuel poverty. Further funding of £1,794,576 has been allocated for 2024/25 to instal energy efficiency and decarbonisation projects for Privately-owned homes in North Ayrshire. Over the last 13 years the Council has delivered energy efficient measures to almost 3000 homes facing fuel poverty or hard to heat properties through ABS.

North Ayrshire Council published their Local Heat and Energy Efficiency Strategy (LHEES) and Delivery Plan in January 2024. Our LHEES helps us understand where efforts to reduce emissions and reducing fuel poverty are best focussed.

The Council’s Sustainable North Ayrshire Strategy 2024-27 contains actions to work towards reducing fuel poverty and supporting a just transition, in a way that is fair and inclusive, therefore contributing to our socio-economic duty.

North Ayrshire Council Plan (2023-28) has a climate change strategic priority. Within the priority there is an action: Reducing the carbon footprint of our estate through rationalisation utilising a locality-based approach and taking a fabric first and low carbon energy generation approach to homes and buildings. To monitor and track our progress with this action when our homes and buildings are well insulated and energy efficient, making them cheaper to heat and reducing their emissions. This action is reported on a six-monthly basis.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Yes. Please see response to Q3

b) High fuel prices?

Yes. Please see response to Q3

c) Low income?

Yes. Please see response to Q3

d) Inefficient use of heat in the home (household behaviour)?

Yes. Please see response to Q3

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

Availability of funding.

Finding those who most require help, household circumstances (elderly, infirm) and the lack of want to change.

Individuals and larger programmes of work have difficulty in contracting installers to implement fabric energy efficiency measures and renewable heating on our islands; with cost impacts felt with increased costs for transport and workers accommodation (if available at all).

Tenure mix can cause difficulties for engagement, and work programmes/funding.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

Increased funding support.

Support for agencies that support household with debit, income maximisation and dealing with energy suppliers.

We utilise Scottish condition surveys for local authority level fuel poverty statistics, due to covid and changes to data collection these are not available for reporting use.

Respondent: North Lanarkshire Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

The challenges faced by households in North Lanarkshire in being able to heat their homes primarily relate to affordability, in that energy prices albeit reduced in recent years still remain high. This coupled with the ongoing cost of living issues and financial hardship makes fuel bills unaffordable for many households. Over the last year North Lanarkshire Council has seen a 41% increase in referrals to the council’s Tackling Poverty Team, indicative of the financial hardship endured by many households. Many of these households are in both fuel and food poverty.

When incomes are stretched it also makes it difficult for households to invest in energy efficiency measures which is a key driver of fuel poverty. Although some financial products exist for homeowners and private landlords for energy efficiency measures, there is not enough help available, combined with a reluctance or financial inability to uptake and a general lack of awareness of such measures/support.

There are particular groups more at risk. Private rented sector tenants have limited influence to improve the energy efficiency of their homes and often face higher fuel bills as a result of this. Owners in mixed tenure blocks of flats also face difficulties in progressing some common works which improve the energy efficiency of their home, for example external wall insultation, due to issues with participation of other owners in common works. There are other groups also at more risk, including ethnic minority households, disabled people, households using prepayment meters, single parent households as well as households on low incomes which includes households with children (1 in 4 children are currently living in poverty in North Lanarkshire).

Properties in the social sector are better performing than those in the private sector, with many low regret measures already progressed across council stock, such as internal wall insulation and double glazing providing energy efficient homes and lower fuel bills for households. This means that other remaining energy efficiency measures are often more expensive and sometimes challenging to install.

There are also challenges with some harder to treat properties, many of which are in the private sector in which energy efficiency measures are cost prohibitive and/or not technically feasible.

Some households face challenges in relation to energy debt. The cost of living crisis and increasing energy costs has led to an increase in the number of households in arrears on energy bills. This debt can result in households being on expensive tariffs or prepayment meters. Many households on prepayment meters cannot heat their homes effectively as they are in energy debt and the debt repayment is taken as a percentage of the amount they top up their meter. Sometimes a fixed amount is applied or sometimes it’s a combination of both percentage and fixed weekly amount and its not always clear from looking at the meter what the position is, with some households paying off two lots of debt repayment resulting in only a small amount of their top up money crediting their meter which is ineffective in heating their home.

Wider poverty issues such as poor resilience against unexpected shocks/changes in circumstances (reduction in income or unexpected expenditure), low awareness of support available are also challenges. Although the council and wider partners have implemented a range of supports and interventions to assist households to tackle fuel and wider poverty issues.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

• Developed and implemented the Local Heat and Energy Efficiency Strategy and Delivery Plan.
• Commissioned two research studies on net zero to help scope out our journey towards compliance with climate change targets for council housing stock which focusses on energy efficiency measures and projects costs and scope of works.
• The findings of the research studies resulted in the installing external wall insulation on our properties and the creation of a standalone PV programme as part of our Housing Capital Programme.
• Since 2021/22, £2.1M of EES:ABS funding has been invested to improve energy efficiency across mixed tenure blocks. Investment is primarily used for external wall insulation, increased ventilation, installation of Solar PV panels (£2.9 million allocated for 2024/25)
• Delivered a net zero homes pilot - testing renewable technologies and increased enhanced energy efficiency measures. These homes are being evaluated to understand the impact of zero emission heating systems on energy use.
• Over £65.8m has been invested in energy efficiency measures in council homes from 2021/22, with £38m proposed to spend in 2024/25.
• Implemented a social landlord forum on asset management with other social landlords in North Lanarkshire to share good practice and explore opportunities to improve energy efficiency and house condition.
• Established and facilitate a private landlord forum in which condition/energy efficiency is a focus.
• Provide support and advice to private landlords and homeowners through a dedicated private sector housing team.

a) Increase local incomes in your area

• Increased the number of employers in North Lanarkshire with real living wage accreditation.
• Increased tackling poverty interventions within community benefits.
• Supported families who are in at risk of poverty to support/access into work.
• Improved transport and access to services across the whole of North Lanarkshire.
• Identified pathways within labour market growth sectors or areas of high replacement demand which provide progression routes out of low pay in North Lanarkshire.
• Assisted people further from the labour market into employment (particular key client groups, including children leaving care, people with additional support needs, people with disabilities).
• Delivered the Prospects Programme (helping unemployed people further from the labour market into work).
• Established a first point of contact team for advice and information services.
• Targeted approach: families and children who received a social work service to ensure income was maximised; worked with the Macmillan Cancer Advice Service to maximise income of cancer patients and their carers; kinship carers.
• Established food poverty referral gateway to mitigate the need for foodbank use.
• Established health hub information and advice surgeries.
• Maximised income through benefit uptake.
• Implemented a Universal Credit Assistance Fund.
• Implemented a Universal Credit drop in.

b) Reduce energy costs in your area

• Procured and established an Energy Advice Service, delivered by the Wise Group which helps people with fuel debt, advice on practical quick wins to cut energy use and also find the cheapest energy tariffs (as well as signposting to wider supports).
• Continued to implement a ‘fabric first’ approach by installing energy efficiency measures across council and registered social landlord homes.
• Established a fuel poverty group bringing together partners to collectively identify and implement measures to help tackle fuel poverty through reducing energy costs and improving access to advice and support.
• Delivered training in partnership with Home Energy Scotland to increase knowledge amongst council housing staff to assist tenants and residents with fuel debt and high energy costs.
• Continued to update the council’s webpage on fuel poverty, providing clear information for tenants and residents on support and help available.
• Developed a suite of new practical leaflets/materials for tenants on how to use their specific different heating systems effectively.
• Utilised the council’s communication platforms to promote ways in which households could access advice and support to reduce energy costs, with additional activity aligned to key themes e.g. Challenge Poverty Week.

c) Support people to heat their homes efficiently in your area (behaviour)

• As outlined above worked with Home Energy Scotland to deliver training to frontline housing staff to increase knowledge of staff to provide advice to tenants on effective energy use in the home.
• As part of the tenancy sign up processes, advice is given to tenants on how use their heating system effectively and as part of ongoing housing management, advice and support is provided.
• Support provided via locality housing support teams and commissioned services with budgeting and tenancy sustainment also covers advice and support on practical independent living skills which includes advice on effective heating use, general energy saving tips.
• Developed and published material on the council website.
• Delivered tenant and resident participation activities.
• We continue to work in partnership with Home Energy Scotland and make referrals for advice through the online portal.
• Refer for home energy checks.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

The Local Heat and Energy Efficiency Strategy (LHEES) has only recently been published and is in the early stages of implementation. The impact of the actions set out in this strategy have yet to be realised fully, but are planned to significantly improve fuel poverty, given that this is one of the key priorities set out in the LHEES. The Energy Efficiency Area Based Schemes have had a positive but somewhat limited impact given the issues associated with the participation of owners. Owners are often reluctant to participate in common energy efficiency works due to their financial circumstances. Ex-right to buy owners often have lower income and equity which makes it difficult to participate in some works, despite an appetite to do so.

Actions set out in the Local Housing Strategy and the Housing Asset Management Plan have been effective. Many of these actions have focused specifically on improving the energy efficiency of council homes, wherein significant investment in energy efficiency programmes has been made over the course of the current strategy resulting in improved energy efficiency of council homes. Several actions are also set out to improve energy efficiency in the private sector through working with private landlords to improve compliance and increase awareness of support and help available to improve energy efficiency and support tenants facing financial hardship. The Local Housing Strategy has a specific key action to help households out of fuel poverty which includes improving energy efficiency and fuel poverty advice. To help achieve this, an energy advice service was procured to assist households experiencing or at risk of fuel poverty.

This alongside targeted financial support, such as fuel vouchers/assistance has been particularly successful in alleviating the impacts of fuel poverty in North Lanarkshire.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Yes, as outlined in the response to previous questions, a ‘fabric first’ approach which addresses poor energy efficiency in homes is at the core of our local authority’s efforts to tackle fuel poverty. Investment in energy efficiency measures accounts for over 50% of the council’s housing capital investment programme and it has been effective in improving the energy performance of council homes. Partner Registered Social Landlords are aligned with the council’s approach with

considerable advances in energy efficiency made over the past decade across social sector housing stock.

b) High fuel prices?

The local authority has implemented a range of actions particularly over the past 3 years in response to the sharp increase in fuel prices, particularly those seen over the winter of 2022/23. Responses mirrored those of some other local authorities in the provision of warm spaces, increased targeted awareness campaigns of financial/income advice, provision of specific financial targeted supports such as help with food, fuel, rent assistance fund, employability support, housing advice as well as access to wider holistic supports. While these actions have undoubtedly helped reduce the impact of high fuel prices, they have not fully mitigated the impact for many households due to the impossible situations some households face when household income is insufficient for an adequate standard of living (even with benefits and income maximised). Some of the support provided was short term urgent support specifically delivered to help with the energy crisis over 2022/23 and supplemented the national support provided by the Scottish Government, but several have continued and evolved, recognising the interconnectedness between the challenges experienced by households in fuel poverty.

c) Low income?

Two of our four drivers for tackling poverty in North Lanarkshire focus on low income through maximising income via employment and through social security benefits. Driving up income from employment remains one of the mechanisms in North Lanarkshire which offers real opportunities to support unemployed and underemployed residents out of poverty. Actions have been effective.

Average earnings in North Lanarkshire are now above the Scottish and UK averages for the first time. However, this is not withstanding challenges. The number of people reported as ‘long term sick’ has increased, and while unemployment is lower than pre-pandemic levels the number of people in the workforce in North Lanarkshire has reduced. Our Tackling Poverty Strategy sets out our actions which focus on continuing to work with employers to create opportunities for our unemployed residents, with all employability programmes delivered by or on behalf of the council based on the No One Left Behind policy. Some significant achievements have been made, over the course of the last Tackling Poverty Strategy. The Tackling Poverty Team, Housing Solutions and Social Work Services generated over £99 million in additional benefit income for the residents of North Lanarkshire. This together with the £22.6 million generated via Citizens Advice Bureaux means that over £121 million has been generated by supporting people through the benefit system.

Despite the positive work on driving up incomes via employment and benefits, the core issue remains that high fuel bills coupled with continuing high food prices means that many households still struggle financially, as their income (from employment and/or benefits) can be insufficient to meet household basic needs.

d) Inefficient use of heat in the home (household behaviour)?

The council and its Registered Social Landlord partners have delivered several awareness raising campaigns to educate households on how to efficiently heat their home. This has involved social media platforms, ad hoc awareness raising campaigns as well as more formal planned activities via Challenge Poverty Week and Tenant Participation activity.

Support from partner organisations such as Home Energy Scotland for housing staff to participate in training which includes practical tips and support for housing officers to provide advice to tenants has been effective, increasing skills and knowledge amongst local housing teams, which enables a proactive response both when tenants are signing up for a new tenancy but also for any later contacts. This being said, it is difficult to ascertain with certainty the full impact this has had on household behaviour, given individual choice.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

The energy market can be complex, and households often struggle to navigate this and therefore do not always find it easy to access the support available to them from the supplier. Our experience has been that households also find the wider framework of support complex at times – it’s not always clear what support is available, who/how to contact and eligibility. This applies to both energy suppliers and also support from community and voluntary sector organisations as well as support from the government.

North Lanarkshire has particular demographics characteristics which makes it even more challenging. This includes factors such as a higher level of limiting long term illness, higher proportion of local authority stock in comparison to other areas (although council housing stock is more energy efficient, tenants are often on lower incomes than other tenures which means they are more affected by energy price increase and more vulnerable to financial pressures). These increase vulnerability to fuel poverty.

Issues in the private rented sector, quality/condition and energy efficiency standards continue to prove challenging. Mortgage rate increases and changes in taxation have been cited by private landlords as directly impacting on their ability to fund improvements in properties, such as energy efficiency measures.

The cost of living crisis, although reported to be easing, is still affecting many households, particularly as food inflation remains stubbornly high. Affordability issues/low household income remains the main challenge as households struggle to afford to adequately heat their homes.

Understanding the full extent and scale of fuel poverty is also challenging as there is limited data available, with the primary source being that provided through the Scottish House Condition Survey, supplemented by SIMD (poverty/deprivation indicators) and housing data locally. It is difficult to identify with accuracy who is fuel poor and where they live to ensure targeted interventions make best use of available resources to tackle fuel poverty.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

• Improve data collation and sharing systems to identify and target those in priority need
• Simplify/streamline supports available to make it easier for households to access the support and advice they need
• Increase the range of financial products available to support private landlords and homeowners improve the energy efficiency of their homes
• Provide greater flexibility to councils in the use of Energy Efficiency Area Based Scheme funding to enable greater participation from owners
• Improve the range of energy advice and information available
• Promote advice and support available more widely to increase awareness
• Consider the future provisions set out in the Heat in Buildings Bill and Social Housing Net Zero Standard and how this impacts on households in terms of a just transition (given electricity prices are still significantly higher than gas)
• Improve affordability of fuel bills through fairer pricing and better regulation (working with the UK Government)
• Review existing fuel poverty measures and develop more accurate measures
• Improve targeted financial support for fuel poor households, particularly during times of high energy prices
• Work with social landlords to better understand/forecast the costs associated with energy efficiency measures and impact on tenants’ rents
• Increase support for households in energy debt – implement specific measures to address the standing charge element of energy bills
• Carry out further research to better understand the extent and scale of fuel poverty with particular attention to individuals/groups who share protected characteristics i.e. ethnic minority groups, disabled people to determine any concealed inequality to be addressed

Respondent: Orkney Islands Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

With no mains gas, Orkney predominantly relies on already decarbonised electricity and heating oil as the main sources of heating for both domestic and non-domestic properties. As Orkney produces over 100% of the island’s current electricity demand from renewable sources, electric heating would appear to be the ideal solution both on environmental grounds and on practical terms, as oil heating is phased out.

However, Orkney’s household income and (older) housing stock profiles – in tandem with extreme electricity prices - contribute to some of the highest rates of fuel poverty in Scotland.

The most recently published figures for Orkney show that 30.5% of Orkney households were in fuel poverty during 2017-19, compared with a Scottish average of 24.4%. Over the same period 21.8% of Orkney households were in extreme fuel poverty, compared with a Scottish average of 11.9%.

[Scottish House Conditions Survey (SHCS), Local Authority Tables 2017-2019 provided have been removed as do not meet accessibility requirements. The data can be found within the published SHCS tables.xlsx]

Challenges

The cost of energy in this geographical area is higher than elsewhere in the country. There is no mains gas available, limiting the availability of energy options to those that are more costly to the householder or to the environment.

There is an increased number of hard to treat, rural and isolated properties.

Lack of enabling funding for homes in poor condition, to bring them to the standard where energy efficiency measures can be installed.

The geographical remoteness and location mean there is a limited availability of contractors for either installations or preparatory works.

As an island community, the challenge of this geography affects the transport availability for an aging ferry fleet, limiting access across Orkney for contractors, or employment options for islanders. Also subject to delays and cancellations due to weather and repair schedules.

Modest economies of scale, result in higher costs for materials and hardware. With limited supply chain frameworks to deliver goods & services to householders.

The withdrawal of radio teleswitching service functionality to legacy meter systems combined with the slow rollout of smart meter installations has created anxiety with customers as to what happens in 2025. The energy suppliers have yet to explain what switching options will be made available to householders with legacy dual-rate meters and what that is likely to do for the real cost of heating homes. The majority of the social housing sector is reliant on electric storage heaters. This tenure also has the highest density of fuel poverty and extreme fuel poverty as can be seen from the table above.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

Council stock

Ensuring Orkney’s housing stock is well insulated and has an efficient heating system, removes the energy efficiency of the property as the driver of fuel poverty.

Our progress with assessing and upgrading our stock is included in our Annual Return on the Charter submission to the Scottish Housing Regulator:

Council Properties	2021	2024
Total self-contained Properties	955	1003
Self-contained properties that meet EESSH1	88.12%	96.47%

For our social rented stock, we had prepared a multi-year plan to deliver the Energy Efficiency Standard for Social Housing 2 (EESSH2), with considerable challenges identified, original funding requirements, supply chain, rapid price inflation, timescales and local installer capacity.

However, we now await the publication of the new Social Housing Net Zero Standard (SHNZ) and the impact this will on our future programmes of work.

Analysis undertaken by the Council in 2022 showed that under 200 council houses met the EPC B standard. The Council has been trialling approaches to meet the higher energy efficiency standard, undertaking an individual assessment when a property becomes void and taking a Fabric First approach, coupled with fitting mechanical heat recovery ventilation systems to help maintain air quality alongside ensuring the provision of an efficient heating system.

If this approach was to be undertaken for all council stock that does not meet a standard broadly equivalent to SHNZ then the estimated cost would be a total of £25.2m, or £21,348 per unit (in addition to the normal major component replacement). The difficulty will be trying to ensure that the standard is met while maintaining an affordable rent for our tenants. The Housing Revenue Account is under considerable pressure given the competing demands for development, maintenance and repair of an aging stock and the need to meet the energy efficiency targets being developed.

[Map image provided showing Orkney Housing Stock was removed as it did not meet the accessibility requirements].

Private Sector

Engagement of a managing agent for the local Area-Based Scheme (ABS) to deliver energy efficiency improvements to domestic properties.

By having Warmworks Scotland as our managing agent who delivers not only the Area- Based Scheme, but also the Scottish Government’s national scheme – Warmer Homes Scotland - has further raised the profile of the energy efficiency support available to vulnerable households in the area.

[The table provided showing the breakdown of energy efficiency measures has been removed as does not meet accessibility requirements].

Under our current multi-year managing agent contract, we have completed four years of ABS delivery; resulting in over 500 households participating and 689 energy efficiency measures installed. This totals over £5.42M of ABS funding from the Scottish Government.

For ABS 2024/25, we have received a reduced funding allocation of £1.21M.

This is a significant reduction to our recent programmes of work (2022/23 - £1.745M; 2023/24 - £1.862M) and will result in ABS 2024/25 having a limited impact in Orkney. We have more applications beyond the funding allocation and are in discussions with Scottish Government officers re the possibility of additional grant.

An overview of the ABS delivery and associated annual reports are available from this link - https://www.warmworks.co.uk/our-work/orkney/

LHEES

Our LHEES is underway with a consultation period, prior to presentation to Councillors for approval & publication.

Draft priorities for Orkney LHEES are:

• Priority A: Making Orkney’s homes energy efficient
• Priority B: Removing energy efficiency as a driver of fuel poverty
• Priority C: Improving carbon efficiency of non-domestic Council buildings
• Priority D: Exploring heat networks for non-domestic Council buildings

b) Increase local incomes in your area

• In 2023, in response to the dramatic increase in fuel prices and the general cost of living, the Council launched a Cost of Living Grant Scheme to provide one-off grants of £200 to households on low incomes.
• The Council provides funding for Orkney CAB, who work with service users to maximise their incomes, including benefits. In 2023/24, the CAB figure for client financial gain was £1,693,127.
• The Council provided the seed feeding and actively supports Orkney Money Matters (OMM), a partnership led by Orkney CAB, THAW (Orkney’s fuel poverty charity), Voluntary Action Orkney (Orkney’s third sector interface) and Orkney’s community planning partnership. OMM has:
  • Improved the capacity of the advice sector and its ability to provide financial advice.
  • Provided cash and vouchers as a dignified alternative to in-kind support to those in fuel and food poverty.
  • Developing a ‘No Wrong Door’ referral system.
• A review of the Scottish Welfare Fund has been carried out, and the team has worked closely with local agencies supporting people in financial difficulty to improve the quality of applications received. This has dramatically increased the number of applications of the fund that are successful (up from 40% to 68%).
• The Council supports the community planning partnership, including financially. The work of this partnership has focused on addressing the cost of living crisis and the development of a plan to deliver Community Wealth Building in Orkney, all of which supports the increase of incomes that people receive. A good example is how the Islands Costs Crisis Fund, money which came via the Council, has been used to support people on a low income.

c) Reduce energy costs in your area

See other responses regarding energy efficiency schemes and support.

d) Support people to heat their homes efficiently in your area (behaviour)

The Council has committed significant funding to support the activities of THAW Orkney. Their latest annual report is also enclosed for an overview of this service provision.

In respect of Area Based Scheme delivery - our managing agent routinely encourages customers to engage with independent, impartial energy efficiency advice services and other stakeholder partners, including Home Energy Scotland and more locally, the fuel poverty charity THAW Orkney. Customers are also signposted for Citizens Advice Bureau support, to the local Care and Repair service, and to appropriate contacts within the third sector, also supporting the NHS Orkney through GP practices.

Case example:

In Feb 2024, Orkney Care and Repair received a referral from Warmworks Orkney to help a client in Orphir, with some major repairs to their home.

The client was hoping to get upgraded insulation in their house through the local HEES: ABS, but due to a damp rotten wooden floor, Warmworks were unable to carry out this upgrade.

Orkney Care and Repair supported the client by securing a small repairs grant from the Council, then securing a contractor to lay a new concrete insulated floor.

The work was completed by the end of the following month. Which meant that Warmworks were then able to follow on and complete their insulation upgrade.

This demonstrates excellent joined up working, with various partners all working together to support clients in a common end goal.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

As noted in Q2a, above, the delivery of energy efficiency measures to the private sector via the Scottish Government’s ABS funding programme has had a significant impact to participating households. With positive feedback and case studies included within the links detailed previously.

The scale of funding has strengthened local contractor capabilities, increased employment and positions the construction sector well for the expected Social Housing Net Zero Standards projects to come.

We have recently published our Local Housing Strategy 2024-2029 and are to commence with a series of Housing Market Partnership Forums to work with stakeholders and to measure & progress the stated deliverables. This Strategy is also enclosed for reference. Fuel Poverty is a key priority weaved within the strategy and we work with others, including the Cost of Living Taskforce, on delivery.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

b) High fuel prices?

c) Low income?

d) Inefficient use of heat in the home (household behaviour)?

Our actions are noted in Q2, above. With respect to 4 (b) for areas without mains gas an electricity tariff, for heating systems, more reflective of gas prices would significantly reduce the levels of fuel poverty and extreme fuel poverty.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

The idea of an integrated service covering both domestic and non-domestic buildings is noted in previous local strategies such as Orkney’s Fuel Poverty Strategy 2017-22 and Orkney Sustainable Energy Strategy 2017-2025, but the service has not materialised to date.

The four main stakeholders who currently who provide advice and support on energy efficiency are:

1. Home Energy Scotland – national advisory service

2. HEES: ABS Managing Agent – limited local advisory services

3. THAW (Tackling Household Affordable Warmth) Orkney – charitable organisation offering fuel poverty support services

4. Orkney Islands Council

However other pathways exist; from NHS Orkney, Citizens Advice Bureau, Social Care and Third Sector organisations. As well as new strategic aims documented in our Local Housing Strategy and Child Poverty Strategy.

Ideally, with proper resourcing, integration will lead to clearer identification and appropriate support to all vulnerable households impacted by fuel poverty.

Underpinning the level of fuel poverty is our location with a need for heat for a greater part of the year and the unit price and standing charge of electricity, in an area rich with renewable energy resource.

Orkney has a low population density, and buildings are generally dispersed. There are a small number of non-domestic council buildings with heat demand high enough to warrant the exploration of a heat network.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

Baseline data for fuel poverty

The Scottish House Condition Survey: Local Authority Analysis Tables are the authoritative statistics for fuel poverty and extreme fuel poverty, in Scotland.

The three-year rolling dataset is a valuable tool for national and regional strategic planning. With the publication of results based on the current fuel poverty definition. Therefore it can also be used to identify regional issues and to target, resource and support local responses.

However, the current dataset is for 2017-19 and we feel that the publication of a refreshed report is a matter of urgency.

Social Housing Net Zero Standard

All Councils and Housing Associations await the completion of the consultation phase and publication of the new Standard. Under the previous Energy Efficiency Standard for Social Housing (EESSH2), a ten year plan was being developed to meet the 2032 target. This is on hold although pilot works have been undertaken on different house types to determine effective ness of works and refine costs. Time has now been lost if the target remains as 2032. Costs have also increased, particularly materials and supplies directly impacting affordability. Once the new guidance is published planning and delivery work can recommence.

It is unknown if the Housing Revenue Account will be able to support the required improvements while keeping rents affordable.

HEES: ABS funding model

We note that the national funding pot for ABS 2024/25 was retained at £64M, as per the previous year.

However, unlike previous project years, the application for funding process did not evaluate on a ‘quality of bid’ basis and instead reverted to allocations based on COSLA methodology. With the full £64M committed to Councils on this basis.

This means that for Orkney our original bid of £2.25M was dismissed and we reverted to a project totalling £1.21M. Previous programmes of work were worth £1.862M and £1.745M (2023/24 and 2022/23, respectively).

We also note significant expenditure shortfalls in the national ABS funding pot for recent years; £18.8M in 2022/23 and -£10M in 2023/24.

We therefore want to highlight that the funding model requires revision and should account for past performance and ‘quality of bid’ processes. As it stands many Councils will return ABS funding and the opportunity for Orkney Islands Council - and others who are operational - to spend more of this committed funding and support householders will be lost.

The approach taken by Scottish Government to allocate funds has been consistent in the last five years. However, there is an option for Scottish Government to look at how funds are allocated at outset and to monitor effective delivery and maximise spend through re- allocations.

Respondent: Perth and Kinross Council

Steps taken and progress made to meet the 2040 target for Fuel Poverty since December 2021

Tackling Poverty is a corporate priority for Perth & Kinross Council (PKC), with cross service involvement, and includes actions relevant to Fuel Poverty on providing households with Energy efficiency advice and providing new Affordable homes.

The council provides year on year financial support to SCARF, who support all residents across Perth & Kinross with free energy efficiency advice and fuel debt advocacy. We aim to provide an integrated approach via an Energy Advisors network with Citizens Advice Bureau, with seamless referrals from our Welfare Rights team to ensure holistic and comprehensive support. In addition, we run social media campaigns to promote our website with resources, tips and funding available to improve home energy efficiency. We aim to develop this further and are scoping a one-stop-shop service for home energy retrofit as part of an IUK funded programme.

Supported by the Local Housing Strategy, our Affordable Homes programme includes Scottish Government Funding to provide new homes to EPC B standard. The development of a New Build Design Guide (published 2023) aims to ensure that any new build social housing has energy efficiency levels that exceed the current Building Regulations, in order to future proof new build properties.

During the reporting period approximately 672 new build homes were delivered to EPC B standard as a minimum, through the Affordable Homes Supply Programme. We have aligned decarbonisation and tackling Fuel Poverty via the Local Heat and Energy Efficiency Strategy (LHEES) 2024-2045, with an accompanying 5-year Delivery Plan (2024-2029), informed by the Local Housing Strategy (2022-27) with the vision that by 2045, our homes and buildings will be more energy efficient and with more decarbonised heat sources providing more affordable warmth and no longer contributing to climate change.

The LHEES Strategy focuses on two Strategic Priorities:

• Decarbonising heat within a transitioning energy system focusing on heat networks and heat pumps.
• Improving buildings’ energy efficiency aiming for affordable warmth and regulatory compliance.

The accompanying Delivery Plan prioritises improving buildings’ energy efficiency aiming for affordable warmth in areas where poor energy efficiency is the highest and acts as a driver of fuel poverty. This would target areas where low cost retrofit options are possible and where social housing is likely to experience a greater reduction in fuel poverty, due to low cost retrofit measures.

We support the ECO4 Flex programme and have established an approved contractor list. We continue to apply for HEEPS ABS funding from the Scottish Government to assist private homeowners to access funding for energy efficiency measures and have delivery programmes planned for HEEPS ABS in 2024/25 and the ECO4 Flex workstreams continue to be supported through the sign-off of referrals.

Understanding the condition of the housing stock and the costs to bring improve energy efficiency is key to progression. For PKC owned social rented homes, we have been building a model of archetypes with ARUP consultants, to facilitate energy efficient retrofitting of the building fabric heating solutions to reduce fuel usage. Approximately 65% of our housing stock has been modelled into archetypes upon which to plan retrofit projects to meet the required targets. We are in the late stages of working on the development of two pilot projects for other archetypes in our housing stock.

We have created an Energy team within our Housing Improvements team, to aid with the investigation of our own housing stock Energy Performance Certificate (EPC) levels and the interventions that are needed. An external contractor has now been appointed to conduct EPCs for any property that receives improvement measures and addresses where we had gaps in the EPCs for our current housing stock.

This work ensures more accurate data on our housing stock condition to refine appropriate solutions for each home.

The barriers or challenges people in our local area might currently face in terms of being able to heat their homes according to their needs

Barriers exist at the macro and micro level. Despite higher than Scottish average household incomes, 20% of Perth and Kinross Households have an income of less than £20,000. The Scottish Housing Condition Survey 2022 (SHCS) predicts 43% of these households are in fuel poverty. Furthermore 12% of households in Perth and Kinross have incomes of £15,000 or less. The SHCS predicts 89% of those are in fuel poverty. These percentages will be higher in rural low-income households, e.g. Eastern Housing Market Area has 14% of household incomes £15,000 or less. This is reflected in a higher rate of Extreme Fuel Poverty in Perth and Kinross (18%) than the Scottish Average of 12.4% (when SCHS data was last available in 2019) . Households with low incomes, particularly those with higher energy needs (such as the elderly, disabled, or those with chronic health conditions), find it challenging to afford their energy bills meaning that this winter many will ration fuel or disconnect which will have severe health and well-being impacts leading to more costs to the public purse in terms of the NHS. It is expected that the means testing of Winter Fuel payments will have an impact on the affordability of energy for some with high energy needs.

We have worse than the Scottish average energy efficiency, as well as older and larger properties than average with an outsize proportion off the gas grid due to rural locations. These require greater demand for heating given the higher latitudes, more hours of darkness and colder temperatures in winter than more southerly located homes. As such the fluctuating cost of heating oil is also significant in Perth and Kinross. Rising energy costs adversely impact low-income households and as well as those in rural areas which pay a premium due to availability and accessibility of affordable options in terms of both food and fuel. Households with no access to gas have the additional pressure of having to have a significant sum of money available to order oil.

Low income rural households are therefore exposed to at least 3 of the drivers of fuel poverty which is likely to explain in part the higher rate of extreme fuel poverty in Perth and Kinross.

The significant increasing cost of energy outweighs any benefit that would have been created by improvements in the heating or building fabric. This resulted in locally reported statistics in the Perth & Kinross Early Learning and Childcare Bi-annual Survey of parents. When 11% (of 460 responses) said they struggled to pay energy bills to heat their home and a further 14% said they sometimes struggled to pay energy bills to heat their homes.

The educating and understanding of people in how to run their heating efficiently and how to operate their heating/how the heating works as well as the influence of the energy market, can be challenging as many people have and it is often difficult to change this. This challenge will increase with the introduction of newer fuel and energy technologies.

A range of steps have been taken by Perth & Kinross Council since 2021 to tackle fuel poverty in our area as a delivery partner

Improving Energy Efficiency

Carrying out insulation measures; installing more energy efficient heating systems and windows/doors; improving fabric measures; utilisation of HEEPS ABS funding wherever possible to improve energy efficiency in privately owned homes; setting up ECO4 approved contractors’ scheme to provide energy efficiency measures in privately owned homes; designing new build housing to higher energy efficiency standards than the current building regulations.

Increasing local incomes

The Council created a local scheme (Financial Insecurity Fund) in December 2020 for Perth & Kinross households in receipt of low incomes which provided access to payments in respect of priority debts (energy, Council Tax, rent, school dinners etc).

In addition, the scheme provides one-off payments to those living rurally that experience increased cost of living compared to those in urban areas; crisis payments to those with no recourse to public funds; and assistance with infant formula for households that have exhausted all other available resources at that time.

Applications to the fund provide a comprehensive welfare benefit check as an integral part of the assessment and so an opportunity to maximise income prior to payments being made.

Since December 2020, the Fund has allocated £379k towards energy debts for households throughout the Perth and Kinross area, and in 2023-24 over £9k to households in rural areas towards the cost of oil and solid fuel.

Financial Insecurity Fund spend in respect of energy debt (£) 20/21 - 50,233.53 21/22 - 80,257.40 22/23 - 115,704.72 23/24 - 129,942.03 24/25 - 2,666.48

£379k has been dispersed in just over the 3-year period to low-income households to reduce or remove their energy debts entirely. This does not take into account the increased income on an on-going basis via income maximisation, or additional income through reduced deductions or no deductions from benefits or income in respect of these and other debts.

Last fiscal year the Council’s Welfare Rights Team generated at least £8.5m in additional income to the residents of Perth & Kinross via the welfare benefit systems and processes.

More of the activity undertaken by the Council’s Welfare Rights Team to maximise incomes and provide longer-term sustainable solutions for households can be found within their annual report: www.pkc.gov.uk/wrannualreport

The Welfare Rights Team also makes regular referrals to CAB for those in crisis to access Fuelbank vouchers, seamless referrals to SCARF and other local energy advice projects in the normal course of their work.

In 2023-24 the Scottish Welfare Fund Team provided around 5,000 Crisis Grants in Perth and Kinross to households in crisis to the value of over £650k to allow those households access to food and fuel.

Reducing energy costs

Use of PV is being explored and installed wherever possible. Use of Sunamp and battery storage and other innovative energy solutions are also being explored, as well as initial investigations into heat networks.

Supporting people to heat their homes efficiently

Support to the HEAT Project and Warm Connections (both organisations that offer free home energy advice) in addition to our work with SCARF. As a result of the Council’s funding to SCARF (approx. £128,000 for 2023/24), 1551 households have been provided with energy efficiency and/or low carbon heating advice from April 2023 to March 2024. Households were provided with fuel poverty and renewable energy support such as advice on improvement measures (loft insulation, draught proofing, energy efficient appliances), as well as referrals to national and local schemes, and writing off fuel debt.

This funding is a result of two funding streams; one from the Council’s Climate Change budget, and one from the Property/Housing budget.

With regards to the Climate Change stream, £68,000 was allocated to SCARF for 2023/24 for the expansion of their Home Energy Advice Team service (existing service operating linked to the Property/Housing funding) to allow more households to receive help with fuel bills, but to also provide renewable energy support which was previously not covered from the existing energy advice service.

The provision of the Climate Change funding for 2023/24 therefore resulted in a total £10,439.25 of fuel debt being written off in 2023/24, an estimated £17,456.91 cost savings and an estimated 51.33 tonnes of carbon dioxide (tCO2) savings because of the advice provided to households.

Have actions undertaken by Perth & Kinross Council since 2021 either helped to improve fuel poverty OR helped alleviate the impacts of fuel poverty on people in our local area, and why?

Yes, we confirm this is improving fuel poverty and the impacts, through the improved energy efficiency, we are reducing energy demand. However, the full benefit of this is not being fully felt as the cost of energy rises are impacting on the benefits.

The comparative cost of electric units to gas units needs to be reviewed. The biggest cost for an Air Source Heat Pumps is to get it up to temperature, but impact of increasing unit costs needs to be factored in.

With regard to the LHEES, it is too early in delivery to say that it has improved fuel poverty levels but has helped us identify priority actions and geographic areas to focus on.

It is difficult to track impacts on Fuel Poverty due to access to data. SHCS was last able to provide figures at the local authority level in 2019, but statistically comparable figures will not be available until 2026. In the meantime, less accurate modelled figures have to be relied upon. It would be beneficial if the SCHS could be expanded to produce annual local authority figures to assist in attaining the 2040 Fuel Poverty reduction target.

Have actions undertaken by PKC since 2021 helped reduce the impact of the 4 drivers of Fuel Poverty?

Poor Energy Efficiency?

Yes, but much more is needed. Still a work in progress with the benefits of technological improvements contributing more to over time e.g.: advances in PV technology.

High fuel prices?

No - unfortunately not. Actions to improve Energy Efficiency are currently outweighed by the rapid increases in energy prices, often creating lasting fuel debt. This has long term implications for affordability of energy by impacts of types of billing and meters, meaning that often the most vulnerable are the most exposed to the macro-economic setting of energy prices. Housing costs in Perth and Kinross are also rising, impacting on the ability to afford heating. The introduction of a social tariff for energy could help to protect the most vulnerable to increases in fuel costs and addressing Standing Charges as they also have a large impact also on affordability.

Low income?

No. Due to cost-of-living increases, everything is more expensive, and this results in tenants having to make decisions on whether to eat or heat. However, as a Housing Service, there are areas of focus where support is made available, such as ensuring that tenants are claiming all the benefits to which they are entitled, without stigma.

Inefficient use of heat in the home (household behaviour)?

Yes. A successful pilot of embedding of live sensors in homes to improve heat/ventilation in council properties is planned for expansion in 2025.

Challenges to delivery of tackling Fuel Poverty in our local area include:

• Take up of HEEPS ABS by private homeowners, including private landlords due to perceptions around 'cowboy contractors' and reputable installers, for example, incorrectly designed and specified heat pump systems having a negative impact on the benefits.

Social media - allows bad press to be circulated without any control and the impact of negative comments without challenge. These challenges around private homeowners can also impact mixed tenure blocks resulting in additional challenges for council owned properties.

• Tenant refusal to allow improvements to their social housing property is a challenge.
• Access to building level and/or robust area level data to enable accurate targeting of energy efficiency measures to improve fuel poverty. Personal data and GDPR act as a barrier to effectively sharing information between organisations and sectors seeking to target fuel poverty. SMID data is used to guide where the prioritisation of the workstreams should be targeted to ensure that the right groups are being targeted and prioritised, but this data may be out of date given the time taken to collate the information and for it to be made available.
• A complex fuel poverty funding landscape and limited access to data to target households based on complex, and often personal data linked to eligibility criteria act as a barrier to area-based targeting at the scale needed to improve energy efficiency and tackle fuel poverty to meet targets. A streamlined funding landscape, including a mechanism to spatially target households or areas experiencing fuel poverty and a mechanism for data sharing and data improvements across partner organisations working to alleviate fuel poverty would be welcomed.

The following further action is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland

• Reform of funding streams for alterations to social housing - the Housing Revenue Account relies on rental income and with the levels of energy efficiency improvements required, rental income cannot rise in line to provide sufficient funding.
• Programmes for delivery of funding stream work need to be more realistic - a construction project involving mixed tenure blocks is difficult to manage and co-ordinate and there needs to be a longer timeline for addressing the engagement and consultation to ensure as much uptake as possible allowing proper planning for safe delivery of the workstreams.
• Funding thresholds for individual measures and the criteria for the measures that receive funding need to be consistent and practical.
• Scottish Government should be marketing the available funding streams and giving them more media coverage - official marketing to help support the funding streams and counter beliefs (often promoted through social media) that the funding is a scam - this doesn't endorse the work that contractors are doing, but more endorses that there is funding available and raises awareness across Scotland (for example - for HEEPS ABS and ECO4).
• Less complex application processes for householders, businesses and local authorities, but including measures to ensure fraud is not possible.
• Publication of an ambitious Heat in Buildings Bill with stringent targets for landlords around improving energy efficiency. This will also hopefully help give local Small and Medium-sized Enterprises (SMEs) the confidence to upskill and invest in home retrofit capacity due to the increased certainty of the pipeline.
• Availability of timely, local fuel poverty data availability would be very helpful.
• Small things around how people can access Home Energy Scotland also will help (e.g. enable suppliers to be paid directly rather than having to go through the householder as having the necessary liquidity is a barrier for householders; if buying a new house enable people to apply for the grant funding before they own it so they can arrange for contractors to do the works before moving in; speeding up processing times.
• The changes to and lack of adequate resourcing of energy efficiency schemes over the years means that there is a confusing (for the householder) range of measures that need to be taken in the home and EPCs currently are not a robust guide to these. A step change in the resourcing, targeting and adequacy of these schemes is required.
• As we adopt low-carbon heating systems as we are trying to do in Perth and Kinross, there may be a greater demand on electricity which remains four times the cost of gas. This price discrepancy risks inadvertently increasing bills without dedicated support for those in fuel poverty. A wider reconfiguration of the current energy markets to align electricity and gas prices is needed. This requires attention otherwise fuel poverty will continue.

Respondent: Scottish Borders Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

The barriers or challenges within the Scottish Borders Council area might be described as follows:

• High number of rural off gas properties and a large percentage of older property archetypes. Solid walled pre-1919 properties are harder and more expensive to heat and keep warm, and suitable insulation measures such as Internal Wall Insulation are costly. Immediately puts households at risk of more expensive energy costs to heat their homes.
• Higher than average fuel poverty levels and lower average wages combine to make it hard for households in the region to heat their homes according to their needs. This then leads to additional negative impacts around health and well-being.
• Lots of properties are off gas and have no access to the current cheaper fuel choice. This means higher the cost of fuel is higher for many households, such as oil or the higher cost of electricity.
• Price volatility of oil has been an issue. As we push towards clean green heating such as Air Source Heat Pumps, then ultimately electric will be the fuel option, but increasingly high electricity costs mean this is an expensive option, especially for someone currently on gas.
• A key issue is what benefit or incentives are there to encourage a vulnerable and/or fuel poor household to switch to a more expensive fuel type, with a system that also needs significant upfront costs to instal?

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

Within the Scottish Borders Council area, we have:

• Successfully delivered energy efficiency schemes. EES:ABS. This has targeted older solid walled archetypes through Internal Wall Insulation and also delivered clean green heat through heat pumps and through installation of Solar PV system with battery storage. As per LHEES and EES:ABS methodology has been able to target households in or at risk of fuel poverty. A total of 78.61% of all participating EES:ABS properties are in the most deprived parts of the council area as per SIMD ratings.
• Seen a steady increase in EPC ratings across the region. Driven in part by energy efficiency schemes, such as EES:ABS and the RSL EESSH 1 & 2 where EPC improvements are made across social housing stock. Whilst it is early in the LHEES delivery, the core of the LHEES will continue to promote energy efficiency and improvement of property energy ratings. Across the scheme EES:ABS has seen average SAP improvement of 8.23 across all dwelling types.

b) Increase local incomes in your area

Local partnership with Citizens Advice and energy charity Changeworks, secured funding through Warmer Homes (National Grid) to deliver Warm & Well. Two key aspects to Warm & Well were Energy Efficiency support for those identified as being in fuel poverty, and the offer of benefit checks and income maximisation. The scheme has been successful and well received.

Support included working in partnership with local Social Housing energy advocacy services, so all tenures were supported.

c) Reduce energy costs in your area

Whilst Scottish Borders Council is unable to influence the cost of energy, it supports households to use less energy by promoting retrofit insulation and increasing thermal comfort, and/or in moving to more efficient heating and/or in supporting a switch from older polluting hydrocarbon systems to clean green heating. These initiatives are underpinned by an ambition to protect households from increased costs including those which result from a less appropriate heating system or regime.

The success of the EES:ABS scheme over several years has enabled households to maximise their properties’ potential in reducing energy use and therefore energy cost. IWI for example continues to be an important measure for the EES:ABS scheme as it targets hard to heat properties in areas of fuel poverty. Older solid stone properties are a common archetype within the rural Borders.

d) Support people to heat their homes efficiently in your area (behaviour)

Knowing how to best use their heating systems or to reduce consumption of energy is key to households getting better value.

We have promoted energy advice and advocacy services; primarily through Home Energy Scotland, but also through local energy action and through a joint energy advice and income maximisation service delivered in partnership with CAB called Warm & Well. A similar sister service was provided specifically social housing tenants. This had behaviour change and guidance at the core. We also signposted households to further support where appropriate.

Behaviour change and energy advice are offered to households as part of the EES:ABS delivery and through working with organisations such as Home Energy Scotland. Hosting events in the region or through online support is well-established. The local Social Housing will also offer advice and support to their tenants.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Both the EES:ABS and more recently the nascent LHEES have supported the alleviation if Fuel Poverty, and will continue to do so.

EES:ABS has been a core delivery mechanism and was positioned within the Council’s Affordable Warmth strategy and Local Housing Strategy. The newly published LHEES builds on this and has provided a cohesive framework across all local authorities in a tight timeframe that will drive positive changes in fuel poverty reduction/mitigation and decarbonisation delivery.

We have provided actual measures that have been installed and bring immediate changes and benefits to households. This is particularly so when targeting those in fuel poverty or who are vulnerable to fuel poverty.

EES:ABS is now a mature delivery mechanism and effectively targets the high number of perennial issues with the local housing stock, such as solid wall older properties needing IWI or the high number of off gas properties on oil or electric that can be successfully offered a switch to heat pump, or “low regret” switching households.

The LHEES enables a clear ground up review of the areas most in need of intervention around energy use, energy costs and practical measures. Whilst some of these interventions and initiatives will be larger, longer-term projects, involving other regional stakeholders, such as potential Heat Networks, others have already been well served by shorter term more immediate actions. E.g. retrofit insulation, energy advice and support, switching etc.

LHEES outputs have informed EES:ABS strategy and will continue to do so. In turn, EES:ABS allows a targeted 12 monthly cycle to address specifically fuel poverty and the effects of fuel poverty.

Table 5: Investment in EES: ABS since 2021

Source: SBC and Changeworks monitoring data

Households assisted by EES: ABS	EES: ABS investment levels	Measures installed	Households supported
2020/21	£1.72m	195	176
2021/22	£1.78m	192	116
2022/23	£1.8	225	138
2023/24	£1.82	100	88

We have seen a transition away from lower cost interventions such as CWI, towards higher cost measures that are a more holistic and focused on carbon reduction as well as addressing fuel poverty. These interventions primarily comprise Heat Pumps and solar PV and battery technology.

It follows that the trend is towards fewer, but more expensive measures. This reflects an evolution from easier retrofit insulation measures, such as Cavity Wall Insulation and loft insulation towards more complex interventions like Internal & External Wall Insulation, Air Source Heat Pump replacing oil or electric systems, and increasing solar PV & battery storage installs. These developments reinforce and address the need to consider both energy efficiency and decarbonisation in buildings.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

Please see our previous responses.

Our insights on progress with reducing fuel poverty are limited to the Scottish Borders. However, based on our experience, and assuming that experience and progress is reflected in other local authority areas in Scotland, it seems likely that meaningful progress is being made.

At the same time, it is important to recognise that different places will have different drivers of fuel poverty and care must be taken not to extrapolate general conclusions based upon a limited number of places or examples of activity. Moreover, that ‘one rule does not fit all’ reinforces the cardinal importance of a regional approach to the issue, permitting local authorities and their partners to develop approaches which best respond to local circumstances.

According to the Scottish Housing Condition Survey (SHCS), the average fuel poverty rate in the Scottish Borders Council area is around 29% of all homes. This is 5 percent higher than the Scottish national average (24%) and places the Scottish Borders Council as 23rd of all 32 local authorities in the country. This is driven by regional energy efficiency improvements through schemes such as EES:ABS, Warmer Homes Scotland, ECO/ECO Flex and the EESSH standards for social housing.

With each Local Authority being able to focus on their own challenges and opportunities, we expect to see a positive response to driving down and eradicating fuel poverty.

a) Poor energy efficiency?

Please see our previous responses.

b) High fuel prices?

Please see our previous responses.

c) Low income?

Please see our previous responses.

d) Inefficient use of heat in the home (household behaviour)?

Please see our previous responses.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

Within the Scottish Borders Council area, the following are important challenges to progress in addressing fuel poverty:

• No “at scale” dense urban pockets or pots of same/similar archetypes. We must make projects smaller or more open to different archetypes/sizes which can increase cost as remodelling is required and benefits of scale lost.
• Funds to target at scale projects. The lower cost “easier” measures were largely done first, with the higher cost, longer payback properties left.

• Listed and historic buildings can represent specific challenges as generally the skills and materials that would be approved, cost significantly more than the standard alternatives. This means doing anything to upgrade these properties is very difficult.
• Rurality. Costs more to do any work in rural and remote rural locations. A mark up on everything and from travel costs to delivery. Everything costs more to deliver and to supply.
• Skills shortage or lack of competition. Settled smaller SMEs and “one/two person” businesses don’t need to go looking for work or having to generate interest/pipeline of work. Need to be a better/smarter/fairer way to get a more robust supply chain locally.
• Reliance on out of region supply chain to deliver projects.

What further action do you feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

• Continuation of the funding for schemes such as EES:ABS to deliver improvements for vulnerable households. Important this is not diluted or reduced.
• Any steps that can be taken to support / sanction lower energy costs, particularly electricity, to support the switch to cleaner green heating systems such as heat pumps.
• Working with energy suppliers to address the challenge off escalating energy costs, particularly for those in rural locations.

Respondent: Shetland Islands Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

Shetland has the second highest rate of fuel poverty in Scotland.

The fundamental issue is the high cost of energy and our exposed and windy climate, which means households have to use fuel to heat their homes for a greater proportion of the year than any other part of Scotland. Many households are making difficult choices about heating their homes, or purchasing other essential items.

Households have a lack of choice, when it comes to cheaper and more efficient heating sources. The predominant heating source is electric, making average household energy costs double those of a UK household.

The lack of contractors exacerbates this, meaning that energy efficient choices are also constrained.

The demographics of a growing number of smaller households is resulting in us having an increasing number of under-occupied households. This means that less of the property is heated, which in turn, impacts on property condition.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

• Implementation of grant schemes, such as the Area Based Scheme
• Assist with Warmer Homes Schemes (e.g. carry out property assessments)

b) Increase local incomes in your area

• Distribution of Islands Cost Crisis Emergency Fund
• Economic development activity
• Employability Pathway
• Funded contract (Financial Health and Fuel Poverty Advice) and referrals to CAB

c) Reduce energy costs in your area

• Lobbying for consideration of a Shetland Specific Tariff
• Use of Fuelbank Foundation, Scottish Welfare Fund

d) Support people to heat their homes efficiently in your area (behaviour)

• Advice pages on the Council’s website
• Staff provide advice when inspecting properties

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Yes, we have, in order to ensure Shetland’s population has good health and wellbeing outcomes. However, despite all of our collective efforts, the rapid increase in energy prices means that fuel poverty rates continue to escalate.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?:

a) Poor energy efficiency?

Yes, through landlord actions to meet energy efficiency standards and loans / schemes available to householders.

b) High fuel prices?

No, because we have no effective levers to do this.

c) Low income?

Not to any measurable effect.

d) Inefficient use of heat in the home (household behaviour)?

See 2d) above.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

The following are challenging:

• The policy and funding landscape is cluttered and burdensome.
• A lack of appropriately targeted funding.
• Frequent consultations on proposed schemes, lack of clarity and guidance over implementation, shifting timescales for delivery on schemes, for example EESSH, followed by EESSH2 (which never got implemented) to be replaced by SHNZS, for which there is no guidance (consultation ended in March)
• Rising energy costs without any commitment from Government to tackle this, and a broader lack of commitment for any other substantial mitigation
• A one-size-fits all to delivery of grant and loan funding, which doesn’t consider the difficulties of delivery in a remote island local authority with a varied and disperse housing stock. This is particularly the case with insulation projects, and fabric first is essential to combat energy costs most effectively:
  • Accreditation required to undertake works for grant schemes is suited to large firms, not the small, family-run firms based in Shetland that can’t commit to the large amount of time and paperwork required to both achieve and maintain accreditation. Also, training generally is delivered away from Shetland which is time consuming and costly for prospective installers.
  • The different solutions required for retrofit insulation upgrades due to the build types means that where we require works, and there is an absence of local contractors, the use of external contractors often isn’t an option as they are working to methods of install that doesn’t suit our needs;
  • This impacts on low carbon technologies where the fabric of the property impacts on the efficiency of the technology e.g. heat pumps.
• Equalising of some grant/loan funding e.g. currently can get grant/loans for heat-pumps but only a loan for community heating. This would help to widen the options available to in the absence of mains gas in Shetland and the removal of improvements to oil systems for grant support.
• Limited number of alternative energy companies, if a household requires ‘Total Heat, Total Control’ equivalent, constraining better deals and being able to take advantage of Smart Metering although signal issues is hampering the operation of smart metering rolled out to date.
• If an Islands Community Impact Assessment is undertaken, none are done to a standard to island proof policy and schemes.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland.

Clarity, with a focus on reducing energy costs.

Respondent: South Lanarkshire Council

What barriers or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs.

Low income, poor financial resilience and a vulnerability to income shocks is a major factor that contributes to people being unable to heat their homes in South Lanarkshire. This has been exacerbated in recent years by the volatile consumer energy price market, which has seen household energy prices increase significantly.

Deepening levels of poverty because of the significant increases in the cost of basic essentials such as food and heat which disproportionately affect those on lower incomes. Many low-income individuals, families, struggling to get by and unable to meet their basic needs and keep their homes warm, heat food due to rising energy prices. A significant challenge for residents being able to heat their homes is the high cost of energy.

Availability of funding for retrofitting their homes to make them more energy efficient will also be a barrier for residents to reduce their homes’ heat demand to make it easier and cheaper to heat.

South Lanarkshire has substantial rural areas, which are potentially at greater risk due to the particular rural dimension for fuel poverty identified in the Scottish Rural Fuel Poverty Task Force Action Plan Report in 2016. A key priority for housing investment programmes and advice and support services will be to continue to identify and target those rural housing areas and people who are likely to face higher risks of fuel poverty, including off-gas grid homes and solid wall, non-traditional construction types.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

The Council has invested approximately £78m since 2021 in the domestic housing stock. Investment in improving the energy efficiency of homes has undoubtedly mitigated against the level of fuel poverty worsening, as acknowledged in the Report of the Scottish Fuel Poverty Strategic Working Group (October 2016) however since then significant challenges have arisen in the cost of energy used within homes.

The council has and continues to actively direct its Housing Investment Programme and utilise national funding including the Energy Efficient Scotland Area Based Scheme to deliver a wide range of energy efficiency improvements within its’ housing stock, including external wall insulation, installation of high-performance doors and double glazing.

In June 2023, the council also set up arrangements to support delivery of the Energy Company Obligation Scheme which continues to deliver a range of energy efficiency measures across private homes in South Lanarkshire.

As a result of this investment, the average Standard Assessment Procedure (SAP) rating for all homes with an Energy Performance Certificate in South Lanarkshire rose from 65.1 in 2021/22 to 67 in 2023/34.

b) Increase local incomes in your area

A partnership Living Wage Campaign Group brings together public sector and national organisations and the business sector to promote payment of the Living Wage to employers across Lanarkshire. The council also supports the Living Wage Accreditation Discount Scheme.

A partnership Fuel Poverty Group brings together various public sector and national organisations who promote the financial advice supports that are available. The action plan includes actions and measures aimed at maximising household income levels. The group has also produced a Tenant's Energy Guide and Advice for those worried about energy costs and falling into debt.

A partnership Local Child Poverty Action Plan Group brings together various public sector and national organisations to address the drivers of Child Poverty. Work focuses on three main areas, income from employment, cost of living and income from social security and benefits in kind. The latest report which provides and overview of progress to date and includes cases studies, can be found here.

Money is not the only problem

This is an online resource to assist individuals and families with accessing help, support and guidance regarding finances and wellbeing including energy. Booklets are also available and are distributed to partners, communities, public buildings and at events.

South Lanarkshire Council has primarily tried to address fuel poverty drivers through the provision of support from its in-house money and welfare rights service. In 2023-24, the Money Matters Advice Service generated £24.2m in financial gains for residents in South Lanarkshire, supporting 12,694 unique households and made 6,432 referrals for emergency energy vouchers.

A triage service deals with food and fuel emergencies when people present with these. This is primarily achieved by working with food banks and fuel vouchers providers, but also by the investment by South Lanarkshire Council in the creation of a Cash First Scheme that sees 97% of people who are successful receiving same day financial support with a £50 payment.

This scheme has built on previous schemes that included a Financial Wellbeing Support Fund that invested £1.6m in financially supporting approximately 6,000 households as they received advice with payments of £250 and also an Energy Top Up Voucher Scheme in partnership with the Wise Group that distributed over 10,000 energy top up vouchers to residents in South Lanarkshire. The council worked with the Citizens Advice Bureaux in South Lanarkshire to ensure they could refer their clients direct to the Wise Group, thereby maximising the reach of the voucher scheme across the council area.

c) Reduce energy costs in your area

A partnership Fuel Poverty Group brings together various public sector and national organisations who promote the financial advice supports that are available. The action plan includes actions and measures aimed at reducing energy costs. The group has also produced a Tenant's Energy Guide.

d) Support people to heat their homes efficiently in your area (behaviour)

As above, a partnership Fuel Poverty Group brings together various public sector and national organisations who promote the financial advice supports that are available. The action plan includes actions and measures aimed at providing energy saving information and advice. The group has also produced a Tenant's Energy Guide.

Over 6,432 people received basic energy advice and support and 444 people received specialist level energy advice and support, as our Money Matters Advice Service has employed an energy adviser and is seeking to source funding for another.

In your opinion have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Yes.

The range of support provided by the Money Matters Advice Service both financial and advisory has provided a level of mitigation for households to counter some of the worst effects of the significant increase in energy costs. Any important element of support is the provision of a benefit check. The award of new and sometimes backdated benefits can result in clients’ financial circumstances changing significantly and this can help with meeting higher energy costs.

The appointment of a dedicated energy advisor within the service has allowed specific energy support to be provided to clients including access to a wide range of providers of energy vouchers.

Since 2020/21 the percentage of South Lanarkshire Council’s housing stock meeting Energy Performance Certificate Bands A to C has increased from 90.95% to 92.62% while over the same period the average Standard Assessment Procedure rating for housing stock has risen from 73.82 to 74.46. This suggests that the significant investment led by the council is improving the energy efficiency of homes across South Lanarkshire.

The main priority for the council’s new LHEES is to reduce heat demand using a fabric first approach to improve the condition and energy efficiency of housing across all tenures to ensure that poor energy performance is removed as a driver of fuel poverty. As the strategy moves to a delivery phase, a key focus will be to help to alleviate the impacts of fuel poverty on people in South Lanarkshire.

In a national context, South Lanarkshire is the tenth most deprived area out of 32 local authorities, based on the SIMD analysis carried out. A total of 31,590 properties in South Lanarkshire fall within SIMD deciles one and two. Just under half of the total properties owned by the Council fall into this category. This illustrates a strong link between the social housing tenure type and areas with high SIMD scores. With a priority of alleviating fuel poverty, South Lanarkshire Council has used the LHEES process to investigate areas of high probability of multiple deprivation in conjunction with category one properties.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

Yes, as can been seen in the RdSAP and EPC metrics highlighted in question 3 above. As at March 2024, 95.4% of the Council’s housing stock are compliant with EESSH, up from 93.88% in 2021

b) High fuel prices?

No, it is not believed that any one council can influence the global markets for fuel prices.

c) Low income?

During 2023/24 the council’s Money Matters Advice Service assisted 12,692 unique clients across South Lanarkshire and brought £24.2 million in financial gains for residents.

The council operated a Financial Wellbeing Support Fund that invested £1.6m in financially supporting approximately 6,000 households as they received advice with payments of £250 and also an Energy Top Up Voucher Scheme in partnership with the Wise Group that distributed over 10,000 energy top up vouchers to residents in South Lanarkshire.

Overall, 79% of Money Matters clients live in data zones that are classified as being in the lower half of all SIMD data zones, showing that the service is successfully reaching clients that are in the most deprived areas of South Lanarkshire.

Over 6,432 people received basic energy advice and support and 444 people received specialist level advice and support.

Money Matter Advice Service Financial Gains:

• 2021-22 - £18.8m
• 2022-23 - £27.6m
• 2023- 24 - £24.2m

The Citizens Advice Bureaux also delivered similar types of support in South Lanarkshire, supporting households who were experiencing fuel poverty.

d) Inefficient use of heat in the home (household behaviour)?

The council’s Money Matters Advice Service works closely with Home Energy Scotland to ensure that people have access to advice about keeping warm at home and saving money on your energy bills. Energy advice, including energy saving advice has been provided by Money Matter Advice Service through the dedicated Energy Advisor.

Significant efforts have also taken place to support the council’s 25,000 tenancies in reducing inefficiencies within their homes. This includes energy advice and support information published in regular newsletters and sent to all households, as well as supporting tenants with the transition to net-zero systems with the provision of ‘how to guides’ to make the most of their new system.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

The scale of the issue has made the efforts to tackle fuel poverty challenging: 31,590 households in South Lanarkshire live in fuel poverty. In terms of the council’s land area and population distribution: 75% of the land is rural and is inhabited by 25% of the population; 25% of the land is urban with 75% of the population living in these areas. It is estimated that one in every five properties in South Lanarkshire is off the gas grid and will pay more in energy costs (source: non-gas map). In addition, the uncertainties around the level of fuel poverty add to the challenge with no accurate national or local data sets available.

Limited timescales for delivery and an underdeveloped supply chain for energy efficiency measures has presented significant challenges in maximising the impact of funding made available through the Energy Efficient Scotland Area Based Schemes. Owner contributions within mixed tenure buildings also add to the complexities within these projects resulting in many not being progressed despite an identified need for them to do so. Additional flexibilities for the council in utilising this type of funding to target fuel poverty would be beneficial.

Improving customer awareness of how to maximise the benefits of any energy improvements made to properties is also a challenge.

The availability of funding for expensive measures such as external walI insultation, heat pumps, heat networks, solar PV panels and battery storage also presents a challenge to talking poor energy efficiency as a driver for fuel poverty.

A further challenge we have is about how fuel poverty is measured: (1) it is largely dependent on the income of the household and therefore very fluid and, (2) there is no real accurate way of measuring it. For example, we could complete a survey to see who is in fuel poverty, then target investment at their property to improve energy efficiency with the aim of reducing their bills and lifting them out of fuel poverty. In the time it takes us to upgrade the property the tenant has moved to a different property with lower energy efficiency ratings and remains in fuel poverty.

The only solution is to aim to bring all stock up to higher standard which is increasingly difficult to do given the standards themselves keep changing and the council stock keeps getting older.

To date, there has not been a comprehensive dataset detailing fuel poverty given the resources required to do so and the risk of identifying individuals and communities through the use of sensitive information such as income data. The fuel poverty data in the Home Analytics dataset is therefore probability driven and figures are not an absolute number or percentage but rather a likelihood of fuel poverty. An instance where fuel poverty data lacks confidence and leads to a poor representation of the geographical area is in households in affluent areas who may be labelled as in fuel poverty because they live in stone buildings with poor heating capture.

What further action do feel is required from the Scottish Government for the purposes of reducing/ mitigating fuel poverty for vulnerable households in Scotland?

Ensure that the transition to net zero is just and does not increase fuel poverty by introducing more costly alternatives, for example a move from gas to electric. More cost effective green alternatives which focus on decreasing fuel poverty levels for those on low incomes, could be explored. Consideration could be given to better targeted and fairer allocation of fuel payments that include families experiencing ‘in work’ poverty.

Further investment in renewable energy projects which are owned and operated by local communities however with the appropriate support networks to build community capacity. Continue to challenge the injustices of the energy sector in providing affordable energy (UN SDG 7).

Given that the social, economic and health determinants of poverty reach far wider than those set out in this policy, consideration could be given to aligning this legislation to existing legislation and policy, for example relating to Child Poverty Action, Employability, Housing, etc.

Consider additional incentives and financial supports for households that are off grid to support them to reduce energy costs and phase out fossil fuels.

The Scottish Government could implement multi-year funding for the Energy Efficient Scotland: Area Based Schemes to give future certainty to allow local authorities to plan strategic retrofit investment programmes. The Government could also expand the options of financial products available to private landlords and owner occupiers through the Home Energy Scotland service.

The Scottish Government could encourage the UK Government to complete the review of electricity market arrangements (REMA) and decouple the price of electricity from that of gas, thereby reducing electricity costs.

The Scottish Government could also apply pressure to the energy companies to provide a ‘social housing tariff’ for the most vulnerable tenants who are struggling to pay their energy bills at the current rates.

The Government could also renew investment in the Fuel Insecurity Fund.

Assessing progress and the impact that the council is making on Fuel Poverty levels can be challenging. National statistics are available through the Household Condition Survey; however, this data is only available at a Local Authority level every few years, with the next available data due to be published in 2025. More timely data at a Local Authority level is required.

Respondent: West Lothian Council

What barrier or challenges might people in your local area currently face in terms of being able to heat their homes according to their needs?

People in West Lothian, like many parts of the UK, face several challenges related to heating their homes. Energy prices have surged in recent years which has led to soaring electricity and gas bills, leaving many households struggling to keep their homes adequately heated. The increase in energy costs has pushed many households into fuel poverty, which is defined as spending more than 10% of income on heating. In West Lothian, this is a significant concern, especially among lower-income households, pensioners, and people with disabilities. Energy providers charge households standing charges that are fixed daily costs, regardless of how much energy is used. These standing charges have also been rising, putting additional strain on those who consume less energy or live in smaller homes. For people on low incomes, these charges can be a disproportionate financial burden. In homes where energy use is lower, the fixed standing charge can become a significant percentage of the total energy bill, even if the household doesn’t consume much energy.

Older people and people with chronic illnesses or disabilities are particularly vulnerable to cold weather and often have higher heating needs. Many are living on fixed pensions or benefits and cannot absorb the additional cost of heating during colder months. Larger families can face higher heating demands, but the rising costs make it more difficult to maintain adequate warmth across the home.

Many households are not just struggling to afford heating, but also find themselves trapped in energy debt. As energy prices have increased substantially, many households in West Lothian have accumulated substantial arrears on their energy bills. 18% of West Lothian households are in fuel poverty. 9% of West Lothian households are in extreme fuel poverty. 31% of Scottish households were in fuel poverty in 2022. With the increasing impacts of the cost of living, paying off energy bills becomes an ever-growing challenge. People in this situation often find themselves locked into a cycle of debt that can feel impossible to escape.

A significant challenge that people face is negotiating affordable repayment plans with energy suppliers with some suppliers imposing repayment terms that are unreasonably high, making it impossible for the customer to stick to the plan.

The Scottish Government’s Home Heating Support Fund (HHSF), which provided crucial financial support to low-income households struggling with fuel debt, has been a huge loss for many. It helped people pay off arrears and provided a much-needed safety net, especially during cold weather months. The loss of this fund has left a significant gap, as people are now unable to access this kind of support from the Scottish Government. Without the HHSF, those already in debt now have fewer avenues to reduce their arrears, pushing them further into energy poverty. The loss of this fund has also increased the pressure on local councils, charities, and advice services who assist people in debt. These services are often overwhelmed and unable to meet the demand.

For many people, the stress of dealing with mounting energy debt and the pressure from suppliers to repay at unaffordable rates can lead to significant mental health challenges. The anxiety of not knowing whether they can keep their home warm in the winter can feel overwhelming. There’s also a stigma around debt and poverty that can prevent people from seeking help. Many people feel embarrassed about their financial situation and may avoid contact with energy suppliers or debt support services. This isolation worsens their situation and prolongs their struggle.

When it comes to understanding energy bills and navigating the challenges of heating a home affordably, knowledge plays a crucial role. Many people do not understand the nuances of the price cap. It’s important for people to understand the difference between fixed and variable tariffs, and knowing how the price cap impacts individual bills so people can make more informed decisions about how to manage their energy costs. Many households do not have a full understanding of how to make their homes more energy efficient. This includes things like proper insulation, energy-saving appliances, and heating controls. While many of these changes can be simple and inexpensive, people often don’t know where to start. For those in poverty or debt, investing in energy-saving improvements can feel out of reach, even if they would save money in the long run.

The energy market is full of confusing jargon, and many consumers don’t have the time, energy, or knowledge to compare tariffs. The process of switching suppliers can be daunting, especially when suppliers may not be transparent about the pricing or offer incentives that are not easily understood.

The removal of the Winter Fuel Payment, alongside cuts to Universal Credit uplift payments and Cost of Living payments, presents a significant challenge for pensioner households and others on low incomes, especially when energy costs remain high. These cuts come at a time when energy bills are still well above historical norms, and many households in West Lothian are facing rising poverty and financial instability. The Winter Fuel Payment has been a crucial support for many older adults, providing a lump sum during the winter months to help with heating costs. Its removal disproportionally impacts pensioner households, many of which are already struggling with the burden of high energy prices.

The number of pensioners claiming means tested top-up benefit Pension Credit has noticeably decreased in West Lothian since 2012, and has continued to fall over the last five years. This may be due to lack of awareness of entitlement or reluctance to claim as there is an estimated £5.3 million unclaimed Pension Credit in West Lothian alone. Some pensioner households may have small incomes that disqualify them from Pension Credit but still leave them struggling to meet energy bills. These people may fall into a category that is too wealthy to qualify for targeted benefits but too poor to cover their basic needs, leaving them in a precarious financial position.

Local Authorities are delivery partners in many of the actions outlined in the Fuel Poverty Strategy: “Tackling Fuel Poverty in Scotland”, for example via Area Based Schemes delivery, and published Local Heat and Energy Efficiency Strategy (LHESS). Please provide a broad outline of the actions that your local authority has undertaken since December 2021 to:

a) Improve energy efficiency in your area

Since December 2021, West Lothian Council has been actively working to improve energy efficiency and tackle fuel poverty through various initiatives aligned with Scotland’s Fuel Poverty Strategy. The council has delivered Area-Based Schemes (ABS), focusing on energy efficiency measures like insulation and heating upgrades for vulnerable households, particularly those in fuel poverty.

West Lothian Council has approved the development of its first Local Heat and Energy Efficiency Strategy (LHEES), which includes plans to establish Heat Network Zones across the area. These networks will supply heat to homes and businesses from a central source, improving energy efficiency and reducing carbon emissions. The strategy, aimed at improving building energy efficiency and reducing greenhouse gas emissions, identifies 14 potential Heat Network Zones and will be shaped by public consultation later in 2024. Key issues identified include uninsulated cavity walls, which affect 30% of domestic dwellings. The LHEES, a requirement under the Local Heat and Energy Efficiency Strategies (Scotland) Order 2022, uses data from the Energy Savings Trust to inform its development, with ongoing engagement planned for homeowners and local businesses to support energy efficiency improvements.

The Advice Shop provide energy efficiency advice and in 2023/24, they provided advice to 140 individual households. When a Fuel Bank award has been granted, an automatic link to the energy efficiency page is now sent to customers. For Quarters 1 & 2 of 2024/25, this link has been sent to 434 households.

For financial year 2023/24, the council was awarded £1,025,252 HEEPS: ABS funding which was used to target privately owned properties of No Fines construction in:

• Staunton Rise, Livingston
• Talisman Rise, Livingston

A No Fines Concrete house is one that has been built using concrete without the finer particles. The method of construction was used during the period of 1920s to the 1970s. Sign-ups were successful with the target of 41 properties achieved and exceeded, with 73 homes receiving EWI and ventilation measures. The specification was also extended by topping up loft insulation to 300mm when required and to address increased ventilation by installing kitchen and bathroom extractors where the most moisture is produced in households.

Huntly Avenue and Jubilee Avenue, both in the Deans area of Livingston will be prioritised for the 2024/25 ABS grant funding using the Scottish Index of Multiple Deprivation (SIMD) to accurately identify these streets as most at risk of extreme fuel poverty with a No Fines construction type.

b) Increase local incomes in your area

In 2024, the profile of West Lothian tells us that the demographics of poverty are changing. There are now fewer people claiming out of work benefits and more people in employment than when the first Anti-Poverty Strategy was developed in 2012. Since 2016/17, West Lothian wage growth has been consistently strong and overtaken the Scottish average, in comparison to the Scottish level where slow wage growth has been identified. Underemployment and insecure jobs continue to be key factors for the working age population creating potential for higher levels of ‘in-work poverty’. Local unemployment is 2.8% of the general working age population. This rate is 0.5% below the Scottish average and 1.5% below the UK average. The tightening of labour supply and an ageing workforce can be seen as an opportunity for local people to retrain and up-skill.

There is some emerging evidence of increased post-retirement working at the highest rate since the beginning of the pandemic in 2020. Evidence also points to retired people coming back into the workforce due to cost of living pressures. Housing Customer and Building Services will be researching what available data sources they have, to identify older people missing out on pension credit entitlement in order to develop a more targeted approach for a wider reach to help older people maximise their household income.

The Anti-Poverty Service is exploring the use of the Inbest tool to deliver targeted interventions for older people, aiming to maximise their income and ensure they claim Pension Credit. By utilising the tool, individuals who may be entitled but not yet claiming benefits such as Pension Credit, can be identified which can be key to unlocking further entitlements such as the Winter Fuel Payment. This approach will help ensure that older residents receive the financial support they are due, particularly during the colder months when energy costs rise.

Over the last three years, the Anti-Poverty Service has been rolling out Energy Grants to help with soaring energy prices. In West Lothian, 3,627 customers received an Energy Grant. Clients receiving Energy Grants were located across all the SIMD quintiles but the majority of clients were within quintile 1 (35.8%) and quintile 2 (37.7%).

Through partnerships with programs like Home Energy Scotland and Warmer Homes Scotland, the Anti-Poverty Service has facilitated access to grants and funding for energy-saving measures. These financial supports directly reduce household energy costs, boosting the overall financial well-being of residents, especially those struggling with high fuel bills. On-going benefit and campaign support to raise awareness of financial support that looks at maximising incomes to help low-income residents secure benefits that they may be otherwise unaware of, directly increasing their income and reducing financial stress.

The Anti-Poverty Service refreshed the Tackling Poverty Strategy in 2023 to consider the changing landscape of poverty and increased living costs. By working with Community Planning Partners, the service has made advice available within communities, set up warm welcome locations, signposted customers on where to access food in their area as well as a website that supports people to manage costs. To ensure accessibility and to reach the communities that need it most, the service’s Advice Shop has developed services that are available in a variety of settings across West Lothian. Advice in accessible settings such as local community centres, libraries, and other accessible public spaces, makes it easier for people to receive support without having to travel far. There are also a number of regular drop-in sessions in various places across West Lothian for people to access advice. People are also able to access advice remotely through phone consultations and online services.

As part of its ongoing efforts to reduce financial hardship, the Anti-Poverty Service has rolled out the Family Fuel Grant to support families struggling with energy costs. The aim of the grant is to provide direct financial assistance to households that meet the Child Poverty Priority Groups who are struggling to manage their energy bills and paying more than 10% of their income on energy costs. The Family Fuel Grant is part of a broader strategy to ensure that families do not face the difficult choice between heating their homes and other essentials.

During Challenge Poverty Week 2024, the Anti-Poverty Service delivered pop-up advice sessions in high traffic areas like supermarkets and community hubs, offering on the spot guidance on issues such as debt, benefits, and energy savings. To further extend reach, the service enhanced its social media presence, sharing regular updates and information on financial support available. This combined approach of face-to-face engagement and online outreach helped raise awareness of poverty-related issues and made essential services more accessible to a wider audience.

Warm Welcome Locations have been set up across the West Lothian locality, to provide local people with a place to visit, socialise, access services and provide support. These areas are warm and welcoming. The Anti-Poverty Service and partners such as the Food Network will align pop-up sessions with Warm Welcome Locations to support advice sessions and increase general benefit take-up.

Collaborative work between the Anti-Poverty Service, Economic Development and the Improvement Service has led to the development of the Child Poverty Index (CPI) tool which has helped to inform decisions and make targeted interventions at a local level. The CPI was initially tested using Education benefit data to determine areas where uptake of benefits was higher or lower than expected. To make the tool as meaningful as possible, the aim is to consider other sources of data such as Housing Benefit or Council Tax Reduction Scheme data. The CPI simply provides an indicator of areas and potential issues meaning that it is important the information is used to inform a wider discussion and be given consideration when planning actions and interventions.

c) Reduce energy costs in your area

The Anti-Poverty Service has worked to raise awareness of financial support schemes, such as the Family Fuel Grant and Pension Credit, to help low-income households manage their energy costs. To create long-lasting, sustainable efforts to reduce energy costs, it is imperative that progress on improving energy efficiency of homes continues. Please refer to response 2(a) for some of the energy efficiency measures that West Lothian Council has already undertaken.

d) Support people to heat their home efficiently in your area (behaviour)

The Anti-Poverty Service have worked in partnership with Home Energy Scotland to facilitate referrals for residents needing advice and assistance with energy efficiency improvements. This collaboration helps households access grants for insulation, heating upgrades, and other energy-saving measures. Additionally, in its efforts to provide a holistic approach, the Anti-Poverty Service ensures households are aware of available benefits and facilitates discussions around energy efficiency in the home as well as sending customers an SMS with links to the web page and further relevant information.

To further promote energy efficiency, the Anti-Poverty Service has incorporated energy advice into Housing’s Dampness & Condensation Information Booklet, offering guidance to tenants on how to manage energy use and reduce heating costs. This includes tips on improving home insulation and reducing damp, which can increase energy consumption. Anti-Poverty staff members have received training through Energy Action Scotland’s “Stay Warm Stay Well” program, increasing awareness and knowledge about energy efficiency, fuel poverty, and available support services. This training ensures Council staff are better equipped to assist residents in making informed decisions about energy-saving improvements and accessing relevant support. In addition, through the Winter Campaign Planning Group, the Anti-Poverty Service is committed to delivering talks and training to local groups and organisations to provide fuel efficiency advice.

The Scottish Fire and Rescue Service have committed, through the Winter Campaign Planning Group, to deliver fire safety talks to community groups and provide risk recognition training to community partners to help improve fire safety within communities, increase risk recognition by partner agencies and encourage referrals for Home Fire Safety visits. In addition, they are running a Make the Call campaign which aims to reach those most at risk from fire within the home.

In your opinion, have actions undertaken by your local authority since 2021 (for example, Area Based Scheme delivery, published Local Heat and Energy Efficiency Strategy, published Local Housing Strategy) either helped to improve fuel poverty OR helped to alleviate the impacts of fuel poverty on people in your local area in Scotland? Why or why not? Please explain your answer.

Actions undertaken by West Lothian Council since 2021 have helped to improve fuel poverty and alleviate its impacts on local residents. Through Area-Based Schemes and LHEES, West Lothian Council has made progress in improving the energy efficiency of homes, particularly for low-income and fuel-poor households. The installation of insulation, heating system upgrades, and the development of Heat Network Zones all contribute to lowering energy consumption and reducing heating bills.

These improvements directly reduce the financial burden on households struggling with high energy costs, especially in areas with a high proportion of older homes or poorly insulated properties.

West Lothian Council’s energy strategies not only improve energy efficiency but also reduce the financial strain on families by helping them access additional financial support. The Anti-Poverty Service is a free, impartial and confidential service to help provide the people of West Lothian with financial support, help to tackle poverty and promote inclusion and equality through a range of services. The service works in conjunction with energy advice programs to ensure households receive energy related benefits as well as carrying out Benefit Health Checks to ensure individuals are accessing their full entitlement to other benefits. These supports help improve financial resilience, a core objective of the Tackling Poverty Strategy, by ensuring families can manage their energy costs without falling further into debt.

Both the Tackling Poverty Strategy and energy initiatives emphasise community engagement. Efforts to raise awareness about energy efficiency, financial assistance projects, and understanding the risks of fuel poverty help empower residents to make informed decisions about their energy use.

While these efforts have made significant progress in addressing fuel poverty, challenges remain. A significant limitation is the reliance on fossil fuels and the fact that energy policy is predominantly managed at a national level. West Lothian Council’s ability to influence energy pricing or policies such as standing charges – which disproportionately affect low-income households – remains constrained. While energy efficiency improvements can reduce energy consumption, they do not address the fundamental issue of affordability. The introduction of low-income tariffs, additional support for standing charges, or other cost-reduction measures at the national level would significantly benefit households in fuel poverty, as local efforts alone cannot overcome the broader issues of fuel poverty. To achieve sustainable reductions in fuel poverty, it is essential that these local efforts be supported by systemic changes at the national level, ensuring that energy is both affordable and accessible to all, regardless of income.

In your opinion have actions undertaken by your local authority since 2021 helped reduce the impact of the following driver on fuel poverty in Scotland?

a) Poor energy efficiency?

While increased awareness of energy efficiency through initiatives like improved insulation and energy-saving tips can help households manage their energy costs, it is not a complete solution to fuel poverty without broader support. West Lothian Council have taken significant steps, such as implementing Area-Based Schemes to upgrade insulation and heating systems, partnering with Home Energy Scotland for energy-saving advice, and through the Anti-Poverty Service providing financial support and referrals. These actions help to reduce energy consumption locally, but without addressing the root issue of high energy costs, particularly standing charges, fossil fuel reliance, and the need for affordable renewable energy, many low-income households will continue to struggle. National action is needed to lower energy prices, introduce low-income tariffs, and promote affordable renewable energy solutions to ensure long-term relief from fuel poverty.

b) High fuel prices?

By helping residents maximise their income and provide support with energy debts and supplier issues, the Anti-Poverty Service has alleviated some of the financial pressures caused by rising energy costs. This support includes assisting households with energy debts, negotiating with energy suppliers, and ensuring residents access benefits like the Warm Home Discount or Family Fuel Grant. However, despite these efforts, West Lothian Council has limited power to influence the root cause of high fuel prices, as energy companies remain nationally regulated. While local actions can provide essential relief, without broader national policy reforms addressing high fuel prices, the impact on fuel poverty will remain constrained.

c) Low Income?

Actions have been undertaken through income maximisation, access to fuel grants, and support with energy debt and other energy-related issues. The Anti-Poverty Service has been instrumental in ensuring residents are aware of and can access financial support, such as benefits and energy/fuel grants.

Additionally, the service has worked to help households manage and resolve energy debts and navigate issues with energy suppliers, which is crucial in alleviating the financial strain of rising energy costs. Furthermore, developing relationships with the Fuel Bank Foundation, has allowed for partnership working to assist in emergency cases where residents are at risk of being disconnected or struggling to maintain a supply. High energy costs, standing charges, and supplier practices continue to impact low-income households making it an ongoing challenge.

d) Inefficient use of heat in the home (household behaviour)

West Lothian Council has provided practical advice on energy-saving measures, such as improving insulation, reducing drafts, and using heating more efficiently. The Stay Warm Stay Well training for Anti-Poverty staff members has equipped them with the knowledge to provide tailored advice to households, ensuring that residents know how to minimise energy waste. Due to the ongoing energy crisis and capacity of the team, resource has been directed towards emergency cases such as securing fuel grants or assisting with Fuel Bank referrals for those facing immediate energy cut-offs, rather than on long-term behaviour changes or energy-saving education.

What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

Delivering effective solutions to tackle fuel poverty in West Lothian has been challenging due to several factors, both at the local and national level. One significant barrier is the energy supplier policies and practices, which often work against efforts to support vulnerable customers. Many suppliers are reluctant to accept third-party mandates, limiting the ability of the Anti-Poverty Services Energy Advice Team and advocacy services to act on behalf of customers who may struggle to communicate directly with their energy providers. This makes it more difficult to resolve issues such as debt management and disconnection risks. Additionally, some energy suppliers impose exit fees when customers attempt to switch to better deals or more affordable options, which compounds financial stress. The limited transparency of available tariffs also makes it harder for residents to identify the most affordable options, exacerbating fuel poverty.

Another challenge comes from the attitudes and training of supplier staff. There are instances where staff are unwilling to engage or lack understanding of the specific issues faced by low-income households. Many suppliers default to automatic debt recovery actions, often imposing debt recovery charges at rates as high as 70%, with little room for pro-rata debt repayments or tailored payment plans. This inflexibility prevents many residents from managing their debts in a way that is realistic and sustainable, often pushing them further into fuel poverty.

At the local level, the Energy Advice Team at the Anti-Poverty Service, has also faced challenges due to limited resources. Financial constraints on the local authority have meant that the Energy Advice Team cannot be expanded to meet the growing demand for support. The team is often stretched thin, focussing on emergency cases and immediate debt resolution, which leaves less capacity to work on long-term solutions like improving energy efficiency or providing behavioural advice on reducing energy consumption.

What further action do you feel is required from the Scottish Government for the purposes of reducing/mitigating fuel poverty for vulnerable households in Scotland?

To effectively reduce and mitigate fuel poverty for vulnerable households in Scotland, the Scottish Government must take a more pro-active and comprehensive approach, especially in the wake of the loss of the Home Heating Support Fund. One critical step is campaigning to reduce energy costs, particularly standing charges, which disproportionally affect low-income households. These charges remain a significant barrier to affordability, and reducing them would provide immediate relief to many residents struggling with high energy costs. Additionally, the Scottish Government should continue to advocate for a social energy tariff for those on the lowest incomes, ensuring that vulnerable households are not paying higher prices for their energy consumption. This could work alongside efforts to standardise eligibility criteria for programmes like the Warm Home Discount (WHD), ensuring consistency across all suppliers and making it easier for households to access vital support.

Further, exploring options for an automatic WHD payment, similar to the system in England and Wales, would simplify the process and ensure that eligible households do not miss out on crucial financial support. The current Broader Group set-up can be complex and inconsistently applied across suppliers, leading to confusion and potential gaps in support. The Broader Group criteria includes those who are in receipt of an income related benefit and either have a child under 5 years of age and/or receive an additional disability element in their benefit award. However, each supplier may also choose to extend their criteria and allow additional categories to be included for individuals to apply. A system based on low-income thresholds could ensure that those who need assistance the most receive it without additional hurdles. In addition, the Scottish Government should continue to support the growth of renewable energy sources, reducing Scotland’s reliance on fossil fuels and insulating the population from the volatility of global energy markets. Promoting renewable energy will not only support long-term sustainability but also help lower overall energy costs in the long run.

Lastly, increased financial support for energy advice agencies is vital. These organisations play a crucial role in maximising household income, navigating energy debt, and providing targeted advice to vulnerable households. With more resources, advice agencies can expand their capacity to meet growing demand, offering tailored, proactive support that helps households take control of their energy usage and finances.

By addressing these key areas – energy costs, social tariffs, renewables, and support for advice agencies – the Scottish Government can significantly mitigate fuel poverty and help ensure that vulnerable households are not left behind as energy costs continue to rise.