Tackling Fuel Poverty in Scotland: periodic report 2021-2024

Engagement Responses: Headline Summary

Section 10(1)(2) of the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 sets out the statutory requirement to consult on the Fuel Poverty periodic report. The 2019 Act requires a periodic report for the three year period from the publication of the Tackling fuel poverty in Scotland: a strategic approach, from 23 December 2021 to 22 December 2024. Due to limited time available, a targeted engagement exercise was undertaken with stakeholders.

Table 1 shows the engagement requirements within the 2019 Act, with the sample of organisations who were chosen to represent those with lived experience noted below, aligned to the protected characteristics outlined in the 2019 Act. A selection of community councils across Scotland were chosen to gain a deeper understanding of impacts on communities living in different areas of Scotland, particularly in rural areas.

Table 1 – Fuel Poverty Act requirements on persons to be consulted

Section 10 – Consultation on Periodic Report

10(1) In preparing a report under section 9, the Scottish Ministers must consult such persons as they consider appropriate

10(2) The persons consulted under subsection (1) must include:

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

(b) local authorities,

(c) disabled people,

(d) people with long-term illness,

(e) older people,

(f) individuals living in rural areas, and

(g) the Scottish Fuel Poverty Advisory Panel.

In alignment with the requirements in Table 1, the following were invited to consult:

• All 32 local authorities
• Sample of 8 community Councils
• Age Scotland
• Energy Action Scotland
• Energy Savings Trust
• Minority Ethnic Carers of Older People Project (MECOPP)
• Tenants Together Scotland
• Wise Group
• Scottish Fuel Poverty Advisory Panel

All 32 local authorities in Scotland were invited to respond. In addition to their requirement in Table 1, the questions posed to local authorities sought to capture the requirements in section 9 of the 2019 Act, as noted in Table 2.

Table 2 - Requirements to report on local authority progress towards meeting 2040 Fuel Poverty targets

Section 9 - Preparation of periodic reports

9(2) 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,

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

(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.

The Acting Minister for Climate Action wrote to those noted under Table 1 on 27 September 2024 with a request for responses by 8 November 2024. This deadline was extended to 22 November to enable sufficient time to respond. Three responses received after the 22 November deadline were also included in the analysis, meaning all responses were analysed for this report.

A total of 41 responses were received: 23 local authorities; 9 community councils - however, these were from community councils in similar local authorities - Shetland (3), Scottish Borders (1) and Highland (5); 8 organisations - this included two that were not contacted directly by the Minister but sent responses due to their membership with Energy Action Scotland; and the Scottish Fuel Poverty Advisory Panel.

Engagement Questions

The engagement asked five or six open questions to each organisation, as set out below. Questions were adapted to allow groups with insights into the experiences of those with specific protected characteristics to give their perspectives. The 2019 Act requires local authorities to report on their actions taken towards the fuel poverty targets and tackling the drivers of fuel poverty. Organisations and community councils were asked to report on Scottish Government actions taken and their impact on reducing fuel poverty and progress towards the 2040 targets, therefore questions were adapted to meet the requirements.

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

This question was adapted to ask about certain demographics depending on the contact (people with long term illness, disabled people, individuals with protected characteristics, people living in fuel poverty, people living in rural areas, older people, local area - for local authorities).

2.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:

This question was adapted to ask for certain demographics depending on the contact (people with long term illness, disabled people, individuals with protected characteristics, people living in fuel poverty, people living in rural areas, older people, vulnerable households, local area - for local authorities).

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.

3. 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?:

d) Poor energy efficiency?

d) High fuel prices?

d) 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.

4. 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?

5. 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.

Questions posed to local authorities differed slightly to capture their actions taken during the reporting period as below:

1. 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)

2. 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.

3. 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 behavior)?

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

Thematic Analysis Approach

A thematic analysis of responses was undertaken by a member of the Scottish Government’s Fuel Poverty Policy Team, with support and quality assurance from Scottish Government Analysts. Responses were coded to identify themes and subthemes, and peer review of the coding framework and a selection of responses was carried out to ensure the approach was consistent and accurately captured the content. A summary of the range of responses is presented below in the summary analysis section, grouped into identified themes and subthemes for each question.

Table 3 sets out the terms used to describe the number of respondents making the points that were identified in the thematic analysis. Quotations from responses are in double inverted commas within the body of the analysis text.

Table 3– Analysis Descriptives

Term	Description
All	everyone participating in the engagement made this point
Most	more than half of participants (21+)
Some	less than half but more than 6 (6-20)
A few	three to six participants
A couple	two respondents
One	just one respondent

Summary Analysis

Questions were worded to capture information under the four main areas below. The analysis captured themes under these questions in relation to the four drivers of fuel poverty and have been grouped as such in reporting of the analysis.

1) Barriers and challenges faced by people in being able to heat their homes according to their needs.

Poor energy efficiency of the home

Some respondents noted that a dwelling’s age, size and fabric contribute to its energy efficiency. Particular challenges raised by respondents included poorly insulated homes and homes in disrepair which require “costly, deep retrofit renovation”; weather-related damage and greater heating demand required for rural communities due to cold weather conditions; and the willingness and financial ability of households to undertake measures. For example, one local authority commented that there can be “perceptions that the cost of energy efficiency retrofit is too high or uncertainty over which measures provide the best value for investment”. Other challenges mentioned included the tenure of a building, with several local authorities noting barriers in the private rented sector and in mixed tenure blocks; the incompatibility of measures such as clean heating systems in a property; and the perceived “lack” of funding and eligibility for funding being too “stringent” when accessing energy efficiency schemes.

Two local authorities highlighted that if done incorrectly and without correct consideration of insulation and ventilation, energy efficiency measures could potentially have unintended consequences for buildings such as causing damp and increased condensation. Respondents added that there could also be unintended consequences of pushing people into, or further into, fuel poverty, due to clean heating systems which rely on electricity, which is currently more expensive than gas, potentially leading to higher energy costs. This was also raised in the section on high energy prices.

Contractors and material supply chains

In addition to cost, a few respondents commented on a lack of available contractors to carry out required work. Some local authorities noted the additional challenges faced by island communities including higher costs for materials, limited supply chains, aging ferry fleet with limited access to the islands, which are also subject to delays due to weather, which can result in a shortage of skilled labour and materials to carry out the work required.

Low Household Income

As highlighted above, respondents identified that households living in fuel poverty are unlikely to be able to afford the installation of energy efficiency measures without support. The Scottish Fuel Poverty Advisory Panel also noted “in spite of mitigating poor energy efficiency as a driver of fuel poverty, the low-income driver is still keeping some people in fuel poverty.”

Some local authorities noted incomes have not kept pace with the energy costs, and combined with the cost-of-living crisis, have had a negative impact on people’s disposable income. Respondents identified households who they believed were more likely to have lower incomes, such as: older households who may have a lower set income; disabled households and household members with long-term illness who may reside in an older home due to accessibility limitations and may be unable to work; and households in rural and island areas where incomes can be lower, alongside other essential costs of living being higher.

A few local authorities also noted high level of demand for crisis support, predominantly from those on low incomes, and others commented on the challenge of poor financial resilience being faced by many low-income households.

High Energy Prices

Most respondents noted the increase in fuel prices over the past three years as the main barrier for people being able to heat their homes.

A few respondents highlighted the negative impact this can have on people’s health and wellbeing, commenting on the higher energy bills that disabled people and people living with long-term health conditions can face, where their expenditure is not optional. For example, requiring electricity to operate assistive or life-sustaining equipment and to keep medication at a safe temperature. This can therefore have a serious impact upon their health and wellbeing if unable to afford their energy costs.

Some noted the lack of fuel choice available for high numbers of households off the gas grid, which they feel has had a “disproportionate impact” on those in rural areas using oil and electricity, which cost more than gas. In addition, those using fuel such as wood/coal/oil have to purchase in large amounts with upfront costs.

A few local authorities noted the lack of incentive for households to implement energy efficient heating systems due to electricity currently being a more expensive heating source. The Scottish Fuel Poverty Advisory Panel also noted in their response that implementing clean heating systems could have the potential to deepen fuel poverty due to the price of electricity currently being four times the cost of gas, suggesting that energy market reform or dedicated support to protect those in fuel poverty would be required to offset this potential unintended consequence.

A few respondents raised the challenges faced by those on prepayment meters who are unable to spread costs over the year. Another local authority noted the “disproportionate standing charge costs for low energy use households,” referring to the challenge faced by consumers trying to reduce costs, whereby standing charges are still accrued when using low or no amounts of energy.

Energy Debt

Some respondents noted rising consumer energy debt due to the increase in fuel prices and cost of living crisis, which can become a barrier to heating homes according to need.

How energy is used in the home

Low-income, high-energy prices, and poor energy efficiency of the home were all referenced in connection to household behaviours on energy use.

Some local authorities noted changes in behaviour may include heating less rooms of the home, fuel rationing, self-disconnecting and choosing between fuel and other essentials, including food. Other coping strategies referenced by the Scottish Fuel Poverty Advisory Panel included rarely eating hot food, having to wear double layers of clothing and only heating rooms at set times.

Advice and knowledge

Some also mentioned people’s general lack of knowledge in how to use their heating systems to achieve best efficiency. This is also the case for some who have had energy efficiency installations, who still lack knowledge on how to use their new heating system. In addition, households may lack an understanding of the energy market, how to move energy suppliers and how to choose energy tariffs.

Some respondents highlighted that, whilst funding is available, households have a lack of awareness of funding available to them, with some finding it difficult to find or access help. Digital exclusion may be a barrier for some seeing help, as is language a barrier for those who do not speak English, or do not speak it as their first language.

Energy Savings Trust, in relation to their Home Energy Scotland advice service, also highlighted that even when advice is given, it may not be put into practice for various reasons. For example, mental health and “mental busy-ness" can potentially impact an individual’s capacity to act on or retain information.

Similarly, the Scottish Fuel Poverty Advisory Panel noted “supplier behaviours can affect consumers use of energy both positively and negatively. A positive is in offering breathing spaces to customers struggling with debt and having dedicated lines for advice services. However, there are also examples of ‘unresponsiveness’ and heavy handedness by energy companies”. One organisation reported that “new tariffs are inaccessible where there is no smart meter signal.”

Energy Action Scotland (EAS) noted that energy companies are frequently re-directing struggling customers to energy advice services, adding to the workload of support organisations. In addition, EAS reported that “energy company call centre staff often won’t accept mandates from housing providers to speak on behalf of their clients” and do not always consider those who do not have access to the internet when directing to online support.

2) Opinions on SG Actions taken since 2021 and the impact of those actions on tackling fuel poverty.

Community Councils and organisations were asked for their views on the actions taken by the Scottish Government since 2021 and if those actions have either helped to improve fuel poverty or helped to alleviate the impacts of fuel poverty for certain protected characteristics, towards tackling the four drivers of fuel poverty. As seen in the separate section below, local authorities were alternatively asked to report on the successes and limitations of their own actions during the same period.

Some responses noted the focus and progress made by the Scottish Government in improving the energy efficiency of Scottish homes, as an area within devolved powers; the support available through Social Security benefits to help raise household income, and; the continued engagement with the UK Government on energy markets. Although there was also recognition that more work is required to tackle fuel poverty and the importance of measuring and evidencing the impact of policies.

Poor energy efficiency of the home

Some respondents commented that Scottish Government energy efficiency delivery programmes – Warmer Homes Scotland (WHS) and Area Based Schemes (ABS) - are effective in helping to reduce heating costs and positively impacting the lived experience of having a warmer home. In particular, organisations commented that ABS has benefited neighbourhoods across Scotland, with success attributed by two organisations as to the longevity of the scheme and delivery via local authorities, who are informed by local knowledge on where best to target support and build trust with consumers. A couple of organisations reflected on WHS as “a highly successful programme” and is used alongside ABS projects in some areas to “augment ABS projects, expanding the reach of the programmes and creating economies of scale.” Two organisations viewed the change to WHS eligibility criteria for 2023/24 positively as this helped to capture households experiencing fuel poverty who are not in receipt of passport benefits and on the margins of eligibility previously.

One organisation noted “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”. This aligns with respondents calling for multi-year funding for ABS which they believe would enable stability in the supply chain and associated scaling up of the programme as well as increasing skills.

The benefits of energy-saving measures were recognised, with the Wise Group noting that “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”.

However, some community councils stated they have seen no or little energy efficiency improvement installations in local communities, and not at a significant scale. The Scottish Fuel Poverty Advisory Panel recognised the Scottish Government’s energy efficiency ambitions through the Heat in Buildings Strategy, the improvements between 2019 and 2022 in the Scottish housing stock reaching EPC C, and the progress made around the legislative framework for improving energy efficiency, such as the introduction of The Local Heat and Energy Efficiency Strategies (Scotland) Order. However, the Panel commented that despite significant Government expenditure, the progress to increase energy efficiency is not moving quickly enough, nor can improving energy efficiency tackle fuel poverty alone.

Low Household Income

A few respondents noted the support available to low-income households, particularly the benefits delivered by Social Security Scotland. One organisation commented upon the Winter Heating Payment as a reliable source of support and the Scottish Fuel Poverty Advisory Panel commented that “it is clear from the evaluation of the Child Winter Heating Payment that it is playing a valuable role and is providing vital support in supporting vulnerable households, some of whom are likely to be in fuel poverty or at risk of experiencing fuel poverty.”

Other support measures, outside of Winter Heating Benefits, were also referenced by the Scottish Fuel Poverty Advisory Panel. This included the Scottish Child Payment, free school meals, free bus passes, council tax reductions, and Discretionary Housing Payments – all of which are included in the Fuel Poverty Strategy – which the Panel note will “have been helping households living in fuel and extreme fuel poverty through increasing income.” The Fuel Insecurity Fund (winter 2020 – March 2024) was also mentioned as a crisis support mechanism, as well as the Scottish Welfare Fund, however the Panel noted the Scottish Welfare Fund’s increase in demand and the pressure to “extend beyond the original definition of crisis”.

The need to better target measures to align with household circumstances was referenced by a couple of respondents. Comments on the need to understand the impact of policies on helping to alleviate fuel poverty were also raised.

High Energy Prices

Respondents commented that overall inflation and the increase in energy prices has had a negative impact on fuel poverty and people’s circumstances, with one organisation suggesting that the impact of high energy prices has “blunted the impact” of Scottish Government schemes. Minority Ethnic Carers of Older People Project (MECOPP) commented upon high energy prices experienced by those using gas cylinders for their heating, such as gypsy / travellers – which was not subject to the Ofgem energy price cap.

The policy levers over energy prices are reserved to the UK Government. However, the Scottish Fuel Poverty Advisory Panel noted that the Scottish Government are “actively advocating for reform to energy support for low income and vulnerable households”, such as for a social tariff mechanism. This was also recognised by Energy Action Scotland. Additionally, Energy Savings Trust, funded by the Scottish Government, reflected upon their role in referring households to energy crisis support and supporting people to switch to the best energy tariff.

How energy is used in the home

There were limited comments on this driver of fuel poverty. Of the responses provided, the importance and value of advice services and third sector organisations was reflected upon, as they were seen as a main channel for household support and influencing how energy is used in the home. One Community Council noted the introduction of smart meters has helped households to make more efficient use of energy to heat homes.

3) What actions has your local authority undertaken since December 2021? Have those actions helped improve fuel poverty or helped to alleviate the impacts of fuel poverty on people in your local area? What, if anything, has made delivery towards tackling fuel poverty challenging in your local area?

These questions were posed to local authorities only, and therefore the responses in this section do not include any comments from any third sector organisation or community council.

Improving energy efficiency in local areas

Strategies and plans

Most local authorities reported tackling energy efficiency as a priority action to reduce fuel poverty in their area, with local strategy and delivery plans aligned to support this objective.

Some local authorities reflected upon their own projects and plans which have a focus on climate change and net zero, with examples provided including commissioning net zero research, focusing on net zero homes, and through a Carbon Neutral Islands project. However, most local authorities mentioned their Local Heat and Energy Efficiency Strategies (LHEES) which provide a focus on where to prioritise efforts, identify costs required to decarbonise heat and reduce emissions, improve energy efficiency and energy ratings, alongside helping to tackle fuel poverty. A couple of local authorities commented on the importance of ensuring a just transition to net zero, which is affordable for households. A few also noted a focus within their LHEES to accelerate the deployment of district-scale heat networks to reduce heating-based emissions and tackle fuel poverty.

A few local authorities referred to the Energy Efficiency Standard for Social Housing 2 (EESSH2) and their work to improve their housing stock to meet the standard. However, challenges raised by respondents included obtaining the funding required to meet the energy efficiency standard, whilst also ensuring these costs are not passed onto tenants, keeping rents affordable; the shift between EESSH1 and 2, and; awaiting guidance on a Social Housing Net Zero Standard which will replace EESSH2.

Furthermore, some local authorities mentioned their Local Housing Strategies, which include priority actions around improving energy efficiency of homes to minimise fuel poverty. As part of this, local authorities noted using the Scottish Government’s Area Based Schemes (ABS).

Area Based Schemes (ABS)

Most local authorities reported using the Scottish Government funded Area Based Schemes (ABS) - obtaining funding to deliver energy efficiency measures. Measures listed by respondents included solid wall and internal wall insulations, heat pumps, installation of Solar PV, loft and/or underfloor insulation, ventilation, and heating system upgrades. Local authorities reported these measures have helped thousands of homes to be warmer, more energy efficient, and with an increased Energy Performance Certificate (EPC) rating.

Local authorities vary in how they target homes for improvements, but most commented on targeting towards those in fuel poverty, towards the most deprived parts of their council areas, with some using SIMD (Scottish Index of Multiple Deprivation) rankings, low EPC rating or council tax bands, and hard to treat properties.

The main criticism reported by local authorities on the ABS programme is the single year grant funding - the impact this has on delivery timescales, with a few also noting budget underspends. Funding for the ABS programme is confirmed annually in the Budget but many ABS retrofit projects are technically complex and cannot be designed, commissioned and completed in a single Financial Year. Some stakeholders have proposed that the Scottish Government publish indicative resourcing assumptions over several years to provide greater certainty about investment in these projects for installers, property owners and local delivery partners.

In addition, a few local authorities noted that with more houses being insulated over time, it can be challenging and more time consuming to identify homes that are eligible for ABS. One local authority noted a challenge to get people sign up to the scheme, due to a lack of consumer confidence and concerns around being scammed as a result of a perceived rise in scams around home improvements and energy efficiency, as well as some households being more comfortable relying on fossil fuels.

Although not a Scottish Government scheme, local authorities also mentioned the Energy Company Obligation (ECO) through which they have received funding to help deliver “whole house” retrofit measures. It was also noted by one local authority that the changes to funding rules by the Department for Energy Security & Net Zero, like the prevention of blending funding between ECO4 and any other public funding such as ABS, has prevented delivery.

Challenges in delivering energy efficiency improvements

Various challenges in delivering energy efficiency improvements were reflected upon by local authorities, with themes emerging across Government policies and funding, cost of materials and access to contractors, tenure of buildings, and data. Challenges relating to the ABS programme are noted in the proceeding section.

A few local authorities noted the challenge of implementing a combination of interacting government policies against a challenging economic context, and alongside a housing emergency. A few sought greater clarity from Government in delivering energy efficiency improvements – for example, understanding best practice.

Furthermore, some respondents noted the challenge in tackling fuel poverty alongside climate change ambitions, reflecting upon high electricity prices as a barrier to affordable heating, especially if a property is not thermally efficient. A couple of local authorities noted a skills shortage and lack of access to contractors, with one respondent commenting that the skills and materials required for listed and historic buildings cost significantly more, aligned to responses in question 1.

Comments also noted additional challenges faced by rural communities, where costs can be higher and homes more dispersed, with one local authority highlighting the importance of Government ensuring policies are island proofed. A couple of respondents commented upon the higher costs of delivery in rural communities, with high inflation remaining a challenge. Respondents also highlighted a perceived lack of local contractors in general, but was a particular challenge in rural areas due to accommodation and disrupted or more costly travel.

As also highlighted in earlier sections, respondents noted the challenge of working across mixed tenures. A couple of local authorities commented on issues with funding eligibility for private sector landlords, whereby in some instances landlords are required to contribute towards the delivery of measures – which they may not be able or willing to do. One local authority stated, “mortgage rate increases and changes in taxation have been cited by private landlords as directly impacting on their ability to fund improvements in properties”. Another commented upon the risk of costs subsequently being passed onto tenants via potentially increased rent.

A few respondents noted the difficulty in identifying homes in fuel poverty to target measures and understand the extent of the issue, noting that a low EPC rating does not necessarily equate to a household living in fuel poverty. Being unable to share data due to GDPR was also raised.

A few also raised that the Scottish House Condition Survey, National Statistics which include estimated fuel poverty rates, has not been updated at local authority level since the 2017-2019 data, with the next 3-year average results not available until 2026.

Increasing local incomes

Most local authorities felt that higher fuel prices are likely resulting in households spending more on fuel, noting particular challenge for those on low incomes to meet these costs, with a few local authorities reporting more people are presenting with requests for help with energy (and overall) debt. In addition, local authorities noted general cost of living increases, resulting in many households struggling to adequately heat their home.

Most local authorities reported various local projects that are helping households with income maximisation. This includes some local authorities who have created their own advice service, fund third sector advice services, or have good referral relationships with third sector organisations, including referring customers for benefit checks and advice on welfare rights. Some local authorities also noted establishing foodbanks/food poverty referral gateways, advice on energy efficiency, and developing good referral pathways between those receiving benefits and their eligibility for energy efficiency funding.

Local authorities also discussed providing crisis payments to those in fuel poverty via various cost of living grant schemes - such as the Scottish Welfare Fund and Island Cost Crisis Emergency Fund.

Reducing energy costs in local areas

Some local authorities noted that high energy prices are a significant challenge and can be a barrier to households being able to afford a low carbon heating system, due to the higher costs of electricity. As previously mentioned, additional challenges faced by island and rural communities were raised, such as limited energy tariffs and fuel options.

Local authorities have no control over energy prices, and have therefore provided support via energy efficiency improvements, working in collaboration with organisations to signpost communities to energy advice services, and administering crisis funds – such as those referenced above.

Supporting people to heat their homes efficiently in local areas (behavior)

A few local authorities reflected that some people are unaware of the support available to them, how to access it, or lacked knowledge of their eligibility to access support to implement energy efficient improvements.

Steps taken by local authorities to help with energy behavior include promoting energy advice and advocacy services, with some doing so via referral pathways with Home Energy Scotland and their local Citizens Advice Bureau. In addition, some noted they have set up their own advice teams or are funding advice organisations. Some mentioned hosting events to raise awareness of support available, and promoting their own online support services, including keeping council web pages up to date with available support, using social media and creating advice leaflets. A few also mentioned making home visits to support vulnerable customers and regular staff training on understanding fuel poverty and how to signpost to relevant support.

4) 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?

This question was posed to all respondents. Most responses focused primarily on suggestions around poor energy efficiency and high energy prices as drivers of fuel poverty, with comments including increasing the scale and funding for Scottish Government energy efficiency delivery programmes, and the necessity for energy market reform to lower prices for consumers.

Some comments were made regarding fuel poverty data and the need to improve data collation and sharing systems to identify and target those most in need – with reference to the limitations of the Scottish House Condition Survey not having recent local authority data with the most recent data being for 2017-2019, with refreshed data due to be published until 2026. A couple of respondents noted the need to consider and target the needs of vulnerable households as part of a future Strategy or Strategy revision, and to reflect the evolving landscape.

Poor Energy Efficiency of the Home

Alignment, eligibility and funding of policy initiatives

A few respondents noted the necessity for policy alignment and clarity to support local delivery, including between housing and energy, with some referencing the importance and opportunity of a Heat in Buildings Bill, Social Housing Net Zero Standard and energy efficiency standards to support fuel poverty ambitions. Two local authorities noted a benefit to implementing the Passivhaus standard as a method to ensure new homes are built to the highest possible standard, improving fuel poverty outcomes. The Scottish Fuel Poverty Advisory Panel highlighted the need for fuel poverty to be at the forefront and aligned across government policies and “cross government governance”, noting the interplay between fuel poverty and wider policies, including child poverty and net zero ambitions.

Most commented on the significant funding that will need to be provided, both in terms of installation and running costs, to remove poor energy efficiency as a driver of fuel poverty, as current funding models were not seen as sufficient to implement at the pace required to help those in fuel poverty.

Most respondents suggested increasing the scale of energy efficiency programmes Area Based Schemes (ABS) and Warmer Homes Scotland (WHS) as, although viewed as effective, the scale was deemed insufficient to meet demand. To enable most effective delivery, comments suggested “early visibility” of multi-year funding for ABS to allow “strategic planning”, increased funding for WHS and adapting the scheme to support retrofit installations. A further suggestion was an increase in funding for the Affordable Housing Supply Programme.

Some also commented on the need to maximise Energy Company Obligation (ECO) and Great British Insulation Scheme (GBIS) funding spent in Scotland, such as by working with the UK Government and Ofgem, and engaging with energy suppliers and third sector organisations to maximise the reach and effective use of funding.

Meeting the challenges related to mixed tenures and rural homes were mentioned, with suggestions including a longer timeline for consultation and engagement for mixed tenure blocks, funding to test alternative approaches to decarbonisation in rural areas, and the overall importance of supporting vulnerable households.

Low Household Income

Only a few respondents made recommendations directly about tackling low household income. These came mostly from third sector organisations and were varied.

Social Security

Winter heating benefits – the Winter Heating Payment, Child Winter Heating Payment, and Pension Age Winter Heating Payment – were referenced. One suggestion was increasing the Winter Heating Payment from £58.75 to £100 as this would benefit eligible households who have a disabled adult and/or child due to the automatic allocation of the payment, and a further suggestion on a cold area premium to support those living in some of the coldest parts of Scotland, namely rural areas where households are subject to more extreme winter weather. Separately, one respondent, whilst noting the welcome support of the Child Winter Heating Payment, commented that the additional funds “do not go far enough to support those households with the additional costs associated with disability and the energy consumption requirements within that.” There were varying perspectives on the Pension Age Winter Heating Payment - including a suggestion to keep the payment universal, and other views on reviewing the eligibility criteria to better support those most in need, and for additional targeted support for fuel poor households.

A few respondents raised the overall challenge to encourage take-up of social security benefits, particularly pension credit, due to what they described as an overall lack of entitlement awareness and complicated application processes. One suggestion was to raise the awareness of benefits and provide money advice in school and health settings, including schools for those with additional support needs. However, the benefit of universal support was mentioned by another respondent as a way for people to avoid navigating systems.

One respondent suggested support for social landlords “as they are best placed to know those tenants who are in fuel poverty” to enable them to provide winter payments directly to support those in fuel poverty; to work with energy companies to support tenants; to identify homes that could be targeted for energy efficiency improvements; and to implement income maximisation services (which was noted as already being done by some social landlords).

High Energy Prices

Reform

Most comments related to the price of energy being a main driver of fuel poverty, which is reserved, and the need for energy reform of some sort. This included calls for reform around standing charges, the need for a social tariff mechanism and decoupling electricity and gas prices – particularly noting the consequences of moving to a clean heating system which could potentially result in higher running costs for electricity, and for those not connected to mains gas already restricted to more expensive types of fuel. Other comments included the need for the Scottish Government to work with UK Government and Ofgem to lower energy prices, and the role of energy companies in working with local authorities, third sector organisations and government to support those struggling with fuel costs.

A few respondents mentioned the “limited effectiveness” of the Ofgem Energy Price Cap for those who do not fall into the category of “Average UK Home” in terms of their energy use. Particular mention was made to those who live on islands and in rural areas, as the Price Cap does not cover unregulated fuels used widely in these areas.

Specific challenges and barriers for some cohorts were identified, including the costs for those using medical equipment at home, and the risk for those with Radio Teleswitch meters if they are not replaced in advance of the switch off date.

Some respondents also noted the need for communities to benefit from the energy that is produced on their doorstep, with one local authority commenting “in an area which is delivering increased levels of renewable energy, it is paradoxical that residents are experiencing higher energy costs and higher living costs.”

In addition, the Scottish Fuel Poverty Advisory Panel noted the need for the Scottish Government to influence the UK Government to “improve the Warm Homes Discount (WHD) offering in Scotland”, particularly on addressing the data matching issues and automatic eligibility.

Crisis Funding and Energy Debt

Some noted the importance of crisis funding alongside longer-term measures to help those in fuel poverty, and the importance to “ensure that people’s health and wellbeing is protected”, with the Scottish Fuel Poverty Advisory Panel noting the importance of crisis support being used towards energy costs. A few respondents noted the rising energy debt faced by customers which is keeping them in fuel poverty and the need for advice services to be supported/funded for them to maintain advice services for all energy consumers.

How energy is used in the home

Advice Services

As reported above, barriers and challenges faced by energy consumers interlink across the four drivers of fuel poverty, influencing how energy is used in the home. Most respondents noted the key role of advice services in how consumers use their energy and have asked for advice services to be streamlined. The Scottish Fuel Advisory Panel recommends a “structural review of the design of energy advice services.” This is in respect of the increase in demand for advice and the funding model needed to meet the demand. In particular, noting the annual funding cycle which “erodes efficiency of advice agencies through staff retention issues...as well as the constant need to divert resource to bidding for the next funding round/grant” and the importance of having a structure enabling access to “holistic, trusted advice”.

There were varying views on the optimal approach to take in improving the targeting of advice. Respondents requested “streamlined” support, others recommended various “accessible channels” that might be used to engage with difficult to reach consumers, such as more support for those who are digitally excluded. A few respondents recommended home visits as a good approach and widening engagement to venues where people experiencing fuel poverty may frequently attend, including community centres and places of worship.