Response 569863629

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Legislative Context

1. Do you have any comments on this new definition of fuel poverty, in particular, what do you think about the proposal to use AHC and MIS as means to measure fuel poverty in Scotland?

a) What, if any, challenges do you think this approach could present in enabling targeting of resources to those most vulnerable to fuel poverty?
Keep Scotland Beautiful has no specific comments to make on this question.
b) If this definition is to be used, how would you propose these challenges are overcome?
Keep Scotland Beautiful has no specific comments to make on this question.

2. Do you have any views on the proposal of using 75 years of age as a threshold for identifying those who are likely to be vulnerable to the adverse health outcomes of fuel poverty?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

Recognising the distinctiveness of all our communities

3. In relation to island communities, are there any additional challenges; and/or opportunities that we need to consider in developing our strategy?

Challenges:
We believe that there are more significant challenges for island communities to access face-to-face advice and installation expertise as readily as on the mainland. In addition, any installation projects to assist with energy efficiency are likely to incur additional transport costs. This could exacerbate fuel poverty which communities already experience on islands.
Opportunities
We believe that there is an opportunity to prioritise local energy financial assistance, in particular renewable energy solutions, in island communities through schemes such as the CARES Loan which supports projects for communities and rural businesses in Scotland. We believe there is an opportunity to encourage community organisations to coordinate energy efficiency advice locally. This would ensure the accessibility of advice and facilitate a higher up take of energy efficiency measures.

4. In relation to rural and remote rural communities, are there any additional challenges; and/or opportunities that we need to consider in developing our strategy?

Challenges
We believe that rural and remote rural communities face similar challenges to the island communities, as outlined in our response to Q3a, when it comes to accessing face-to-face advice and installation expertise, due to the nature of their location. Any installation projects to assist with energy efficiency will incur additional transport. This could exacerbate fuel poverty which communities already experience.
Opportunities
We believe that there are similar opportunities present as in the ones we highlighted in Q3b.

Partnership working

5. Please give us your views on how national partners and local delivery organisations can work better together to identify and support those at risk of, or experiencing fuel poverty?

Please give us your views on how national partners and local delivery organisations can work better together to identify and support those at risk of, or experiencing fuel poverty?
Keep Scotland Beautiful manages the Climate Challenge Fund, on behalf of the Scottish Government, to provide grants and support for community-led organisations to tackle climate change through projects to reduce local carbon emissions. The Fund has supported many community-led organisations to support their communities to become more energy efficient. This has resulted in a network of skilled workers and people who would be able to assist national partners to tackle fuel poverty.
What would best support, or enable such partnerships?
The Climate Challenge Fund stakeholder working group; grant recipient working groups; and framework of mentor organisations have been set up to support collaboration, and provide good examples that could be replicated. Similar models of support groups or networks could be established to support local delivery organisations, although we recognise there is a need for them to be overseen by an ‘accountable’ body.

6. What can local partners do to contribute to meeting national aims of effectively and sustainably tackling fuel poverty?

This might include sharing best practice or developing strategic approaches.
We strongly support the Scottish Government’s aim to ensure that the equivalent of 50% of all Scotland’s heat, transport and electricity demand is met from renewable sources by 2030, and believe that a move towards clean, sustainable energy sources, away from the use of fossil fuels, is essential in order to meet Scotland’s climate change targets and those set out in the Paris Climate Change Agreement.
We welcomed the recognition, in the recent draft Energy Strategy consultation, that Scotland’s energy system must become less centralised, more flexible and more efficient. However, in order to effectively meet both fuel poverty and climate targets, we believe that further work is required on energy efficiency in domestic and non-domestic buildings. This includes, for example, ensuring that building regulations are reviewed to ensure that any new buildings are fitted with proven low carbon heat sources from the outset to avoid expensive and unnecessary retrofit. Local partners, such as Climate Challenge Fund recipients, could provide advice to other community groups on fuel poverty and how similar funding could assist groups to tackle this issue locally.

7. How can SG support local delivery partners (e.g. third sector organisations and social enterprises) to measure their success?

Comments:
The Scottish Government could provide a framework for local delivery partners to use to measure success against Fuel Poverty Strategy, and climate change, targets. This could take the form of current evaluation frameworks, which exist within Scottish Government contracts and grant agreements for funded work. However, it is advisable that these are not overly administrative as adding another layer of evaluation to some already resource-strained organisations will deter use.

8. How can the Scottish Government best support local or community level organisations to accurately measure; report on; and ensure quality of provision of advice and support services and their outcomes?

Measure:
All applicants to the Climate Challenge Fund are required to estimate how much CO2e their proposed project activities will save. To ensure consistency, applicants are provided with example calculations and the Department for Environment, Food & Rural Affairs (DEFRA) CO2e conversion factors. Successful grant recipients are also required to provide information on other aspects of projects, such as the number of people involved, number of volunteers, and how many home energy visits were carried out. This information is submitted in the form of a standardised data collection sheet.
It is important that the Scottish Government, in supporting organisations to accurately measure, does not increase the burden on communities as this will become a barrier to groups developing new activities. However, a standard measuring tool, similar to the one Climate Challenge Fund grant recipients use, would no doubt help ensure consistency of measuring and reporting.
As fuel poverty is embedded across other strategies, measurement tools could be added to existing frameworks and contracts, avoiding duplication.
Report on:
To date, the Climate Challenge Fund has supported 519 projects that have focused on energy efficiency. These projects aim to reduce carbon emissions from energy use by working with households in their community to reduce energy use. Projects can help households install energy efficiency measures, promote locally sourced wood fuel, promote home renewable technologies and reduce energy consumption through behaviour change.
CCF has supported 151 projects to carry out energy efficient refurbishments of community-owned buildings, reducing energy consumption and carbon emissions.
Ensure quality of:
The Climate Challenge Fund’s Capacity Building Programme (CBP) develops the capacity of communities wishing to tackle climate change and contributes towards creating a body of grassroots community organisations engaged in climate action. CBP is provided by Keep Scotland Beautiful through its management and development of the Climate Challenge Fund on behalf of the Scottish Government.
We believe that appropriate training, tailored support and online resources will help communities to understand, measure and report on fuel poverty and interventions designed to tackle it.

9. How can the one-stop-shop approach be enhanced for the benefit of HES clients?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.
In particular, are there any improvements that you think can be made to the HES service to further enable it to best reach the most vulnerable to fuel poverty client groups?
We believe that the HES service could continue to improve its alignment with local community led action on fuel poverty, energy efficiency and climate change to improve its reach to the most vulnerable to fuel poverty.

Targets and indicators

10. What are your views on our proposal to set a new statutory target to eradicate fuel poverty in the Warm Homes Bill?

Comments:
We applaud the ambition of a target to eradicate fuel poverty completely, as set out in the Warm Homes Bill. However, we acknowledge that in order to meet any ambitious fuel poverty and climate change targets that are needed to address this issue there needs to be realistic timescales and clearly identified budgets, particularly when fuel costs are continuing to rise.
As highlighted in our response to Q6 we believe that Scotland’s energy system must become less centralised, more flexible and more efficient and that further work is required on energy efficiency in domestic and non-domestic buildings.

11. What are your views on the proposed sub-targets?

a) What are your views on the proposed levels?
Keep Scotland Beautiful has no specific comments to make on this question.
b) What are your views on the proposed timeframe?
Keep Scotland Beautiful has no specific comments to make on this question.

12. What are your views on the proposed interim milestones?

a) What are your views on the proposed levels?
Keep Scotland Beautiful has no specific comments to make on this question.
12 b) What are your views on the proposed timeframe?
Keep Scotland Beautiful has no specific comments to make on this question.

Monitoring, evaluation and reporting

13. How should the new Fuel Poverty Advisory Panel and Fuel Poverty Partnership Forum monitor progress towards meeting the proposed sub-targets and interim milestones?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

14. What do you think the Advisory Panel’s priorities should be in its first year?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

15. What examples do you have of using proxies to identify fuel poor households?

a) Which proxies did you use?
Keep Scotland Beautiful has no specific comments to make on this question.
b) Based on your experience, how well did these proxies work in accurately identifying fuel poor households?
Keep Scotland Beautiful has no specific comments to make on this question.

16. What are the key lessons to be learnt from any existing approaches that apply proxies in door-to-door, on-the-ground assessments in this context?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

17. Do you have any concerns about the use of a doorstep tool, in particular the challenges around delivery of area based schemes?

Comments
Keep Scotland Beautiful has no specific comments to make on this question.

18. How can the Scottish Government most effectively work with Community Planning Partnerships in a collaborative manner to report on overall fuel poverty levels as part of the SHCS?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

Outcomes and Principles

19. What are your views on, or experience of how an outcomes-focused approach would work in practice?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.
a) Would it encourage national and local policy and delivery partners to work together effectively, and if not, what alternative approach(es) do you propose could be used instead?
Keep Scotland Beautiful has no specific comments to make on this question.

20. Do you think the principles detailed in the 3 bullet points above are adequately reflected in the outcomes framework?

Comments:
Keep Scotland Beautiful has no specific comments to make on this question.

Assessing impacts

23. What implications (including potential costs) will there be for business and public sector delivery organisations from these proposals?

Comments:
We believe that there could be an increased burden on businesses and public sector delivery organisations from the proposals, due to the additional reporting, evaluating and scrutiny requirements, as detailed in the consultation which will undoubtedly result in additional time and cost.

About You

What is your name?

Name
Catherine Gee

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Organisation
Keep Scotland Beautiful