Response 272953478

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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?
The Scottish Islands Federation (SIF) welcomes a refreshed Government strategy to tackle social injustices associated with fuel poverty. We also recognise the case for a new definition of the problem and appreciate the opportunity to contribute our perspectives. Our first impression is that the new definition proposed is less readily intelligible, and it is difficult to fully understand what it will mean in practice or how it will help to engage people. This will be an issue if it is to be used to decide how resources and funding will be targeted. We are concerned that the new definition may omit categories of households in rural areas and islands in particular, where high fuel costs limit the quality of life of people who might not be considered fuel poor under the new definition. SIF's main concern with the new definition is thus its potentially negative impact on individual islanders, island households, islands and rural communities in general: AHC: In principle, we agree with the use of AHC but would call for further clarity on what is excluded and included and an appraisal of impacts. For example, the consultation document does not specify exactly which ‘housing’ costs will be included within the definition and so impacts on households which may have lower housing costs (no mortgage) but still have high fuel costs are not clear. SIF points out that island and rural communities typically have a higher cost of living and also spend a higher percentage of their income on fuel. MIS: The use of MIS based on a UK- wide MIS appears to disregard the specific challenges faced by island and rural communities. The 2013 report and subsequent update in 2016 - ‘A Minimum Income Standard for Remote Rural Scotland’ – shows clearly that the budgets required by households to achieve a minimum acceptable standard of living in remote rural Scotland were typically 10 to 35% more than the rest of the UK and 25 to 40% higher in the islands. This higher cost of living was recognised by both the Rural Fuel Poverty Task Force and the Scottish Fuel Poverty Definition Review Panel which recommended ‘the inclusion within MIS of significant mark-ups for disability/long-term illness and for remote rural cost of living factors’. SIF is concerned that this recommendation may not be accepted by the Scottish Government. The explanation that it would be ‘inconsistent with the broader approach taken by Scottish Government in measuring income poverty’ doesn’t seem to reflect the point that ‘Scottish Government agrees with the Panel that fuel poverty is distinctly different from other forms of poverty’. It also seems unfair not to make provision to adjust the MIS threshold to take disability and long-term sickness into account. By basing the definition on a generic national assumption we don’t believe it can necessarily provide the flexibility required to address distinct additional challenges of islands and rural areas. Fuel poverty needs to be tackled across all of Scotland’s communities but in practice could it mean that island households will effectively have a lower weighting because of their location. SIF fears that the new definition may result in fuel poverty on islands becoming less visible within national statistics and may render islands less able to attract the investment and interventions they need. This 'one size fits all' approach gives rise to concerns about long-term implications for island and rural communities as well as for people across Scotland who are living with disability or long-term illness. SIF would like to see evidence to show that the new definition is sufficiently and robustly ‘island proofed’. Island and rural communities have the highest levels of fuel poverty and severe fuel poverty in Scotland - the Scottish Rural Fuel Poverty Task Force states ‘In remote rural Scotland fuel poverty is 63%: nearly double that of the rest of Scotland. The disadvantage is clear. It is shocking to realise that so many of these householders are living in 'extreme' fuel poverty, that is they need to spend at least 20% of their incomes - often much more - on trying to keep their homes warm enough. This is a significantly higher level than is found on average in Scotland and demands serious and urgent attention’. For reasons presented above, SIF fears that the new definition will not adequately target resources or give fair weighting to island communities, which are amongst the most vulnerable to fuel poverty in Scotland. Moreover, while islands have amongst the highest levels of fuel poverty, they also have enormous potential for low carbon energy generation – islands already produce a sizeable proportion of Scotland’s 29.8% renewable energy. If the full extent of fuel poverty on the islands isn’t recognised at the national level, our concern is that there may be less joined up thinking or incentive to invest in innovative approaches to local energy generation to help resolve matters.
b) If this definition is to be used, how would you propose these challenges are overcome?
SIF advocates further appraisal and testing of the implications of the definition - as well as the need for a rural MIS - adapting it as necessary to ensure that island and rural communities are given an equal weighting with urban areas, to create a fairer national playing field for tackling fuel poverty.

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?

While we acknowledge the need to target support to those that most need it, we are concerned that the reduced emphasis on older households (resulting from the combination of using AHC, MIS and an increased threshold of 75 years of age) may have unintended and disproportionate impacts on island and rural communities. • Will the use of AHC recognise that people can still be fuel poor even if they have relatively low housing costs? It is not so unusual for elderly islanders on low incomes to own hard to heat homes in locations exposed to very inclement weather. Would the new definition of fuel poverty necessarily recognise their needs for affordable warmth before their 75th birthday? • Island and rural situations often include a high proportion of older residents, including some living in very poorly insulated old houses. SIF fears that increasing the vulnerability threshold to 75, together with adoption of a new 'Fuel Poverty' definition which fails to take due account of higher local living costs, housing quality and climatic conditions, may effectively mask and disregard some genuine needs which ought rather to be prioritised. • Adoption of inappropriate criteria to define fuel poverty could underestimate levels of local need and discourage investment support to upgrade local housing stock and implement other remedial measures on islands and other rural areas. • SIF would contend that some islands may be very well placed to pioneer innovative approaches to tackle challenges of both fuel poverty and more affordable low carbon energy supply through integrated programmes. SIF advocates further consideration and analysis of the new Fuel Poverty definition proposed, including an assessment of its possible impact on islands.

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?

We welcome this specific request for information regarding islands. Some challenges are mentioned in section 3: - wind and weather, no mains gas, lack of varied fuel types and diversity in the energy market and the need to increase flexibility in delivery programmes to ensure they meet the needs of island communities. The additional challenges have also been recognised by the independent Panel and have been well documented by the Rural Fuel Poverty Task Force as well as the within the Minimum Income Standard for Remote Rural Scotland: Recognition of these distinct and additional challenges is meaningless, however unless it can be translated to practical action on the ground. Disappointingly, such thinking within the current proposals seems lacking. Taking forward the Independent Panel’s proposal to include a specific remote rural enhancement to the new MIS income threshold would be a step in the right direction. Fuel poverty needs to be tackled across Scotland. To do so effectively in an island context needs a new approach to assessment and intervention which genuinely embraces the additional challenges, to allow for drivers of fuel poverty to be tackled in different ways. Through discussion with our members and colleagues at Scottish Rural Action, some further comments on the need for a more flexible and adaptable approach are outlined below: • A significant element of the additional burden experienced by island communities is our higher cost of living, as identified within the higher MIS reported by HIE. • Costs of implementing energy efficiency measures are significantly higher on islands due to types of housing, limited opportunities for economies of scale, additional transport and travel costs. How will the new strategy ensure that national programmes deliver practical benefits to island and remote communities, when available funding is so much more easily spent achieving quotas in more densely populated mainland areas. • It is highlighted within the consultation that ‘through our HEEPS: Area-Based Schemes we already distribute funding based on an assessment of need, which means that remote areas, including all island communities, receive more per head of population to tackle fuel poverty than those on the mainland’. Scottish Government support is very much welcomed but we would like to note that this higher level of investment is likely to be a consequence of the higher cost involved. • Fuel poverty is inextricably linked to wider issues around housing, costs of living and population change in the islands. For young islanders, it can be difficult to find a suitable island home of their own. 'If one considers all the factors that we all filter when deciding whether to stay in a community or not, hard to heat housing is a factor along with transport and connectivity etc. ... It is important to plan for growth and not decline by enabling those who will contribute to society thrive and survive' - Redacted text, Grimsay, Uist. • Island housing stock typically suffers significantly greater exposure to wind and rain so recommended room temperatures are more challenging to achieve for island households. • Understanding heating systems, energy tariffs and energy efficiency measures is key to empowering people to reduce their costs and make the right choices to improve their homes – it is important that national support programmes are made visible and available to remote communities – Cumbrae Elderly Forum. • Supply chains for remedial measures present significant challenges. Few island contractors are certified to carry out government funded home insulation work. If suitably qualified mainland contractors are willing to travel to the islands, additional time, costs and complexities are inevitably involved. Investment in training local contractors could present solutions in some instances but the approach needs to be tailored to address each island situation – Mull & Iona Community Trust. • The lack of cheap fixed tariffs for single supply of electricity. We are aware that SSE is introducing access to lower tariffs but in the meantime island consumers still have to pay the high prices. We would like to see the Scottish Government put pressure on the power companies to make cheaper deals available to all customers as quickly as possible. A lot of older houses in the Islands still have THTC (total heat total control) storage heaters which can only access the highest standard tariffs – Tiree Development Trust. • The surcharge for distribution has island and rural communities paying more for electricity than the rest of the country. How can this be reconciled with ‘it is unacceptable for people to face these fuel poverty challenges just because of where they live’. The surcharge seems particularly unfair when some of these areas are actually generating more renewable energy than they need. Orkney, for example, is a world leader in renewable energy, yet island communities there include some of the highest levels of fuel poverty in Scotland. • Vehicle fuel has not been included within the scope of this consultation but is a significant factor in the fuel poverty and increased MIS of the islands. The exorbitant price of fuel on islands, limited public transport and long distances to travel to get to work, school, college, hospital appointments, shops, recreation etc. is a significant additional household cost for people living on the islands and should be included within AHC – Tiree Community Trust. • The challenge of Brexit is also looming: While the Scottish Islands Federation has been working to ensure that Scottish islands and Community Energy Scotland may play positive roles in the imminent 'Clean Energy for European Islands' programme, we fear Brexit is likely to limit long term benefits to Scottish islands.
Fuel poverty presents an enormous challenge but we also believe that it may be tackled in part, at least, by developing opportunities and releasing potential: • When it comes to low carbon energy production, islands are not remote, they are at the centre and are currently leading the way in innovation to decarbonise energy supplies. • SIF, along with our ESIN partners (European Small Islands Federation) is currently part of a consortium bid for the Clean Energy for EU Islands Secretariat. This work has huge potential for all islands and for the future of clean energy. • The Clean Energy for EU Islands package has developed out of recognition of enormous opportunities for islands as well as the challenges their communities face. ‘Despite having access to renewable sources of energy, such as wind and wave energy, many of them depend on expensive fossil fuel imports for their energy supply’. The project package aims to provide a long term framework to help islands generate their own sustainable, low-cost energy through tailored sustainable energy action plans which will result in: • Reduced energy costs, greatly increased production of renewable energy and the construction of energy storage facilities and demand responsive systems, applying and sharing cutting edge technologies. • Better energy security for islands, which will be less reliant on carbon fuel imports • Improved air quality, lower greenhouse gas emissions, and reduced impact of fossil fuels on islands' natural environments. • The creation of new jobs and business opportunities, boosting island communities' economic self reliance, resilience and sustainability. • SIF would like to see these objectives and outcomes embraced, supported and integrated through the new fuel poverty strategy and also within the new Scottish Energy Strategy: The Future of Energy in Scotland. • Investment and action is required to enable community and locally-led energy initiatives to overcome current grid constraints which curtail potential for renewable energy generation. • Local energy systems can and should work particularly well on islands. One of our ESIN partners, the island of Tilos, recently won the 2017 EU Sustainable Energy Award with its renewable energy-based battery station and smart microgrid, sending a very strong message that alternative, community-level schemes that foster energy storage are becoming a viable reality and a way to address energy security for islands. Closer to home, progress has been made through the ACCESS project on Mull, and Surf ’n’ Turf in Orkney. The Shetland islands have also shown what can be done with their successful ERP district heating scheme in Lerwick. • Electric Vehicles: Public transport on islands is generally limited and fuel costs are significantly higher than on the mainland. Meanwhile many islands also have an abundance of renewable energy resources, but lack EV charging infrastructure. SIF believes there are pioneering links to be made here which could enhance island sustainability, through wider take up of electric and hybrid vehicle technologies. • The Scottish Government target for all homes reach a minimum energy performance rating should surely present opportunities for investment in local economic development. Support for small local businesses could build local capacity and skills to implement or adapt national programmes to deliver positive local energy outcomes. • Many community-led initiatives are making many positive differences to the local quality of life. Investment to build capacity and skills and share good practice always has a significant positive impact for remote communities. Increased shared ownership through community stakeholdership could generate significant income from RES to support measures to tackle fuel poverty. • Education and skills - Embracing innovation and low carbon technology could offer better jobs on islands which could encourage more working age people to stay/move there.

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?

SIF concurs with Scottish Rural Action, regarding the need for better ways to differentiate island and remote communities within measurement and monitoring systems.

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?
National initiatives may always struggle to reach remote households and offer a meaningful service relevant to the island situation. Work to identify those at risk and support those in fuel poverty is best delivered by local partners and community-led, grass roots organisations, particularly in island and rural areas. Working with older people to identify their energy and heating use would ensure that appropriate information and solutions are tailored for that age group. Through working with Home Energy Scotland, Community Energy Scotland and others and by accessing grant investment such as CCF and CARES, many communities across Scotland have addressed fuel poverty, reduced carbon emissions and increased energy efficiency. SIF would like to see the wealth of experience, learning and insight from these projects and those working on the ground taken on board and in an island context, used to help develop or adapt government schemes to work better for us.
What would best support, or enable such partnerships?
12 month project timescales are not very well suited to properly addressing significant community level challenges such as fuel poverty or energy efficiency. Local people's input as trusted neighbours might be vital and also to project manage but dependence upon commitment of already overstretched volunteers may be unsustainable. Partnerships which bring the support of salaried specialist personnel to meetings of local initiatives might be a more constructive way forward than a token local volunteer's voice on a regional committee or community planning partnership.

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.
As noted above, many community-led initiatives and local partners are already proactively tackling fuel poverty. These could become more effective if the new strategy recognises the need for a more flexible approach and longer-term investment. Any committed group of local volunteers ambitiously addressing a significant local issue together (such as fuel poverty) might reasonably yearn for a dedicated paid worker to relieve their unpaid time consuming burden of emergent action points following a meeting. Local partners willing to play or pay for such roles are regrettably few and far between, but could dramatically accelerate the pace of progress of community initiatives to address fuel poverty on islands.

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

Evaluation Support Scotland delivers quality training on this, but fee and travelling and subsistence costs of attending courses may discourage wider take up by more organisations. See also question 8.

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?

Sustained investment is the key here, especially to meet core costs rather than specific and short-lived project costs. As noted above, in island and remote communities the success of government schemes often relies on community-led activity. For example, residents on the island of Eigg have benefitted from HEEPS due to the island development trust initiating participation, while other neighbouring islands have had no engagement. The new strategy must invest in long term local capacity to enable more island communities to tackle fuel poverty and to enable communities to work together, strategically, sharing resources, skills and learning as suggested in the previous question. A reduced level of bureaucracy would also be welcome – most community and third sector bodies will already be required to conduct extensive reporting if they are in receipt of grant investment. A process of assessment, delivery and monitoring that reflects the distinct needs of island and remote communities would help to ensure that a quality service can be provided. It may be that a programme to twin community organisations with academic partners - or even student interns - could allow for more ambitious local initiatives to be pursued, with appropriate expertise and extended skill sets on tap or on call to support monitoring and reporting requirements. Reporting can sometimes be an unwelcome distraction for grass roots activists more concerned to pursue local action to enhance the wellbeing, resilience and sustainability of their communities than with networking outcomes and methodologies. It is sometimes as though every community initiative must start from scratch to reinvent the wheel. Some of us might welcome specialist newsletters or twitterfeeds, but committed inspiring people willing to support and advise in person with specialist expertise - the Community Energy Scotland way - might be the ideal way to sustain momentum and motivation.

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

An increased investment and greater involvement of community organisations would enable an increased reach and better inclusion of those furthest from reach. One-stop-shop could provide the capacity, training, and co-ordination to enable more local delivery.

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?

We would welcome this insofaras it should go some way towards insuring targets are actually addressed and met. However, given the distinct differences between our island, rural, suburban and urban communities and the interventions needed, we would agree with our colleagues in Scottish Rural Action that we would like to see the targets broken down to enable distinct monitoring of progress at local level.

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

a) What are your views on the proposed levels?
We agree that a greater uptake of low carbon, affordable energy solutions and that eradicating poor energy performance as a cause of fuel poverty must be a significant element of the government’s strategy. As with other national targets (eg broadband) however, the last 10% is often the hardest to attain and typically relates to islands and remote communities. Given that such areas tend reflect high levels of fuel poverty, SIF would especially welcome assurance that our constituency won’t be left, behind, with targets specifically relating to islands. There is a need for a proportionate approach in setting the targets that reflects the differences already highlighted, otherwise there is a danger that fuel poverty levels in islands and rural communities will remain higher than in urban areas but hidden in national figures.

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

a) What are your views on the proposed levels?
When setting out its proposed targets and milestones, the consultation does not address the higher levels of fuel poverty in rural Scotland and the islands in particular which require additional, proportionate, targeted action and resources.

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?

We agree with HES that as fuel poverty rates are currently measured via the rolling Scottish House Condition Survey (SHCS), the questions are: • how will these two new groups use the data published by the SHCS? • how will transparency of membership for these groups be achieved? • will records and reports of these groups be published as public documents?

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

SIF would welcome further appraisal and testing of the implications of the new definition and proposals, adapting as necessary to ensure that island and rural communities are given an equal weighting with urban areas, to create a fairer national playing field for tackling fuel poverty. Further work to examine the implications within the proposals for older households, young families and those with disability and long-term illness should be undertaken. We would also agree with HES suggestions of: • To review the fuel poverty data collected by the SHCS to ensure its ongoing robustness, particularly how it measures rural fuel poverty. • To develop means of keeping contact with, and gathering qualitative information from, local delivery organisations across Scotland. This local experience of fuel poverty ‘on the ground’ is invaluable and should be used to support national data and inform the strategy. • To continue to research and develop the fuel poverty definition. In particular, to take up the recommendations from the academic panel to undertake an additional stage of work on vulnerability with specialists from public health, local health and social care.

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?

We would take the lead from the learning of those that have delivered initiatives on the ground. Challenges could be overcome and be more cost effective by having a more locally-driven and collaborative approach.

Outcomes and Principles

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

We agree with HES that the challenge is how to gather qualitative feedback on the impact of fuel poverty/energy efficiency measures (i.e. inputs) have had on individual households. This should be addressed within the priorities for the Advisory Panel as explained above.

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

Bullet point one - ‘The fuel poverty strategy will be firmly based on the principle of social justice and creating a fairer and more equal society, irrespective of whether individuals live in urban or rural Scotland’ - does not seem to be fully reflected: the outcomes within the framework are almost all targeted at low income households. If ‘low income’ is determined by the UK MIS and AHC then it does not adequately address the inequality felt by island communities and is therefore at odds with bullet point one.

Assessing impacts

22. Do you think any of the proposals set out in this consultation will have an impact, positive or negative, on equalities as set out above?

If so, what impact do you think that will be and, if negative, how do you think these could be mitigated?
As outlined throughout our submission, we do not feel that the proposals recognise the particular issues faced by island and remote communities. We would like to see the Equality Impact Assessment include island and remote rural communities. We also note that the Panel’s recommendation to include ‘within MIS of significant mark-ups for disability/long-term’ does not appear to be taken forward either.

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

Delivery to island and rural communities will cost more, will take longer and needs to be more flexible - this needs to be reflected in the proposals.

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