Recommendations to the Scottish Government on its Fuel Poverty Strategy

Executive summary

The Scottish Fuel Poverty Advisory Panel (SFPAP) believes that the Scottish Government’s Fuel Poverty Strategy requires a fundamental review alongside a clear pathway to achieving the long term targets by the end of the current parliamentary term. As an interim measure, an update to the Strategy should be completed by the end of March 2024 to reflect the significant changes in the fuel poverty landscape since the Strategy was published.

The SFPAP’s recommendations to the Scottish Government on its Strategy update focus on six priority areas for action to directly address the drivers of fuel poverty and their impacts. The SFPAP also makes additional recommendations to support the governance and delivery of the Strategy. The six priority areas for action are, to:

1.  intensify the focus on improving the energy efficiency of Scotland’s housing stock through improved planning and accelerated investment. This should include developing strategic partnerships with housing, energy, and advice sectors to leverage capabilities and deliver holistic solutions. (In doing this, the particular challenges and opportunities of Scotland’s rural and island communities should be recognised).
2.  emphasise the structural importance of advice and advocacy in tackling fuel poverty and recognise the need for a review of the design and funding commitments for these critical services across Scotland at all levels of Government.
3. emphasise the key role in the short to medium term of the Fuel Insecurity Fund, and other direct measures, to help with energy costs and managing energy debt. Also, commit to analysing the eligibility criteria for all financial support packages to identify potential gaps in the targeting of financial support.
4. develop a stronger focus on the opportunities to influence the UK Government energy market reforms in the interests of low income and vulnerable households. For example, support and advocate for structural changes to energy pricing for low income and vulnerable households through mechanisms such as a social tariff.
5. develop a stronger focus on improving health outcomes for those suffering fuel poverty, embedding responses such as the implementation of the Warm Homes’ Prescription model.
6. explore the value in building on the Scottish Government’s Energy Summits, which included advice and advocacy organisations and energy companies, to create effective cross-sector collaboration. This collaborative approach could consider policy and organisational behavioural changes to support delivery of the Fuel Poverty Strategy.

We would also advise the Scottish Government that the Strategy update should improve the presentation and positioning of the strategic approach to tackling fuel poverty by including:

a. an outcomes-centred approach, which underpins the strategic vision of eradicating fuel poverty, enabling a clear line of sight between the vision and the actions needed to realise it.

b. mapping the high-level policy landscape for fuel poverty, referencing policies which directly support the delivery of fuel poverty targets, and a clear articulation of accountabilities for their delivery across Scottish Government and beyond.

c. analysis and scenario testing of the relative impacts of delivery plan assumptions on the drivers of fuel poverty, and assessment of what these analyses mean for achieving both the interim and the 2040 statutory fuel poverty targets in the context of changing energy demand and the move towards decarbonisation.

We would ask the Scottish Government that the Strategy update includes a commitment to working with the Panel in 2023/24 on two key areas of the existing Strategy that have not been progressed. These are, developing:

d. a research plan to improve the national evidence base and increase the understanding of fuel poverty in Scotland.

e. an outcomes-based monitoring and evaluation framework, without which the Panel cannot meet its statutory functions.