Recommendations to the Scottish Government on its Fuel Poverty Strategy

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.

SFPAP Reflections and Recommendations on SGs Fuel Poverty Strategy.pdf

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1 House of Commons Library (2023) Fuel Poverty in the UK. Research Briefing. [Available online: Fuel poverty in the UK – House of Commons Library (] 

2 Scottish Housing Condition Survey, 2019.

3 The Scottish Parliament (2023) Chamber and Committees: Question reference: S6W-15551, Written
question and answer: S6W-15551. Available at: (Accessed: April 27, 2023).

4 Scottish Government estimates produced after the UK budget statement on 15 March 2023.

5 The 2019 fuel poverty estimates [24.6% of households, with 12.4% in extreme fuel poverty] mean that 51% of households suffering fuel poverty were in extreme fuel poverty. The current estimates of 37% in fuel poverty and 29% in extreme fuel poverty mean that 78% of households suffering fuel poverty are in the extreme fuel poverty category).

6 Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019, 2040 Targets 1 (b) “no more than 1% of households in Scotland are in extreme fuel poverty”.

7 These recommendations recognise the wider impact of fuel poverty – beyond the immediate payment of bills – to the effect on health and wellbeing with societal-wide consequences for health and social services.

8 Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019, section 6, paragraph 7.

9 An example of where this is done effectively is the thread which runs between national outcomes, sustainable development goals and the strategic outcomes in the Environment Strategy.

10 Review of the National Outcomes – Scottish Government – Citizen Space (

11 Fuel Poverty (Target, Definition and Strategy) (Scotland) Bill and Fuel Poverty Strategy: equality impact assessment – (

12 The Scottish Government (2021) Fuel Poverty Strategy Analytical Annex.

13 The Scottish Government (2023) Using intersectionality to understand structural inequality in Scotland: Evidence synthesis, Scottish Government

14 There are many ways in which this could be done, e.g., using a “theory of change” method to show how interventions will lead to outcomes drawing on available evidence.

15 The Child poverty monitoring and evaluation – framework for policy evaluations (, January 2023, shows how, in a mature model, policies can be evaluated, both singly & collectively, to assess their impact in delivering on the child poverty plan. This evaluation & monitoring framework – hangs off, and depends on, well-articulated outcomes.

16 Heat In Buildings Strategy: Achieving Net Zero Emissions in Scotland’s Buildings (

17 A “no detriment policy” aligns with the fuel poverty principle, set out in the Heat in Buildings Strategy, that decarbonising homes should not make fuel poverty worse. Heat In Buildings Strategy: Achieving Net Zero Emissions in Scotland’s Buildings ( This principle is also referenced in the FP Strategy, p. 56.

18 Rising cost of living in the UK – House of Commons Library (

19 House of Commons Library (2023) Gas and electricity prices under the Energy Price Guarantee and beyond. Research Briefing [available online: CBP-9714.pdf (]

20 Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019, sections 10 (a) low net adjusted household incomes, (b) high household fuel prices, (c) homes having low levels of energy efficiency, and (d) inefficient use of fuel in homes. These are characterised in the Strategy as: (a) low household income; (b) high energy prices; (c) poor energy efficiency of the home; (d) how
energy is used in the home.

21 There are opportunities to learn from other areas in the modelling of individual and collective policy contributions and their impact on outcomes. For example, The Child poverty monitoring and evaluation – framework for policy evaluations (, Jan, ’23

22 This could be viewed as starting to take forward the Strategy action 1 “Working with the Scottish Fuel Poverty Advisory Panel, we will explore the opportunities to carry out further lived experience research and build on our existing evidence base” p. 81.

23 This theme of leveraging data was highlighted by the SFPAP in its advice to Ministers in October, 2022 – see rec. 3.

24 Rationing means that people are not heating their homes according to the acceptable heating regimes set out in the fuel poverty definition or using sufficient electricity to meet all their needs.

25 2022-23 figures are yet to be updated but the last two years for which there is data (2020-21 & 2021-2022) show significant overall underspending.

26  Spring Budget 2023 ( 4.15 The government will adjust the EPG from 1 July to bring charges for comparable direct debit and PPM customers into line until April 2024, when the EPG ends. Looking beyond the end of the EPG, the government will ensure the PPM premium is ended on a permanent basis.

27 Ofgem have produced a voluntary code of practice for involuntary installation of pre-payment meters – 18 April 2023.

28 Although certain energy companies froze debt repayment over winter

29 Ofgem confirms changes to the price cap methodology and frequency ahead of new rate to be announced later this month | Ofgem – 4 August 2022.

30 SFPAP advice to Ministers in October, 2022 – see recs. 3 & 4

31 Review of electricity market arrangements – GOV.UK (

32 Scottish Fuel Poverty initial advice on actions to mitigate fuel poverty, October 2022, p. 20 “consider the efficacy of introducing a social tariff. The Scottish Government could influence the shape of a future social tariff by proposing a social tariff model to the UK Government and advocating for it as a medium-term development in the energy markets”.

33 Fuel Poverty in Rural Scotland – The Solutions_0.pdf (, April 2023, p. 10.

34  AUTUMN STATEMENT 2022 ( 2.44

35 SFPAP initial advice to Ministers – October, 2022 – recommendation 11

36 Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019, 14, 3 (a)-(c) (a) progress toward meeting the fuel poverty targets, (b) the likelihood of meeting the fuel poverty targets, and (c) the extent to which the four drivers of fuel poverty are being addressed

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