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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The Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 set an ambitious target to effectively eradicate fuel poverty by 2040. It established the Scottish Fuel Poverty Advisory Panel (SFPAP) as a statutory body to challenge and advise the Scottish Government in the delivery of its Strategy and the fuel poverty targets. The preparation and periodic reviewing of a fuel poverty strategy are required by the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019.

The Scottish Government’s Tackling Fuel Poverty Strategy (the Strategy), published in 2021, was developed pre-pandemic and published during the pandemic. The fuel poverty landscape has changed significantly since the Strategy was written: dramatic household energy price inflation has led to increasing numbers of households entering fuel poverty, as well as deepening the level of fuel poverty in already fuel poor households1 . This is not unique to Scotland, the rise in energy costs is part of a wider cost of living crisis. Energy price rises and fragile household incomes create a significant new challenge in tackling fuel poverty. This challenge shines a light on why both the Strategy and its delivery is a national priority, as well as the need for it to be re-calibrated to meet the challenges of the new fuel poverty landscape.

The Strategy was written in a time of reducing fuel poverty rates. In contrast, the trajectory over the past two and a half years has been one of escalating fuel poverty rates. The percentage of Scottish households living in fuel poverty declined steadily from 2013-2017 driven by a drop in the price of household energy, improvements in the energy efficiency performance of the housing stock and higher household incomes2 . Current estimates show that since 2019, progress made in reducing fuel poverty rates has effectively been reversed3 . Estimated rates of fuel poverty have risen from 24.6% of households, with 12.4% in extreme fuel poverty in 2019, to current estimates of 37% in fuel poverty and 29% in extreme fuel poverty4 . Both the rise in fuel poverty and the increasing percentage of those suffering fuel poverty in the “extreme” category are particularly worrying5 . There is a stark contrast in the current extreme fuel poverty rate of 29% and the 2040 target of a “maximum of1%”6 .

The SFPAP (which was not in place when the Strategy was written and consulted on) aims to support the Scottish Government in re-considering their Strategy in the light of the environmental and economic changes which have taken place since its publication. Since the SFPAP was appointed, it has engaged widely with the third sector (advice agencies and housing associations), the energy sector (retail and network energy companies and trade associations), the regulator (Ofgem), the Energy Ombudsman, and those with lived experience of fuel poverty. We believe that collaboration and shared goals are essential to tackle fuel poverty. Effective collaboration is needed between: the public, private and third sectors; housing providers; those in the energy supply chain, and the Scottish and UK Governments. In October 2022, we provided initial advice, including 9 (of 11) recommendations to the Scottish Government on mitigating the immediate effects7 of the worsening fuel poverty rates.

The SFPAP welcomes this opportunity to reflect on the Strategy. In doing so, we have built on our initial advice to Scottish Ministers. The SFPAP’s own expertise and experience, and the learning from its stakeholder engagement, has also informed these recommendations for the Strategy update. The SFPAP suggest, however, that its views alone are not a substitute for wider engagement and would welcome the opportunity to support and advise the Scottish Government in any further stakeholder engagement that it undertakes.

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