Scottish Fuel Poverty Advisory Panel
E: c/o philippa.brosnan@fuelpovertypanel.scot & roanna.sefton@fuelpovertypanel.scot & trisha.melvin@fuelpovertypanel.scot
11/03/2025
To: Charlotte Friel, Retail Pricing and Systems, Ofgem
Dear Charlotte,
The Scottish Fuel Poverty Advisory Panel (SFPAP) is an advisory non-departmental public body which provides independent advice to Scottish Ministers on fuel poverty and scrutinises Scottish Ministers’ progress towards delivering Scotland’s 2040 fuel poverty targets. SFPAP is made up of the following members:
- Matt Cole, Chair of SFPAP and Head of Fuel Bank Foundation
- Margaret Corrigan, Panel Member and former Adviser for the energy advice service provided by East Ayrshire Council
- Kirsten Jenkins, Panel Member and Senior Lecturer in Energy, Environment and Society at the University of Edinburgh
- Alister Steele, Panel Member and former Managing Director of Castle Rock Edinvar Housing Association
- Fraser Stewart, Panel Member and Just Transitions Lead at Regen
Since it was established on the 1st of January 2022 the Panel has engaged widely across the third sector (advice agencies and housing associations) and energy sector (retail and network energy companies, trade associations), yourselves at Ofgem, and with the Energy Ombudsman and Consumer Scotland. It has also engaged with and is informed by those with lived experience of fuel poverty. The Panel’s views are informed by this engagement as well as their own knowledge, experience and understanding.
The Panel has heard from concerned stakeholders about the impact the RTS switch off could have on consumers. These concerns have pre-dated the recent RTS switch off campaign, and were part of a number of metering issues that have been brought to our attention through our engagement with consumer groups and stakeholders.
We have previously highlighted these issues to Ofgem1, including the fact that in rural areas of Scotland, where there is already higher rates of fuel poverty2, RTS meters are used by a high proportion of the population. We also know that those households using electric heating systems are also more likely to be living in fuel poverty3. Fuel poverty is not, however, inevitable. Policy choices can impact positively and negatively on the levels and depth of fuel poverty. The approach taken to the RTS switch off has the potential to deepen fuel poverty for those already experiencing it and push more people into fuel poverty.
The energy supply sector has performed poorly over a significant amount of time in the updating of metering technology. Any failure to replace all RTS meters by June 2025 should be viewed alongside delays in the completion of the roll out of smart meters. As we approach the switch off date, suppliers should be doing everything possible to replace the meters of impacted households to ensure this does not happen. However, given that over 160,000 Scottish properties still have RTS meters4, it is now highly likely that many households risk not having access to a suitable alternative post-switch off. There appears to have been a lack of accountability for suppliers who have failed to meet their obligations in replacing RTS meters. As such, the Panel would urge Ofgem to ensure that no customer is left without a supply of heating and hot water post-switch off. Furthermore, Ofgem should use its regulatory powers if RTS meters are not switched over in time, and ensure that a no consumer detriment approach is put in place. The costs and burdens of this approach should be carried by the energy suppliers, as outlined in the paragraphs below. Where customers find that their hearing and hot water systems no longer work, or capabilities are reduced as a result of the RTS switch off, they should receive emergency support as a priority to ensure that they remain warm, and then compensation.