4 April 2025
To: Ms Miatta Fahnbulleh MP, Parliamentary Under-Secretary of State at the Department for Energy Security and Net Zero
cc: Ms Gillian Martin MSP, Cabinet Secretary for Net Zero and Energy and Dr Alastair Allan MSP, Minister for Climate Action, The Scottish Government, Ms Caroline Flint, Chair of the Committee on Fuel Poverty.
The Scottish Fuel Poverty Advisory Panel response on the affordability principle in The Fuel Poverty Strategy for England Consultation
Dear Minister
We [the Scottish Fuel Poverty Advisory Panel] are a statutory advisory body which provides independent advice to Scottish Ministers on fuel poverty matters and scrutinises Scottish Ministers’ progress towards delivering Scotland’s 2040 fuel poverty targets.
The drivers of fuel poverty [high energy prices, poor energy efficiency of the home, low household income, and how energy is used in the home] are multi-facetted and therefore cut across government and policy boundaries. Fuel poverty mitigations sit in both reserved and devolved policy areas. Because of this we have, since our appointment in 2022, commented on fuel poverty issues and mitigation measures when these reach across Scotland’s devolved powers to reserved ones which could have an impact on fuel poverty in Scotland.
We recognise that the proposed Fuel Poverty Strategy is for England but there are elements of the consultation which will, or certainly have the potential, to have benefits for Scottish households too – in particular the proposed Strategy’s intended foundational pillar of energy affordability.
In Scotland 34% of all households are in fuel poverty. This equates to around 861,000 households. 19.4% (or 491,000 of the 861,000 households in fuel poverty) are recognised as being in extreme fuel poverty, and the median fuel poverty gap is £1,250.[1] The figure of over a third of Scottish households living in fuel poverty is stark but this becomes more so when disaggregated. For example, 44% of households in remote rural locations find themselves in fuel poverty and 52% of households using electricity as their primary heating fuel live in fuel poverty.
We would like to take the opportunity of the consultation’s invitation for views on energy cost support for low-income and vulnerable households to set out our thinking to date on how this can best be achieved. We have already shared what follows with the UK and Scottish Governments, and Ofgem, but given the strategic role which England’s proposed Fuel Poverty Strategy could play in helping to lift people out of fuel poverty (or at least not deepen it) across the whole of Great Britain, we are taking this opportunity to draw our recommendations together and to present them collectively.
Our position is that fuel poverty is not inevitable even in an era of high and volatile energy prices. It can be mitigated and potentially eradicated through the right policy choices and effective, collaborative working. Our thinking and recommendations on what some of those policy choices could look like follow.