Scotland's Energy Efficiency Programme: consultation analysis

Aims and objectives of SEEP

85. The consultation document sets out the vision as:

'2050 vision - Scotland's buildings are near zero carbon by 2050 and this is achieved in a way that is socially and economically sustainable'

86. SEEP aims to reduce the energy demand, and decarbonise the heating of, Scotland's built environment in a way that is socially and economically sustainable. The consultation set out the following objectives:

• by 2032 94% of non-domestic buildings' and 80% of domestic buildings' heat is supplied using low carbon heat technologies.
• improvements to the fabric of Scotland's non-domestic buildings results in a 10% reduction, and Scotland's domestic buildings results in a 6% reduction, in their heat demand by 2032.
• SEEP will also support delivery of the Scottish Government's new Fuel Poverty Strategy as this is developed.

Question 2: How can Scotland best meet this vision and underpinning objectives in a way that is both socially and economically sustainable and supports long-term inclusive growth?

Summary of main themes:

• The need to focus on energy efficiency, particularly given its importance as a driver in reducing fuel poverty was highlighted by several respondent, as well as it being a cost-effective means to decarbonise our heat supply
• The need to address fuel poverty and energy affordability was seen as important priority.
• Other priorities included the need to start with existing buildings or to identify and address the most energy inefficient buildings; while other respondents commented on the need to prioritise off-gas areas.

87. 85 respondents commented. Many of these respondents, across groups, specifically commented that they welcomed the vision, aims and objectives, with several describing the vision as 'ambitious'.

88. One of the main themes emerging at this question, from across respondent groups, was the need to focus on energy efficiency. Respondents gave a number of reasons for this including the importance of energy efficiency as a driver in reducing fuel poverty. A small number of respondents quoted from the Scottish Fuel Poverty Strategic Working Group: "The statistics illustrate the important influence of energy efficiency on fuel poverty levels…the incidence of fuel poverty among the income poor rises to 99% among those in the least energy efficient properties, EPC rating E-G".

89. Other reasons included the benefits to health and wellbeing, with consequent savings for the NHS and benefits to the economy through jobs in the supply chain. Some also commented that improving energy efficiency is the most cost-effective route to decarbonise heat. One third sector / NGO said:

"Demand side activity can be implemented far more quickly than changes in the supply side and will allow delivery of carbon reductions with lower levels of low carbon supply. In addition, energy efficiency helps improve security of supply by reducing the demand for primary energy and hence dependence on supply side investment and energy imports. Most energy saving options are also more cost effective than investing in any new supply capacity and energy efficiency can meet multiple government objectives (including climate change mitigation, fuel poverty alleviation, improved health and well-being, employment etc.)".

90. Many respondents, across respondent groups, commented on the need to start with existing buildings or to identify and address the most energy inefficient buildings first. Several respondents also wanted to see priority given to off-gas grid areas

91. Another theme in many responses, again across respondent groups, was that of tackling fuel poverty, for example one housing respondent commented that: " SEEP should seek to eliminate poor property conditions as a driver for fuel poverty":

92. Some of these respondents asked for specific and measurable milestones and targets on fuel poverty to ensure this element is not lost or overshadowed by other objectives. One energy industry respondent commented that the SG will need to be clear "on whether the objective will be to reach the Scottish Government's carbon emissions targets or whether the focus will be on alleviating fuel poverty. The design and delivery of the scheme is likely to differ depending on the chosen focus".

93. The aim of tackling fuel poverty was also seen, by a respondent from the public sector / delivery agency / regulator group, as a useful way of engaging and raising awareness of SEEP as it is something that people will both understand and support.

94. A small number commented on the need for specific action in relation to fuel poverty in remote and rural areas as this may need more individual, and therefore more costly, measures.

95. In addition to fuel poverty, several respondents, particularly from the housing group, mentioned energy affordability. There were comments on the need for targets for energy affordability and the need for a focus on affordable warmth. A respondent from the academia / research / training mentioned that affordable energy should also encompass businesses as this would contribute to the economy.

96. Comments on the need to raise consumer awareness and bring about behaviour change also featured in many responses, again across most groups. For example: "The great potential for energy demand reduction by means of behaviour change must not be overlooked as an element of SEEP as it is at present. Well-aimed investment in public awareness/education is not only necessary but cost-effective" (third sector / NGO).

97. Raising awareness amongst the business industry was mentioned in a response from the public sector / delivery agency / regulator group with the comment: "Building industry awareness of the key milestones of SEEP will be vital to achieving its vision and objectives".

98. The need for local delivery and local supply chains was also a key theme, appearing in many responses across respondent groups. Several of these respondents, particularly from the building / insulation group, commented on the potential benefits to local jobs and economies and a suggestion that using local companies could help to raise awareness among the wider community. There was also a comment that local assessors and advisers would be useful as they would understand the local area and buildings.

99. The need for flexibility to meet the needs of local areas was stressed and a small number commented on the introduction of Local Heat and Energy Efficiency Strategies ( LHEES) which, an energy industry respondent commented, "could provide an effective framework for Scotland to deliver on its objectives in a way that is socially and economically sustainable". They also commented that "it will be for Scottish Government centrally to ensure the combination of these strategies meets national targets, as well as ensuring they are aligned with UK targets". There were, however, comments on the need to ensure local authorities are well supported and resourced to enable them to develop and implement LHEES. There were also comments on the need to ensure that issues for remote and rural locations are addressed.

100. Several respondents, particularly from the energy industry, commented on the need for clear, measurable objectives and targets with clear, long term, timescales and associated resources. There were calls for long term national policy support and the need for both national and local authority leadership, for example: "By setting clear long-term goals with appropriate milestone targets, the Government can help to reinstate confidence in policy, drive investment in innovative, low carbon technologies and encourage the deployment of energy efficiency solutions" (energy industry).

101. A small number mentioned the need to learn from schemes in other countries. Examples given included the Energiesprong approach which is delivering net zero carbon retrofits in the Netherlands; experience in Denmark where "those in the market for a new home are provided with greater transparency of running costs (including utility costs) at point of sale/rental" (energy industry). The municipalisation of energy supply in Europe was also highlighted as an example of delivering economic and social benefits to local communities.

102. Other themes to emerge, in small numbers of responses, included:

• The need for clear definitions, particularly with regards the phrase 'near zero carbon'.
• The need to learn lessons from previous schemes, particularly issues with the Green Deal.
• The need for cross working across the UK and challenges around devolved and non-devolved issues.
• The need for partnership working, between sectors but also between relevant public sector bodies including the NHS.
• The need for independent advice and assessors to ensure quality.
• The need to ensure private sector engagement.
• The need to attract private sector investment.
• The need to consider other energy sources such as LPG, hydrogen or recycled CO ₂.
• The need to future-proof the programme to ensure new technologies can be considered.

Question 3: We would welcome stakeholders' views on how to set appropriate milestones for energy efficiency improvement and heat decarbonisation of buildings to ensure that the level of emissions reduction ambition (i.e. near-zero carbon buildings) is achieved.

Summary of main themes:

• The need for final targets to be long-term was highlighted by a number of respondents, explaining that this will enable planning and allow for market and behaviour change.
• There were requests for targets to be realistic and achievable and to take into account, or be aligned with, targets and policies in other areas. Some respondents commented on the need for targets and milestones for sub-sectors of the building stock or occupant groups, including for fuel poor households or off-gas areas.
• The need for 'real' rather than modelled data to assist in target setting, particularly in relation to Energy Performance Certificates ( EPCs).

103. 76 respondents commented on this question.

104. A main theme from responses was that final targets need to be long-term to enable planning and allow for market and behaviour change. Some of these respondents were concerned that any short term targets could be subject to change and that this would harm rather than help to achieve the final goals.

105. A small number of respondents noted that there would need to be a long enough lead-in time to communicate and raise awareness of targets, as well as to provide advice and support. A third sector / NGO respondent commented:

"We advise long term milestones are set to provide time for landlords, be they social or private, to plan and set aside resources as well as to inform tenants of the benefits of this work to help overcome any obstacles and for owner occupiers to plan for any financial implications".

106. Several respondents, across groups, stressed that milestone targets should be realistic and achievable. There was a suggestion that milestones be set with industry to ensure realistic timescales. For example:

"We also believe that the key to the successful implementation of SEEP will be in setting achievable milestones. [The respondent] would recommend that when setting the trajectory for milestones, the level of ambition should gradually be increased over time. This will enable planned growth in the supply chain and hence help to ensure that both sustained, quality employment for local tradespeople and quality installations for consumers are successfully delivered as a result of SEEP." (building / insulation)

107. In addition, one energy industry respondent suggested that the trajectory for milestones should increase over time and suggested that this could be phased to coincide with times when major renovations are most likely to be undertaken.

108. A small number commented that milestones need to be set for each of the SEEP objectives.

109. While there was a little difference in opinion as to whether interim milestones should be set, most of the small number who commented on interim milestones felt that these would be useful.

110. The need for specific milestones and standards for domestic and non-domestic were seen as necessary by a small number, particularly from the energy industry group, in order to meet the different targets for reductions in carbon emissions. There was a comment, from the energy industry, that these milestones should reflect the timescales for planned reduction in carbon emissions.

111. A small number of respondents outlined the order in which targets should be set and met with some commenting on the need to begin with ways to reduce demand. However, the need for demand reduction measures and heat decarbonisation measures to work together was also stressed. A small number commented that the targets [on demand reduction ] (10% reduction for non-domestic and 6% for domestic sectors) could be more ambitious.

112. Specific targets and milestones for eliminating fuel poverty (as well as carbon emissions) were also seen as a priority, by a number of local government and third sector / NGO respondents, as was the need to prioritise district heating. A small number, across various groups, called for a milestone of EPC band C by 2025, commenting that EPCs are useful target as they are widely known and readily understood.

113. Another priority identified by several respondents was a focus on off-gas grid areas. A small number suggested a milestone of all homes in these areas being highly insulated and heated by renewable, low carbon and affordable heat sources by 2025.

114. Several respondents, from various groups, commented on the need for any milestones to take into account, or be aligned with, targets and policies in other areas. A building / insulation respondent gave the example that the Draft Climate Change Plan favours the use of timber, however high thermal mass materials could help deliver energy efficiency targets. Furthermore, a small number of respondents commented on the need for policies to be rural-proofed so that they do not discriminate against rural areas.

115. There was a query, from a respondent from the academia / research / training group, as to whether the final goal is eliminating fuel poverty or zero carbon, as these will necessitate different benchmarks. A small number also said that there should be equal priority given to both environmental and socio-economic considerations.

116. The need for more, and more current, data on energy consumption was mentioned by several respondents who suggested that this should be real world rather than modelled data. In addition, respondents wanted to see real world validation of the outcomes from any measures introduced.

117. There were further suggestions, each from one or two respondents, for targets or how they could be set including:

• Milestones for electrical goods and appliances, pegged to monitored progress of the DEFRA Market Transformation Programme.
• Solid wall insulation milestones.
• Building emissions performance targets.
• Heat waste.
• Local milestones that align / contribute to national targets.
• The percentage or numbers of buildings that have been improved.
• Aligning milestones to carbon budget periods.