Scotland's Energy Efficiency Programme: consultation analysis

Scenarios

118. The consultation acknowledges that there are many different routes to achieving the vision and presented a series of potential policy and delivery scenarios.

The role of regulation, standards and financial incentives

Question 4: How might regulation and standards be used most effectively across the different sectors and when should they be applied across the lifetime of the programme?

Summary of main themes:

• The need to apply the same standards to all domestic buildings was noted in many responses.
• Standards should address fuel poverty, rather than energy efficiency alone.
• Standards and regulations should be clear and long term in order to promote confidence amongst both investors and consumers. Respondents suggested that short-term changes undermine confidence and create the need for retrofitting in future to meet increased standards.
• There were requests that standards and regulations should be complemented by funding and finance, to support action in both the domestic and non-domestic sectors.

119. 83 respondents commented on regulation and standards.

120. The main theme to emerge was the need to apply the same standards to privately rented and owned homes as apply to the social sector. Comments on this subject were noted in many responses across most groups, including in almost all responses from the housing and third sector / NGO respondents who replied to this question. For example:

"Straightforwardly the private rental sector should have the same targets as the social rental sector. Our energy advice service visits homes from all sectors and private sector rents are the highest, whilst affordable warmth outcomes and energy efficiencies are the lowest." (housing)

121. Other reasons given for this view included:

• That privately owned and rented homes make up the majority of tenure in the country and so standards need to be addressed in order to meet overall targets.
• That properties owned by social landlords should not be subject to more stringent regulations than privately owned properties.

122. Several respondents stressed the need for regulations and standards that focus on eliminating fuel poverty and affordable warmth rather than energy efficiency. A third sector / NGO also suggested that new builds should have a fuel poverty risk assessment. There was a suggestion, from a building / insulation respondent that Local Authorities should receive enhanced powers to mandate building improvements in designated areas affected by high levels of fuel poverty and deprivation.

123. Several respondents, across respondent groups, wanted to see clear and long term standards and regulations, commenting that changes lead to lack of confidence for both investors and consumers and mean that retrofitting is required as standards change. A respondent from the energy sector said:

"First and foremost, effective regulation and standards need to be underpinned by stable policy. This gives confidence to home owners, landlords, businesses and investors alike and is most conducive to competition and innovation."

124. Related to this, there were comments from a small number that regulation is required to facilitate change in behaviour or to drive the market for energy efficiency. A respondent from the energy industry gave the example of higher standards for boiler efficiency which led to a mass roll-out of condensing boilers.

125. Additionally, a small number of respondents suggested there was a need for clear communication and long lead-in times. Some responses also noted the need for new standards to align with current standards. A third sector / NGO respondent commented:

"In terms of how regulation and standards might be used most effectively across the different sectors we will note the importance of a long lead-in time to allow regulatory shadow to influence people before they have to be coerced. It will therefore be important to communicate as soon as possible to the private sector that regulation is on its way, what the standards will be, how these will rise over time and when they are likely to apply. As well as influencing people before they have to be coerced this would also help to ensure that people are able to go beyond initial regulated standards should they desire."

126. There were also comments from several respondents on the need for a carrot and stick approach that complements standards and regulation with financial assistance and funding. A housing respondent commented: "Imposing regulations and standards must come hand-in-hand with support to meet them. Small grants can greatly incentivise uptake of measures. If loans are to be offered these must be at a very low interest rate in order to be attractive".

127. Allied to this a small number, mainly from local government, commented on the need for support (funding) when introducing standards for non-domestic buildings, including the need for adequate funding streams including grants and other financial support; as well as funding for local authorities to decarbonise their housing stock.

128. There were also comments from a small number of cross sector respondents on the need to learn from schemes that have worked successfully in other countries or to look at how other countries have implemented their schemes. Examples included EPC targets in France, the Residential Energy Conservation Ordinance measure in California and district heating schemes in Denmark.

129. A small number of respondents mentioned the need for national standards that allow for local design and delivery. A small number of others made suggestions for standards for specific areas such as technical and skills standards. Some commented that standards should meet the needs of rural areas and that there should be flexibility in delivery to meet these needs.

130. A very small number suggested that changes in planning could help encourage energy efficiency improvements. An energy industry respondent suggested that planning should require new buildings to be energy efficient and incorporate lower carbon heating systems (energy industry respondent). An individual commented on issues around planning in conservation areas that overrides some measures such as solar panels. An energy industry respondent suggested that improving energy efficiency should be a condition of other property improvements or extensions.

131. A small number stressed the need for effective enforcement, both of existing standards and new standards.

132. Other suggestions, from smaller numbers, included:

• The need for improvements to Scottish Building Standards so that they cover non-standard measures that may be required for some housing stock, as well as removing loopholes.
• The need for regulations and standards to co-ordinate and support district heating.
• A small number of respondents from the energy industry commented on the need for consistency between the UK and Scotland to provide clarity and reduce costs for the supply chain.
• The need to allow standards and regulations to be flexible, as achieving them might unrealistic for some buildings.

Question 5: What should be the trigger points for buildings to meet standards? Should this differ between domestic and non-domestic buildings, and if so, how?

Summary of main themes:

The main trigger points identified by respondents were:

• point of sale;
• the start of a lease;
• and/or major renovations.

Views on whether trigger points should be aligned across sectors were mixed.

133. This question was addressed by 71 respondents.

134. The main trigger points identified were:

• Point of sale.
• Start of a lease.
• Major renovations or any change requiring planning permission.

135. Point of sale was mentioned across most respondent groups and by over half of those who commented. This was seen as a natural trigger point, although a small number commented that there will need to be work done to understand if some properties may not be captured. A small number of respondents suggested linking improvements to inheritance as this would capture some of the properties that may avoid the trigger at point of sale. Respondents also noted that as length of tenure in owned properties is quite long, other triggers (such as major renovation) would also be required.

136. The start of a lease was similarly mentioned by a large number of respondents, across groups, and again the main reason was that this is a natural trigger point for when improvement works are likely to be undertaken. As well as being triggered by a new lease, a small number also suggested lease renewal as a trigger.

137. Major renovations or any change requiring planning permission was mentioned by many respondents, albeit in smaller numbers than the points above but again across most respondent groups. Some respondents commented that using renovation as a trigger would capture houses that remain with a single owner for many years. A very small number, from the third sector / NGO and building / insulation groups, also suggested any renovation involving public funding could act as a trigger.

138. The following are examples of comments on these points:

"For both the domestic and non-domestic markets, the optimum trigger points will be at point of sale, new tenancy agreement (or renewal) and/ or building improvement." (energy industry)

"For the housing market the trigger point could be sale or lease as this will be the most straight forward point to regulate. One would need to have information on turn over within the housing stock to know if this would be sufficient to meet the SEEP targets." (local government)

"We think that the key trigger points should be at the point of sale and at the point of rental. These points provide an ideal opportunity to undertake energy efficiency works to a property. However, there are other points when it would also make sense to require buildings to meet standards. These include when properties are extended, when they are renovated and when there is a change of building use." (third sector / NGO)

139. Small numbers of respondents suggested:

• Targets for all new builds.
• Replacement of a heating system or the introduction of a smart meter.
• Change in usage.
• For non-domestic buildings, changes to standards.

140. Several respondents commented that this will not capture all buildings and so there could be a backstop date applied or a planned timeline.

141. A small number, from various groups, commented on the need for different trigger points for different sectors. A similarly small number, again from various groups, suggested that there may be merit in aligning trigger points across sectors.

142. The issue of affordability was raised by a small number of respondents, across various groups, as they felt this could lead to people being unable to sell or to renovate their homes.

Question 6: What do you think are the benefits of using financial and fiscal incentives to support energy efficiency in domestic and non-domestic buildings? Please give examples, from Scotland or elsewhere, of where incentives have been used in this way to good effect.

Summary of main themes:

• The need for a carrot and stick approach using both incentives and disincentives was emphasised by many respondents.
• The HEEPS: ABS scheme was viewed as successful and a number of respondents highlighted the RHI and Feed-in-Tariff, although noted that changes had reduced their effectiveness
• Views on the use of Council Tax and Non-Domestic Rates as a way to incentivise action were mixed.

143. 73 respondents addressed this question with many setting out their preferred methods of incentivising energy efficiency.

144. While respondents acknowledged the importance of financial incentives many, across most respondent groups, stressed that a carrot and stick approach is required.

145. Several also commented on the importance of awareness raising (for example of the potential reduction in fuel costs) and engagement amongst both the public and businesses.

146. One of the schemes mentioned by several respondents, and in particular by respondents from local government and the third sector / NGO groups, was the HEEPS: ABS scheme which was seen as having been successful. Some also mentioned the success of linking HEEPS: ABS with the Energy Company Obligation ( ECO).

147. While several respondents, many of whom came from the local government group, felt that Renewable Heat Incentive ( RHI) and the Feed in Tariff ( FiT) had worked, there were also comments that changes to the schemes had reduced their effectiveness. However, a small number felt the RHI had not worked due to its complexity, while a small number suggested that other methods such as scrappage schemes or up-front cost subsidies might increase uptake.

148. Views on the use of Council Tax were mixed. A small number of respondents commented on recent research from the Consumer Futures Unit ( CFU) at Citizens Advice Scotland that suggests Council Tax rebates or reductions would be an effective incentive while a small number of others, particularly from the industry groups, simply said that Council Tax rebates or reductions could be used as an incentive.

149. Some respondents gave examples of how Council Tax could be used, including:

• That Council Tax could be adjusted to reflect the energy efficiency of a property.
• That there could be a link between Council Tax and zero-carbon properties or properties with reduced carbon emissions.

150. A small number, particularly from the government group, suggested that using Council Tax may prove difficult due to the fact that this is managed at a local level and so there may be differences across local delivery agencies. There was also a comment that rates relief through Council Tax could discriminate against those with older more difficult to upgrade accommodation. A housing respondent said that while a Council Tax reduction might prove effective for owner occupied properties it would not be so effective for privately rented homes as the landlord is not incentivised.

151. These respondents also raised similar points in relation to the benefits and drawbacks of using Non-Domestic Rates.

152. A smaller number of respondents from various groups mentioned low cost or interest-free loans, particularly those with a cash-back element, for example the Home Energy Scotland loan scheme. A respondent from the third sector noted that grant funding may increase uptake more than loan funding as households are already financially stretched.

153. Equity release loans were also suggested by a small number of respondents across groups, although there was some concern about equity release loans from a very small number of local government respondents; one commented: "In other areas of work officers have learned that equity schemes generally don't work and are not an attractive option for many homeowners. This was noted in the Help to Adapt pilot for example and some Empty Home schemes".

154. Encouragement for high street or mortgage lenders to offer preferential rates was also suggested by a small number of respondents, who suggested lenders could offer preferential rates recognising the value of energy efficient homes or that the lower running costs of energy efficient properties could be taken into account when looking at mortgage affordability.

155. Other suggestions, from small numbers, included:

• Tax credits / mentioned by a small number from various groups.
• Varying the Land and Buildings Transaction Tax according to a building's EPC (mentioned by a small number from the energy industry as well as a small number of others).
• Enhanced Capital Allowances.
• Landlord's Energy Saving Allowance ( LESA).
• Help to Buy / Lifetime ISAs.
• Carbon Reduction Commitment ( CRC).

156. Once again, several respondents commented on the need to learn lessons from less successful schemes. The Green Deal was mentioned most frequently.

157. The need to also consider the administrative costs of any scheme was raised by a small number of respondents.

158. A number of specific examples were given by respondents, including:

• The Green Additional Borrowing offered by Nationwide Building Society, in the UK.
• The PACE (Property Assessed Clean Energy) Bond in California.
• The Eco- Prêt 0% loans scheme in France.
• Long term fixed rate low interest loans from the KfW development bank in Germany.

Question 7: What is the best approach to assessing energy efficiency and heat decarbonisation improvements to buildings? How could existing approaches best be used or improved and at what level and scale

Summary of main themes:

• Many respondents mentioned EPCs, with several commenting that they are already well known and are a good approach to assessing energy efficiency.
• However, several respondents commented on a range of issues regarding EPCs, including around the underlying methodologies.

159. 65 respondents replied to this question, with many mentioning Energy Performance Certificates ( EPCs).

160. Several respondents acknowledged that these are widely known and fairly well understood and allow standardised assessments. These respondents, including third sector / NGO, local government and some industry respondents, suggested that EPCs should be used for assessment, for example an energy industry respondent said:

" EPCs offer a simple and widely accepted tool to underpin high level policy ambitions to improve the energy performance across the housing stock."

161. However, several of these respondents also acknowledged that there are some issues around EPCs. A smaller number felt that EPCs are not suitable, mainly because they are based on modelled, rather than real, data.

162. Several respondents, from various groups and both from those who supported and did not support the use of EPCs, called for 'real world', rather than theoretical or modelled data. There were comments that the modelled assumptions currently used misrepresent the distributions of household energy costs and disadvantage vulnerable households and those in rural and island areas.

163. Allied to this, a small number of respondents suggested that EPCs are a 'blunt tool' as they are based on a 'desk' exercise using pre-defined assumptions about the fabric of property. Some felt that EPCs do not work well for Scottish housing stock as they are based on a set of assumptions.

164. Respondents, from various groups, commented that EPCs are designed to demonstrate compliance and not design, and that these model-based methodologies do not always give an accurate picture. There were suggestions that the methodology needs to extend to include building use and performance as well as occupant behaviour. There was also a request for post-coding the carbon content of electricity.

165. Calls for building energy performance to be included in assessment featured in several responses from various respondent groups.

166. A small number also commented that EPCs do not provide tailored recommendations for improvements, do not value low carbon heat, and are based on energy cost.

167. There were suggestions that the underlying methodologies need to be looked at as they are described as slow to change and so may need updated in line with new technologies. A third sector / NGO respondent commented:

"We encourage further work to improve or replace the EPC calculation methodologies as current SAP and SBEM clearly not sufficiently well calibrated. And if elimination of fuel poverty is a major driving force then energy consumption / energy costs must be a clearly identifiable factor for decision-makers not just the ubiquitous carbon dioxide measure"

168. The need for training and accreditation for assessors (and funding to provide this) also featured in several responses, for example :

"An independent framework of independent assessors for the scheme would support smooth application processes and enable monitoring to be transparent, traceable and repeatable" (energy industry).

169. Other suggestions, from small numbers of respondents, included:

• The need for both area based and individual property assessments.
• Aligning energy efficiency and heat decarbonisation improvements with local authority local area heat strategies.
• The need for post occupancy assessment.

The appropriate levels and sources of funding

Question 8: How should the installation of energy efficiency improvements and lower carbon heat supply through SEEP be funded? In particular, where should the balance lie between grant funding and loans for homeowners, landlords and businesses?

Summary of main themes:

• Respondents suggested that a combination of funding measures and sources will be required, with those in fuel poverty being eligible for grants, whilst those who are able-to-pay should have access to low cost loans.
• The need to "kick start" the able-to-pay sector was noted, with suggestions that incentives or grants may be needed as engagement with this group has been low to date.

170. 76 respondents from all respondent groups addressed this question.

171. Most respondents voiced their agreement with the need for a combination of funding measures and sources.

172. Many, again across groups, felt that those experiencing fuel poverty should have access to grant funding while those more able to pay should have access to zero or low interest loans. This example came from a respondent in the energy industry:

"We agree that targeted support should go to households that are not able to pay for measures themselves. This would include, but not necessarily be limited to, households in fuel poverty as it may be appropriate to extend the support available to other vulnerable groups e.g. those with a health condition caused or exacerbated by living in a cold home. The able to pay sector needs to become more active in energy efficiency. As discussed above, this is likely to require a combination of regulation and financial incentives. It is important to get the balance right between incentivising homeowners to take action and providing incentives that are too generous and which have unintended consequences."

173. A small number commented on the need to ensure that those 'able-to-pay' are protected from falling into fuel poverty, for example pensioners who may be asset rich but cash poor; a third sector / NGO respondent suggested that grants, rather than loans, would be required for this group.

174. The HEEPS approach to funding was again mentioned by several respondents, from various groups, who commented that this could be built upon and/or that it should be coupled with the Energy Company Obligation ( ECO) after its devolution. Some commented that the HEEPS approach is easy to understand and consistent.

175. In relation to ECO, respondents commented on or queried how ECO funding will be blended with SEEP funding and on whether the SG could use its powers to ensure the delivery of ECO reflects local requirements. An energy industry respondent also noted that there is a need for "the Scottish Government and the UK Government to work together closely with a focus on ensuring that the costs (and therefore the bill impacts) in Scotland do not differ materially from those in England and Wales".

176. There were differing views on how those able to pay could be supported. Across groups, respondents commented that the take-up from and engagement with this group is low and so grants or other incentives will be required. For example, one local government respondent was of the opinion that:

"the 'Able to Pay' group will need to be incentivised as they will be reluctant participants in SEEP. There has been little or no engagement with this sector of the community as HEEPS is directed to fuel poor areas. Consideration could be given to the use of income levels, SIMD areas and council tax bands to determine the level of grant award, if any".

177. Others simply mentioned the need for loans to be available for this group. One energy industry respondent suggested that it will be important to gain insight across a number of different demographic groups in order to establish the most effective approach.

178. A small number commented on the need for further research from previous and existing schemes in order to gather data on the best measures to use.

179. Some of the suggestions for loan funding (mentioned mainly by a small number of local government and third sector / NGO respondents), included for example, equity release schemes funding through a 'green bank' and deferring payment until a property is sold.

180. A very small number commented that grants should be targeted on the objectives that will be hardest to achieve. A small number also stressed the need for public funding to go to those who need it the most.

181. A small number commented that grants, loans or other financing should be linked to the property and not the lease holder or owner, for example a respondent from the energy industry said: " We need better options than grants or loans. Low carbon assets added to buildings provide long term benefits for the building. The finance needs to be linked to the building and similarly long term. This will minimise and in many cases avoid altogether the need for grant".

182. A small number suggested that the market would need to be 'kick-started' in order to attract private investment. Government backed zero interest loans were suggested as a possible measure for this.

183. The need for funding to be sourced at national level with delivery designed to suit local conditions featured in a small number of responses including a local government respondent that said: "Funding and grants should be sourced at the national level, where across the programmes better rates of return can be produced and compensate for areas likely to be harder to treat for example the cities densely populated may provide a better return than the dispersed rural opportunities".

184. A small number again commented that simplicity will be key to increasing uptake and suggestions included that, if there are various different schemes available, there should be one point of contact or that eligibility criteria should be clear. A respondent from the public sector / delivery agency / regulator group suggested:

"a single point of contact for all relevant grants/loans/support should be provided to help the consumer (public, local authority, private) assess the applicability of these schemes for the project they need, without them needing to know the names, contacts and procedures of all the different schemes. For example a potential applicant could call a number/visit a website where they are required to answer a series of questions that helps the scheme operator identify which fund the applicants are suitable for".

185. A small number of respondents felt that the amount being committed by the SG would not be sufficient, with calls for more work to establish costs and to identify how best to attract private investment.

Question 9: What is needed to encourage private investment in energy efficiency and heat decarbonisation, including the take-up of loans by a wider range of owners and occupiers?

Summary of main themes:

• Respondents reiterated points made at previous questions, including commenting on the need to build market confidence by creating a long-term and stable policy framework that utilises a carrots and sticks approach to drive action.

186. Most of the 71 respondents, from across groups, who replied to this question reiterated the points mentioned at the previous questions on funding.

187. The main points, reiterated at this question and echoing responses given to previous questions, were:

• The need to build the market and to build confidence in the market by putting in place clear, long term policies and funding. Respondents noted that standards and regulation are key levers in supporting and encouraging private investment: "The certainty that comes with regulation will undoubtedly boost the market and support the development of more businesses, jobs and skills" (local government).
• The need for both incentives and disincentives (the carrot and stick approach), including access to affordable loans.
• That the quality of energy efficiency installations is important to building confidence and increasing uptake.
• The need for clear communication, including awareness raising and advice and on educating people about the value of the scheme.

188. Other points made by smaller numbers included that investment would be encouraged by simplicity, a low level of risk for both property owner and investor, and clear and predictable returns.

Question 10: Of the current sources of finance which are currently available for energy efficiency and lower carbon heat supply, which are working well and which are not? Are there successful examples of attracting private sector finance to support energy efficiency improvements that could be explored? Are there any others which should be developed or made available?

Summary of main themes:

• Respondents reiterated points made at previous questions.

189. 47 respondents answered this question and, again, many referred to or reiterated the points that they had made at the previous questions on funding and finance.

190. The main points reiterated by respondents to this question included:

• The need to understand reasons behind the take-up of existing loans and grants.
• The need to consider tax incentives.
• The need for grant funding.
• The need for longer pay-back periods for loans.
• The need for simple, easy to understand and access, funding schemes.
• The need for an area-based approach to encourage private sector investment.

191. Respondents provided the same examples as they had at previous questions with, again, several commenting that HEEPS should be continued or the HEEPS approach built upon.

192. A small number commented on the need to ensure that findings from the SEEP pilot are used to ensure the scheme can be rolled out without need for any amendment.

Advice and information

Question 11: How do we ensure that householders and owners are well advised and supported in making decisions on how to improve the energy efficiency of their building and install lower carbon heat supply through SEEP?

Summary of main themes:

• Many respondents mentioned Home Energy Scotland, commenting that it is well known and trusted; and that it already provides independent and impartial advice. Respondents thought that it has a good track record and therefore should be continued and built upon.
• The need for advice to be tailored to the individual, rather than generic, and preferably delivered face to face was emphasised. Respondents also commented on the need for advice on behaviours to be included.

193. 74 respondents, across respondent groups, addressed this question.

194. One main theme related to Home Energy Scotland. Many respondents mentioned this source of advice noting that it is well known and trusted and that it already provides independent and impartial advice. Its good track record was noted and many respondents commented that it should be continued and built upon. A third sector / NGO respondent commented: "We believe it is important for householders to have a free, impartial and trusted source of advice, Home Energy Scotland and other local advice providers should continue to play this role".

195. Another main theme, from across respondent groups, was the need for advice to be tailored to the individual rather than being generic, with several respondents saying this needs to be provided face to face. For example, a local government respondent commented: "Face-to-face and tailored advice is essential to uncover a range of issues and assist in alleviating fuel poverty. In current schemes generally we feel not enough is invested in face-to-face advice".

196. However, some respondents, from the third sector / NGO group, also wanted to see the use of other delivery methods, including online, social media, hard copy and telephone.

197. Several respondents commented on the need for advice to be tailored to individual financial circumstances as well as energy use, behaviour, and building type and quality (of maintenance / fabric). Some of these respondents suggested that the use of smart meter data will be very useful in this regard.

198. Several respondents, from various groups, stressed that advice should be provided by expert, independent or impartial advisers.

199. There were calls, from across various groups, for quality standards or accreditations, for both installers and those providing advice, to provide confidence to customers. A small number of respondents, particularly industry respondents, suggested that recommendations from the Each Home Counts review on improved training and quality standards should be considered as they felt this would help ensure consistency across the UK.

200. Other themes, mentioned in small numbers of responses, included:

• The need for a national campaign delivered locally by trusted sources.
• The need to utilise all involved in the supply chain in providing advice.
• The need to ensure plain English is used.
• The need for follow-up to ensure any new technology is understood and being utilised correctly.
• The need for schemes to be simple, easy to understand and easy to access.
• The need to also provide advocacy, particularly for the most vulnerable.
• The need to build on the existing network of advice providers.
• The need to ensure advisers are well trained and that they supply advice relevant to each building or person.
• The need for up to date, relevant data to help with advice provision.

Question 12: Are the current mechanisms for providing advice sufficient? What changes, if any, do you think are required?

Summary of main themes:

• Respondents reiterated and referred to comments made at previous questions.
• There were comments on the need to build on existing, trusted, impartial sources.
• The need to raise awareness of, and promote, sources of advice was suggested, as respondents felt that the reach of advice provision could be improved.

201. 61 respondents commented and again many referred to or reiterated comments made at the previous question.

202. Building on existing, trusted, impartial sources was seen by several respondents, across various groups, as the best way forward. Again, Home Energy Scotland was identified as a successful example.

203. There were several comments, from within most respondent groups, that there is a lack of awareness about the sources of advice currently available and that these need to be better promoted, for example: "The current mechanisms are very good however public awareness of the mechanisms needs to be improved - better communication is required" (academia / research / training).

204. This was echoed by a respondent who requested an increase in the capacity and reach of advice provision.

205. Several respondents again commented on the need for a greater focus on behaviour change.

206. A small number commented on the need for adequate funding, both to train advisers and to support, train or accredit those local groups currently offering advice.

207. Pulling together all the different strands of advice (including health, money, energy etc.) under one umbrella was also suggested by a small number.

208. While face to face advice was seen as important, particularly for vulnerable or hard to reach audience, ensuring the availability of other delivery methods, to suit all needs, was also suggested.

209. A small number called for a Code of Practice and/or monitoring of advice provision.

Question 13: What are the opportunities to link SEEP delivery with other initiatives, including the UK Government's smart meter rollout, so that we maximise the benefits for the people of Scotland?

Summary of main themes:

• That smart meters are a good first step in engaging consumers and enabling them to understand their energy usage.
• Views were mixed on the opportunities for linking SEEP to smart meter delivery. Some respondents commented on the benefits of linking SEEP with the smart meter rollout. Others, however, noted a range of issues including timescales, coverage and the risk of overloading the smart meter programme.

210. 61 respondents across groups commented, mainly in relation to the smart meter rollout.

211. Smart meters were seen by several respondents as a good first step in engaging consumers and enabling them to understand their energy usage. Several respondents felt that there could be benefits in linking SEEP to smart meter delivery, especially since the Smart Meter Installation Code of Practice already obliges installers to offer energy efficiency advice.

212. Access to the data that will be provided via smart meters was seen by several respondents, across groups, as potentially beneficial for the development of both SEEP and district heating schemes. A small number commented that the availability of smart meter data would help to provide more detailed and tailored advice for consumers or that that this could be used for monitoring energy consumption.

213. A small number of respondents, from various groups, commented on the need for consumers to be fully aware of how to make effective use of the data provided by their smart meter and that this information could then be a driver for behaviour change.

214. While several respondents saw some benefits in linking SEEP with the smart meter rollout, a small number identified issues including:

• That SEEP and smart meter timescales are different and so making a link may prove problematic. An energy industry respondent commented that smart meter timescales are already under pressure so joining with SEEP could place the 2020 target at risk.
• The short time that smart meter installers spend in each home and that this is not sufficient to be able to deliver tailored advice without putting smart meter delivery costs and timescales at risk. Some respondents noted that consumers may be overburdened if SEEP is linked to the smart meter rollout.
• The coverage of SEEP and smart meters is likely to differ as smart meters are intended for everyone while SEEP may have a more targeted audience. Some respondents were concerned that not everyone will receive a smart meter. Rural areas, areas with poor internet access and parts of the population with lower internet use, such as older people, were mentioned.

Consumer protection

Question 14: How can SEEP be designed and promoted to build consumer confidence (as a trusted 'brand')? What are the risks and opportunities associated with particular approaches?

Summary of main themes:

• The need for local authority-led schemes coupled with national leadership, to demonstrate firm, long-term commitment to the scheme, helping to build confidence.
• The need to build consumer confidence by demonstrating effectiveness.
• The need for robust standards, quality assurance and accreditation was suggested by respondents, with a smaller number suggesting that an independent watchdog would be needed.

215. 66 respondents, across groups, commented on this question.

216. Several respondents again stressed the need for national leadership linked to local delivery.

217. Many respondents, from various groups and particularly local government, commented that local authority-led schemes will be trusted, for example: "Using a local delivery model should help to build consumer confidence as local authorities are seen as trustworthy" (energy industry). There were some calls for co-branding with the Scottish Government and local authorities and several respondents said there should be a national scheme with local delivery.

218. There were also several comments, from various groups, on the need for national leadership, for the Scottish Government to show a firm, long-term commitment to the scheme, and that it should have clear messages and goals as well as funding. National promotion was also seen as a good way to instil confidence. The need for a national, single point of contact or information was mentioned by a small number.

219. Another main theme, again seen in responses from various groups, was that of the need for robust consumer protection measures, including redress. The need for quality assurance and accreditation, including quality marks and standards, also featured in several responses. A small number, across groups, suggested an independent watchdog or regulatory body such as Ofgem. In addition, across various respondent groups there were some comments on the need to build trust or address a negative perception of, the energy efficiency industry.

220. The other main theme in responses, particularly from the energy industry and building / insulation sectors, was on the need to build consumer confidence by demonstrating effectiveness, particularly by using case studies or other 'real' information or data to show the benefits of the scheme, and demonstrating progress against targets.

221. Other suggestions, from small numbers of respondents, included:

• The need for a friendlier name than SEEP (not using an acronym).
• Involving major, trusted organisations such as Citizens Advice.
• The need to streamline existing schemes to remove any confusion.
• The need for effective communication.

222. Once again, there were a small number of comments, particularly from energy industry respondents, that it would be beneficial for SEEP to align with the outcomes of the 'Each Home Counts' review.

Question 15: Is there a tried and trusted form of consumer redress that should be adopted or, if not, what should such a mechanism look like?

Summary of main themes:

• Respondents commented that a consumer protection mechanism should be free, easy to access and widely publicised, as well as being independent and having a clear complaints procedure.
• The Each Home Counts Review was mentioned most frequently as a good form of consumer redress.

223. This question was answered by 42 respondents.

224. While most of the respondents voiced their support for some form of redress, few were able to suggest a tried and tested form. Those that did mentioned the following:

• The Each Home Counts approach was mentioned most frequently by respondents across various groups.
• Ofgem was mentioned by a respondent from each of the energy industry, local government and other respondent groups.
• Professional and accreditation bodies should be involved "in order to avoid re-inventing accreditation" (third sector / NGO) .
• Heat Pump Court from Sweden.
• Energiesprong UK.
• Chartered Trading Standards Institute ( CTSI) Consumer Codes Approval Scheme.
• Financial Conduct Authority ( FCA) Renewable Energy Consumer Code ( RECC).
• HEAT Trust.
• Scottish Public Services Ombudsman ( SPSO).
• Existing industry processes and guarantees.

225. Other, more general, points that respondents felt should be included in any consumer redress included:

• A single point of contact; an oversight body.
• That it should be widely publicised.
• That it should be free and easily accessible.
• That it should be easy to use.
• That it should be independent.
• That there should be a clear complaints procedure.

226. The need for clear codes of practice, certification, guarantees and quality marks were also mentioned by small numbers across respondent groups.

227. A small number of respondents again mentioned the need to learn from the experience of the Green Deal scheme.

Question 16: How should SEEP look to integrate the findings of the Each Home Counts Review - e.g. could it be used a basis for developing a consumer protection framework for SEEP?

Summary of main themes:

• Most respondents supported the use of findings from the Each Home Counts Review as a basis for developing SEEP.
• Respondents suggested that the proposals from Each Home Counts should be adapted to the Scottish context and built upon, in particular the quality mark, consumer charter, code of conduct and code of practice.

228. 31 respondents, from all respondent groups, replied.

229. Almost all said they supported using findings from the review although some commented that as implementation has not yet started it is difficult to be specific.

230. A small number of respondents said they wanted to see the proposals from Each Home Counts adapted to the Scottish context and built upon, as they are seen as providing opportunities to enforce best practice through SEEP.

231. Particular aspects welcomed by respondents were the quality mark, consumer charter, code of conduct and code of practice. In relation to the development and introduction of a quality mark and consumer charter, there were calls, from industry respondents, to ensure that industry is involved in the development or to link to existing industry processes.

232. There was also a call, from a housing respondent, to ensure that the costs or training arrangements involved in gaining a quality mark do not discourage small, local firms. A small number commented that the codes would encourage good business practice or help to minimise the risk of poor quality installation.

233. There was a suggestion, from the energy industry group, that the SG should work with the Department for Business, Energy and Industrial Strategy and the Welsh Government to develop a UK wide consumer protection framework, as the energy efficiency industry works across borders.

234. A small number suggested looking at outcomes from Scotland-specific work. The Warmer Homes Scotland Programme was mentioned, with a comment that this is seen as leading the way in consumer protection, and a suggestion to draw on the experience from this programme.

235. A third sector / NGO respondent also felt it important that "in developing a consumer protection framework it will be important to draw on the experience and views of the supply chain and understand the implications for them of different options".

The establishment and sustainability of local supply chains and trusted delivery agents

Question 17: How can local supply chains be expanded and up-skilled to ensure that maximum economic benefit and job creation is secured across all of Scotland?

Summary of main themes:

• The need for long term programming and funding was recommended by respondents suggesting that this is needed to give certainty to businesses to recruit and upskill.
• Some respondents commented on the need to ensure that bureaucracy does not stifle local supply chains, noting that the costs of accreditation can be prohibitive for smaller operators, and that they are also often not aware of the procurement frameworks.
• The need for clear training pathways was suggested and that delivery and training should done locally.

236. 68 respondents, from across respondents groups, commented on this question.

237. Once again the need for long term programming and funding and for clear targets to provide certainty and market confidence were mentioned as key, as respondents felt these would give businesses the confidence to invest in recruiting and in upskilling.

238. Several respondents commented on the need for a stable framework or policy certainty. A small number of energy industry respondents commented on the need for the Scottish Government to create momentum both in new build and retrofit and suggested that SEEP could help build this momentum and drive demand.

239. A small number of respondents, mainly from the building / insulation and third Sector / NGO groups, felt that a guaranteed level of work would be necessary for businesses to allow them to invest in training. There was a suggestion that a large scale programme of maintenance and repair of existing buildings could help provide this. Several respondents again commented on the need for funding both for training and to provide investment.

240. Comments on training included the need for clear training paths and accreditation standards. Respondents noted the need for local delivery and to work with education, local businesses, industry, enterprise agencies and skills partners. One respondent, from the academia / research / training group, made a number of recommendations in relation to SEEP; three of these related to skills, training and skills demand:

"The Scottish Government should, in conjunction with industry, undertake an initial assessment of the skills requirements to meet the delivery objectives of the strategy. SEEP milestones should reflect anticipated capacity in the workforce and be informed by plans to raise skill levels and training infrastructure for increasing demand. The SEEP Strategy should encourage industry to embed core knowledge, including basic building physics, design stage, consumer interaction and building performance into all relevant vocational and professional pathways. Local energy efficiency programmes should be set against skills provision to ensure that training is maximised to meet need".

241. There were a number of comments on the need to ensure that bureaucracy does not stifle the expansion of local supply chains. Issues related to the cost of accreditation for installers which can be prohibitive, particularly for small businesses or charities. This was seen as a particular problem in rural areas. For example, an energy sector respondent said they:

"would also encourage the Scottish Government to give consideration to the number of requirements placed upon the supply chain - for example, the number of accreditations they need to have and the number of different standards they need to follow. A large number of requirements can put financial pressure on the supply chain, particularly the smaller installers, and those operating in more remote areas".

242. A third sector / NGO respondent also mentioned this issue, from a charity point of view:

"We run a handyman service at South Seeds. Our handymen are skilled joiners and would be able to satisfy most accreditations for home improvement jobs. However where accreditation is costly or involves paperwork which has been developed only for private businesses, these schemes such as ECO, are prohibitive for a small charity".

243. There were also a small number of comments, from across most respondent groups, on the procurement system noting concern that many in the supply chain may not be on, or even aware of, Public Contracts Scotland. There was a suggestion that public procurement should give priority to local businesses and include requirements for training and for payment of the Living Wage.

244. There was also a suggestion that SEEP's impact on local economies should be measured and reported.

Question 18: How can communities best benefit from the expected job creation?

Summary of main themes:

• Respondents identified benefits for local areas, people and businesses as increased employment and stable jobs. Particular benefits for young people were also noted, including increased apprenticeship opportunities.
• Respondents also commented on the knock-on effects from these benefits for the local community, including increased spending power and increased tax revenues.

245. 52 respondents, across most respondent groups, commented at this question.

246. The main theme to emerge, in several responses across most groups, related to the benefits for local areas, people and businesses of increased employment and stable jobs. Respondents suggested that this would include not only installation jobs but also adviser roles and on-going jobs in maintenance. This example came from the energy industry:

"A number of studies have shown that investing in energy efficiency has created jobs and, where schemes are designed to include quality training, this has also led to increased skill levels for the worker. This creates new opportunities for employment by giving people transferrable skills that are desirable both within and across communities. This is a valuable benefit, especially in areas of high unemployment that have seen traditional employment opportunities decline".

247. Allied to this, smaller numbers commented on economic benefits including increased spending power and increased tax revenues that would result from an increase in local jobs and the use of local businesses. One local government respondent also commented that the use of local businesses would also lead to lower costs. One respondent, from the building / installation group, also highlighted the increased economic benefits that would arise from the use of locally sourced or produced materials such as masonry, cement, concrete or aggregate.

248. Respondents from the building / insulations, local government and third sector groups commented on benefits for the local workforce, and in particular for young people that would arise through increased apprenticeships and work opportunities. A third sector respondent further commented that increased work opportunities would result in people who might otherwise have to leave to seek work, being able to stay in their own community.

249. A number of respondents, from various groups, pointed out that the use of local companies would help to develop a local skills base. There were, however, several comments on the need for adequate support and funding to enable and support local businesses to retrain or upskill their workers.

250. There were also some comments on the need to ensure that SEEP maximises the involvement of community groups. Respondents mentioned the benefits of providing advice and support locally. A small number gave examples of existing community groups that have been providing energy advice and energy efficiency advice including Greener Kirkcaldy and the South Seeds community group in Glasgow. There were also references to findings in the Scottish Fuel Poverty Strategic Working Group report on the wider benefits provided by locally-based services.

251. Respondents from several respondent groups said that SEEP should include community benefit clauses and that SEEP should have a clear objective to create and sustain local jobs. A small number of respondents suggested that SEEP should specify the use of local labour through procurement contracts and that there should be a requirement to pay the Living Wage.

Question 19: What provision could be made at a national level to ensure companies increase the capacity of the supply chain across all of Scotland to support local delivery of SEEP, particularly in the rural and remote areas?

Summary of main themes:

• The need for long term programming and funding was suggested as being required to provide certainty and market confidence to invest in training and skills.
• The need for clear targets to provide certainty and market confidence.
• The challenge of gaining accreditation, particularly for small companies, was highlighted by respondents.

252. 45 respondents, from across respondent groups, commented.

253. Several respondents reiterated or expanded on their answers to question 17, in particular the need for long term programming and funding and for clear targets to provide certainty and market confidence. For example; "Longer term funding will provide local companies with the confidence to invest in training, skills, and resources to deliver energy efficiency measures" (local government).

254. Particular concerns for remote and rural areas, raised by small numbers of respondents, included:

• The availability of skills, both in relation to installation but also procurement.
• The need for local training and apprenticeships.
• The need for funding to be targeted directly at remote and rural areas.
• The cost of transporting materials to remote and rural areas.

255. There were also comments, again from a small number of respondents, about the limited size of most local companies, which means they find it more difficult to afford the accreditations required or to be able to deal with the administrative requirements or accreditation. One housing respondent suggested:

"If the administrative burden associated with achieving the accreditation currently being required to carry out work within existing national energy efficiency programmes could be lifted/done away with entirely, the type of one-man/two-man operations that operate in the islands could sign up. The creation of an 'umbrella' organisation to sign off works and ensure standards would seem to be a logical solution, freeing up workers to work."

256. Respondents from the third sector / NGO and building / installation groups called for a skills development strategy which would include training and apprenticeships.

Question 20: What do companies need to do to increase their skills base to deliver a programme of this nature?

Summary of main themes:

• The need for certainty was reiterated by respondents, noting that companies may not be keen to invest in training without it.
• Respondents noted the need to involve the appropriate professional bodies in the design and delivery of training courses as well as in the design and oversight of SEEP.

257. 44 respondents, from across respondent groups, commented on this question.

258. Several respondents reiterated factors mentioned at the previous questions, in particular certainty and funding, with comments that companies may not be keen to invest in training without the certainty of work.

259. One theme emerging at this question, from a small number of respondents, involved the need to ensure that the appropriate professional bodies are involved in the design and delivery of training courses as well as the design and oversight of SEEP.

260. Specific requirements for companies, mentioned by small numbers, included:

• Support to identify skills gaps and to access appropriate accredited training.
• Local training, including upskilling courses.
• Mentoring / opportunities to share skills and knowledge.
• Access to apprenticeships.
• The need to increase awareness of the funding available for skills and training.

261. A small number raised a concern over system-specific training, including:

"concerns have been raised about the amount of training that is being supplied by system manufacturers. The main issue here is that the training is systems based and not house based. In other words installers are trained on how to install a product without sufficient attention being given to the suitability of that product to particular building types" (third sector / NGO).

The nature of programme delivery

Question 21: What roles should national and local bodies play respectively in delivering SEEP and how can national and local schemes best be designed to work together towards meeting the Programme's objectives?

Summary of main themes:

• The need for a national scheme, with national leadership, promotion, targets, milestones and timescales, to be delivered locally.
• Potential resource implications for local authorities were noted by respondents, who suggested there may be a need to support in terms of resources and capacity building.

262. 64 respondents, across groups, commented and many of the comments reflect those seen at previous questions.

263. The main theme, seen in many responses, was the need for a national scheme, with national leadership, promotion, targets, milestones and timescales, to be delivered locally. Several respondents stressed the need for local schemes to reflect local needs, while delivering overall SEEP targets. An energy industry respondent commented that: "The implementation and enforcement of the LHEES framework will provide a suitable vehicle to coordinate local action".

264. There were again comments, from the building / insulation and energy industry, that national policy and commitment is required to provide long term certainty and so instil confidence and attract investment.

265. Smaller numbers commented on the need for collaboration, close working and sharing best practice, both between national bodies, local authorities and local bodies.

266. There were also comments, again from smaller numbers across various groups, on resource implications for local authorities in delivering SEEP. Respondents suggested that support for local authorities in terms of funding, resources and capacity building would be needed. This might include ring-fenced financial support for delivering SEEP, support for upskilling or the pooling of expertise to support smaller local authorities that may not have expertise in procurement for energy efficiency services. This could be facilitated by joint working.

267. Targets were also mentioned and comments included the need for targets and milestones to be realistic and achievable. There were also comments on the need for consistency across the UK, in terms of timescales for meeting targets. Another comment in relation to cross-border issues, from a respondent in the energy sector, was the need to minimise differences between the schemes in Scotland, England and Wales, particularly in relation to administration and reporting arrangements, in order to minimise the costs to suppliers and not impact on their competitiveness.

268. Other themes, each from small numbers of responses, included:

• The need to build on local initiatives that are already working successfully, a partnership between a housing association and Warmworks was given as an example.
• The need to build on the experiences and successes of the HEEPS: ABS.
• The need to gather and use data on the difference that measures have made, rather than simply numbers or modelled data.
• The need to ensure that SEEP is integrated with other strategies.

Question 22: What are your views on the relative benefits of area-based schemes as against those targeted at particular sectors or tenures in delivering SEEP? What other targeting approaches might be effective?

Summary of main themes:

• That area based schemes have been shown to work successfully. The success of the Home Energy Efficiency Programmes for Scotland: Area Based Schemes has been noted by respondents in comments on a number of questions.
• However, there were mixed views on the relative benefits of area-based schemes versus targeted schemes, with several respondents suggesting that a combined approach would be needed.

269. 62 respondents across groups commented.

270. The main view expressed was that area based schemes have been shown to work successfully.

271. Many respondents, across groups, supported the use of area based schemes; however there were several others, again from various groups, who felt that a combined approach would be needed. Typical comments included:

"[The respondent] would strongly support a move to concentrate SEEP on area based capital projects which can have a greater accumulative impact on the local community and local economy. Area Base Scheme delivers against a number of Scottish Government priorities, including tackling poverty and fuel poverty, reaching vulnerable groups such as the elderly and those in poorly performing private rented accommodation" (building / insulation).

"Again a good mix of area and tenures is essential. As carrots and sticks tend to work differently for these sectors e.g. what motivates a landlord will be different to what motivates a tenant, or a home owner or business owner. So it is right to identify them all into the correct pots, and have the correct drivers to enable Scotland to get energy efficiency on the agenda for all of them" (academia / research / training).

272. Comments on area based schemes, each from fairly small numbers, included:

• That these have been relatively small scale and often focused on a single type of property; however, some respondents felt that these could be expanded to suit other tenures and sectors.
• That area based schemes are cost effective and allow for economies of scale.
• That any expanded area based scheme would need to include a degree of flexibility in the funding model to allow for any different approaches required for different types of property.
• That any area based scheme must focus on households where there is greatest need; some suggested that present schemes have allowed suppliers to target the 'low hanging fruit'.
• There were also comments on the need to consider remote and rural areas; with concerns that some remote areas are being left out.
• The need for better data sharing between all relevant sectors (including health and the third sector) to ensure all relevant data on the needs of vulnerable households are included.

273. Comments from those who felt a mix would be more effective, again each given by small numbers, included:

• That solutions should be based on needs and circumstances.
• That a sector led approach would be more suitable for non-domestic buildings.
• That area based schemes may not be best suited for all technologies, with some being better delivered through targeting sectors or tenures. Others thought guidance should be technology neutral.

274. There was also a comment that as neither a full area based scheme nor a sector based scheme has been tried, it may be best to undertake a pilot and base the approach on the findings.

Question 23: How best can we align nationally set standards with local, area-based delivery?

Summary of main themes:

• Respondents agree that standards should be set nationally but delivered locally, akin to those seen in HEEPS.
• National oversight across a range of areas including guidance, targets etc. was suggested as a means of achieving consistency, but there should be some flexibility to design schemes to suit local areas.

275. 46 respondents answered this question.

276. Most respondents, across groups, agreed that standards should be set nationally but delivered locally, akin to those seen in HEEPS.

277. Several of these respondents made specific suggestions and the main themes to emerge from these, each from small numbers, included:

• The need for a nationally agreed framework and timetable; a third sector / NGO respondent said: "We believe the best approach is for small-scale solutions within a large-scale framework".
• The need for nationally agreed standards, but local authorities should have responsibility for ensuring buildings within each of their own areas meet these standards. This would provide consistency for all homes but allow for flexibility to design programmes suited to regions.
• The need for nationally agreed standards and accreditations for installers
• The need for guidance and resources and support for local authorities for target setting.
• That local targets should be expressed in the same terms and format as national targets.
• That local targets should be evidence-based and robust and should align with national targets and priorities.
• The need for guidance and standards to ensure local strategies and programmes are consistent in format across all local authorities.
• The need for national oversight to ensure that local contributions deliver the national targets.

The balance between local and national responsibilities

Question 24: What should the overall balance be between national and local target setting? Should local authorities set local targets with the flexibility to determine whatever methods they want to meet the Programme vision? Or should there be a greater degree of setting the target(s) and delivery methods by national government?

Summary of main themes:

• Respondents commented on the need for a national scheme, with national targets, but for it to be delivered locally with local flexibility in order to meet local needs.
• Respondents also commented on the need for measures suitable to each area, although there was some concern that this could lead to a confusing, inconsistent landscape.

278. 55 respondents, across groups, commented with many reiterating points already seen at previous questions.

279. The main theme to emerge, in many responses across most groups, was the need for a national scheme, with national targets, to be delivered locally with local flexibility in order to meet local needs, for example:

"Responsibility for target setting should be shared between national and local government. Climate change targets may be set nationally but local targets need to be achievable and recognise local differences, such as rural areas etc." (local government).

280. Respondents said that allowing local authorities this flexibility would enable them to deliver in a way best suited to the local conditions, building stock and residents.

281. The following example of this type of comment comes from an energy industry respondent: "There needs to be some local flexibility to be able to adapt delivery targets and methods, which gives local authorities some control over their own projects, but these programmes must fit in with the national strategic aims and targets".

282. The need for measures suitable to each area was mentioned in several responses. However, respondents also wanted to ensure that this did not lead to a confusing, inconsistent landscape. There were comments on the need for national oversight to ensure that each local authority is delivering in a way that both meets its own targets and the national targets:

"we agree that SEEP should have an overarching vision underpinned by targets and milestones. Local authorities should have the flexibility to set their own targets to contribute to the national target. The performance of local authorities will need to be monitored by the Scottish Government or through a dedicated body established to oversee SEEP." (housing)

283. A smaller number of respondents commented on the need for national co-ordination, funding and opportunities for sharing good practice.

Question 25: What would a good governance structure to oversee any framework of responsibilities between national and local government look like? What examples are you aware of within the UK or elsewhere?

Summary of main themes:

• Many respondents agreed that there is a need for an independent national body with responsibility for strategic oversight and delivery.
• Respondents wanted to see better systems or methods of review introduced in order to support governance, with comments that these should be based on outcomes rather than outputs.

284. 32 respondents, across groups, commented.

285. There were several calls, from respondents in various groups, for an independent national body with responsibility for strategic oversight and delivery. Smaller numbers suggested ministerial oversight, or joint ministerial / COSLA oversight.

286. Other, single, suggestions included:

• A national energy agency, such as exists in Denmark.
• A governance structure such as that which exists in education.
• The Regeneration Capital Grant Fund ( RCGF) was cited as an example of good governance in the distribution of a large capital funding.
• The Energy Start suite delivered by the US Environmental Protection Agency.

287. A small number, from housing and the third sector / NGO groups, wanted to see "a new strategic group should oversee the development of schemes but give equal emphasis to the delivery of positive affordable warmth and health outcomes over carbon and energy saving priorities".

288. In order to support governance, respondents wanted to see better systems or methods of review introduced, commenting that these should be based on outcomes rather than outputs.

289. Other suggestions to support governance, from small numbers, included the need for :

• The process to begin by defining what the governance is intended to achieve and how this will be monitored and measured.
• Strategic partnerships established at an early stage.
• Clear lines of accountability, both nationally and locally.
• Capacity and expertise at both national and local level.
• Clear guidance, methodologies, standards and enforcement.
• Sharing best practice.
• Engagement with appropriate professional bodies; that the governance structure should include representation from industry.

290. A small number, from local government, again suggested that experiences from HEEPS, where there are good links between local authorities and the SG, should be built upon.

Monitoring and review

Question 26: What should be included in a monitoring framework to ensure that the Programme is effectively monitored and evaluated?

Summary of main themes:

• The need for real, rather than modelled data, to be used as part of a monitoring framework to ensure that the Programme is effectively monitored and evaluated.
• Respondents noted that in the past schemes have not been evaluated and that on-going monitoring should be a part of SEEP to inform and improve its delivery.

291. 52 respondents, again from across respondent groups, commented.

292. A number of respondents commented that previous or current schemes have not been evaluated, or not evaluated effectively, and some stressed the need for effective and on-going monitoring of SEEP to inform and improve its delivery.

293. Several respondents, across groups, commented on the need for current data and for data collection and that this should be 'real world' rather than modelled data. A small number suggested that a baseline would need to be established against which to monitor. Examples of comments included the following, from local government:

"A baseline for each local authority would be required, using currently available EPC data and acknowledging where data is missing. A form of benchmarking would be useful, to evaluate performance fairly".

"Having before-and-after data would be ideal and a standard kit for collecting this information could be made available in order to accomplish this (such as the BRE/ SU monitor) and if procurement arrangements were made for this a level of consistency could be applied to the data that can then be gathered on a web portal with local pages for reporting".

294. Suggestions, from small numbers, included:

• The need to monitor progress against targets at national and local level.
• The need for the framework to be structured to allow for comparisons across local authority areas, as well as within areas so that remote and rural areas can be monitored.
• That measurement should be based on outcomes and not just outputs.
• That monitoring should also seek to understand the impact of interventions, including health and local economies.
• That the provision of evidence will help secure future investment.
• That there should be clear reporting criteria.

295. There were many different suggestions for factors that should be included. These included: improvements to building stock; the number of advice enquires received; saving on fuel bills; quality; progress towards elimination of fuel poverty; and the impact on carbon emissions, amongst many others.

Additional Comments

Other comments

Question 27: We would welcome feedback and expertise on any other issues in relation to SEEP that aren't covered by the questions above.

296. 67 respondents provided other comments.

297. A number of respondents offered to provide further assistance, advice or asked to be involved in the next stages. There was an acknowledgement of the scale of the task in successfully delivering SEEP.

298. Other respondents provided additional information, such as background information or added their thanks for the opportunity to comment. A number of respondents provided industry-specific or business-specific information in support of their responses.

299. Additional points, that have not been addressed elsewhere, that emerged from the other comments provided by respondents included:

• The need for more detail on budget allocation, timeframe, total budget, forecast costs and benefits to consumers.
• The need for more assessment and detail on the legislative provisions that will be required to meet SEEP objectives.
• The need for ongoing stakeholder involvement in the development of SEEP.
• The need for SEEP to work closely with existing community organisations.
• The need for an affordable energy policy.