Ending the need for food banks - draft plan: consultation analysis

Findings

Question 1 - approach

Do you think that the approach outlined is consistent with the vision to end poverty and the need for food banks? Is there anything else you think should be included?

Overview of responses

Many of the respondents agreed that the need for food banks is primarily a reflection of poverty and that they are not a suitable or long-term response to poverty; and agreed with the prevention and response approach set out in the Draft plan.

A few of the respondents disagreed that the approach is consistent with the vision set out in the Draft plan. Typically, this was because they do not think the policies described are sufficient to end poverty.

A few of the respondents said they were unsure that the approach is consistent with the vision on poverty.

Table 4: Question 1, by respondent category (number of responses)

	Yes	No	Don't know
Individuals	113	30	16
Organisations	111	21	7
Food aid provider	27	6	4
Community organisation	26	8	-
Campaigning organisation	25	6	1
Local authority	9	-	1
Money advice provider	7	-	-
Other	17	1	1
Total*	224	51	23

*Note: There is a total of 116 food aid providers. 77 were the campaign responses. They did not respond to the closed questions. Base = 298

Overall approach

Generally, there was support for the vision set out in the Draft plan, with many welcoming Scottish Government's commitment to ending the need for food banks, aligned with a wider commitment to a human rights approach and ending poverty.

Respondents generally agreed that household food insecurity is caused by people not having enough money to afford food. There was some difference of opinion on what contributed to or caused this lack of money. For some, the main causes were external due to lack of adequate income or social security payments, precarious work and rising living costs. The dual approach to preventing and responding to hardship was welcomed by these respondents. Key solutions related to fair wages, quality employment, and entitlements, cash-first initiatives, and holistic support delivered through effective referral pathways. The importance of ensuring emergency support remains available for those who need it was stressed and, critically, that this support is rooted in the values of dignity and respect.

A few respondents commented that reliance on food aid as a response to poverty has become increasingly accepted and normalised; and welcomed the measures to address this. One respondent noted that that there is now a range of alternative food providers, including social supermarkets, food pantries, larders. They commented that whilst providing more choice and dignity than food banks, not all of these models are sustainable and they could not or should not be extended, because they rely on volunteers, the ongoing supply of surplus food and they have a limited reach to those experiencing food insecurity.

One respondent commented some food aid providers are finding it more difficult to source food as prices increase; indicating that they may start to struggle to respond during the cost of living crisis.

A few respondents identified personal reasons for poverty, such as lack of poor homemaking skills (budgeting, cooking), addictions, chaotic lifestyles, and so on. Respondents suggested that community support/education (including support into employment/housing) where appropriate would be of assistance, with food aid provided in emergency. These respondents did not generally support cash payments, they were concerned people would use this to buy unhealthy food or non-essentials.

"I haven't needed to use the food bank, but I do volunteer at one. Although most people using the bank appreciate the help, some people think they have a right to use it (as if it is one of their benefits) and forget the foods are donations. Financial advice would be useful, but when it comes down to it, people can use their money in whatever way they want." [Campaigning Organisation]

Specific issues raised

Positive issues: Respondents agreed that food insecurity must be addressed as part of wider action on poverty, with prevention and early intervention key to success.

"If people don't need to come to food banks, they won't come to food banks, but this must be addressed in the wider context of social circumstance and a joined-up approach to reducing harmful behaviours and drug deaths and making sure everyone has access to decent and affordable housing. Food banks should not be targeted in isolation from other measures to improve life circumstances." [Campaigning Organisation]

Respondents were supportive of the holistic approach underpinning the plan: action to increase incomes from fair work and social security; accessible support when required; and access to emergency food where needed.

"Increasing people's incomes on a sustained basis, presents a more rights-based approach to food insecurity than ongoing and increasingly institutionalised reliance on emergency food bank provision." [Other Organisation]

Negative issues: There were a few respondents who commented on the scale of the task, and who had concerns about capacity and/or resources to effect the changes demanded. Some of the respondents commented that the vision set out in the Draft plan would require systemic changes in Scottish economic policy and/or government policy and practice.

A few respondents commented that they were skeptical that Scottish Government would be able to achieve the objective with respect to ending the need for food banks as a primary response to food insecurity. A few others commented that a (clear) timeline setting out the actions was required, and clearly earmarked resources to underpin the changes were crucial in giving stakeholders confidence in the vision.

"To bring about the proposed changes a monumental shift in the organisation of local and national government would have to take place. To enable local authorities to be able to respond in a timely fashion, to ever changing needs within the community they operate there would need to be a significant investment in financial and practical resources. Food banks have responded to the local need and have adapted to the changing environment by being autonomous and able to be flexible in their approach to client needs. This was evidenced particularly during the Covid pandemic when most statutory organisations closed their doors to the public, but food banks did the opposite and reached out in the local community." [Food Bank Aid Providers]

"It's all just generic statements? There doesn't seem to be any substantive actions as such; just a wish list… Not meaning to sound negative. Anything is progress. But the situation on the ground is way past the time for strategies. It is .... desperate..." [Individual]

A few respondents commented that the Draft plan either lacked ambition, or that the direction of the Draft plan was misdirected: the food banks in themselves were not the problem, and the government should be focused on addressing poverty. Many of these respondents stated that action on poverty was required quickly:

"People living in poverty now cannot afford to wait; commitments need to be matched with bold action. We need transformative policy change, in the short, medium, and long term, if we are to achieve the vision of a Scotland where no one needs to access charitable food aid." [Campaigning Organisation]

Benefits of food banks and other direct food providers: While most respondents supported the ambition to end the need for food banks; a few respondents commented they did not consider food banks a 'problem' to be resolved, but a valid community response to a very real problem that is not being, and probably could not be, addressed by anyone else.

"As a food bank we would be delighted to not be needed. We very much acknowledge we are a sticking plaster for a much deeper wound. However, we see clients weekly who are being let down by overstretched and understaffed services and they need a food parcel until they can get the support required from other third sector or public sector services." [Food Aid Providers]

A few respondents commented that the broader societal roles performed by food banks should be acknowledged: they provide an opportunity for social interaction and a chance to discuss recipes, as well as a referral pathway to access holistic advice and support services.

One respondent commented that as well as benefiting users, food banks benefited volunteers and the local communities:

"The establishment of local food banks by local people for local people has empowered local people to take initiative within their own community. It has given an opportunity for local people to support and help each other and has given them an opportunity to learn new skills and gives a sense of achievement…. The support extends beyond food support but offers a listening ear and empathy and supports people with mental health issues." [Food Aid Providers]

A few respondents commented that there may be a continuing role for food banks, or some other form of food aid provider, to provide aid in emergencies.

People with no recourse to public funds (NRPF): Some respondents highlighted the potential limitations of the approach for refugees who have NRPF. Many of the responses that underpin the cash-first approach, in particular income-strengthening (wages, entitlements, etc.) and cash payments, are not available to people with NRPF without jeopardising their immigration status, while they can access food parcels.

Welfare advice: A few respondents commented that adequately funding effective welfare advice and support would be essential. One respondent (a large local authority), said it was vital that high quality welfare and debt advice is available in local communities, delivered in ways and places that people trust. They commented that the authority is currently struggling to recruit suitably qualified advice workers to meet the increased demand for services arising from the current cost of living crisis.

"It is vital that people giving advice are skilled and accredited – incorrect advice can have major consequences for people. To ensure consistent quality of advice, local and national plans should consider introducing requirements for welfare rights and debt advisors to be registered to agreed standards, with mechanisms to ensure that there is sufficient capacity for quality assurance. National planning should also recognise that such recommendations would have further additional resource consequences for local partners." [Local Authority]

Definitions: A few respondents suggested that a clearer definition of food bank was needed, and that food banks should be distinguished from community food initiatives such as larders, pantries, fridges, co-ops; which have broader objectives around the quality of and the way that food is produced, the environment, and the local community. Related to this, another commented that it is important to assess the impact of measures to end the need for food banks on the use of other food initiatives, including emergency options such 'soup kitchens'/community kitchens.

"Food banks differ widely in their activities and "community food projects", though often suggested to provide more choice or dignity, share many of the same features as help from food banks, namely, that they are not entitlement-based, rely on charity, and rely on surplus food, inherently restricting choice and not providing access to mainstream ways of acquiring food. Our research has highlighted an increasing appetite for low-cost community food retail models amongst community food providers. It is important to recognise that such models, whilst different from food banks, should also not become equated with the response to food insecurity." [Individual]

Question 2 - actions underway

Do you think that the actions underway will help to reduce the need for food banks as a primary response to food insecurity?

Overview of responses

Most of the respondents said they thought the actions underway would help to reduce the need for food banks. There was support for measures to increase income, especially given that people were currently facing the withdrawal of temporary Covid income supports (the universal credit uplift and furlough payments) alongside rising food, energy and housing prices.

Some of the respondents said they thought actions underway would not help, or be insufficient, to reduce the need for food banks. Key concerns were lack of resources, measures listed are often time-limited, inconsistent levels of support across the country and lack of service integration.

It is noted that even some of those who thought the actions would help, were concerned that the actions did not go far enough or that the current cost of living crisis would present significant challenges to success. One respondent commented that spending on food tends to be reduced when people experience financial difficulties, so there will be a need to increase incomes to a level that food can be afforded.

A few of the respondents said they were unsure if the measures set out in the Draft plan will help reduce the need for food banks. Some respondents were supportive of the Draft plan, together with the current and proposed initiatives. However, they did comment on the scale and complexity of task ahead, and concluded that it was impossible to say whether the measures would be sufficient.

Table 5: Question 2, by respondent category (number of responses)

	Yes	No	Don't know
Individuals	90	43	26
Organisations	90	28	25
Campaigning organisation	30	5	2
Food aid provider*	20	11	6
Community organisation	16	7	10
Local authority	7	1	1
Money advice provider	5	1	1
Other	12	3	5
Total	180	71	51

*Note: There is a total of 116 food aid providers. 77 were the campaign responses. They did not respond to the closed questions. Base = 302

Specific actions

Fair work

A few respondents agreed that measures are required to make work pay. Respondents identified zero hours contracts, insecure work, and seasonal work as key issues to be addressed, with some of these respondents suggesting zero hours contracts should be banned. In-work poverty was identified as a key issue, with a few respondents noting that they continued to encounter clients struggling to manage on their wages, and clients who would be better off on benefits.

A few respondents commented that there was a need to ensure the real living wage was being paid to workers, including young workers.

Other suggestions included

• Support to get back into work – including support and training on applying for jobs and sustaining employment.
• Support to small employers so they were encouraged and able to pay fair wages as well.

Social security

Many of the respondents commented that people used food banks because they did not have enough money; and that as well as a fair wages and a reduced cost of living, good social security was essential to ending the need for food banks. Question 4 below discusses the improvements respondents suggested to social security. General comments made about the system as is currently operates were as follows

• A few respondents commented that they greatly welcomed Scottish Government measures such as the Scottish Child Payment and the Best Start Grant. Some concerns were raised that awareness and uptake of these entitlements needed to be improved, and entitlement needed to be extended. A few respondents welcomed the bridging payments for the Scottish Child Payment which they felt was likely to improve the system for assessing eligibility and paying benefits. This is covered further under Question 4
• A few respondents welcomed the move to the new disability assistance payments. However, they stressed that the level of disability assistance would remain unchanged and expressed concern that this was insufficient to meet needs.
• A few respondents welcomed the Scottish Government's use of discretionary housing payments to mitigate the impact of the bedroom tax.
• A few respondents commented that social security entitlements were skewed towards those with children and disabilities; while single people, especially those under the age of 60, were unlikely to get support.
• A few respondents commented on the Scottish Welfare Fund. While they welcomed the support available from the fund, there were concerns about awareness of the fund, bureaucracy, waiting times, the number of applications people can make and consistency of assessing applications across the country.

"In 2020, during the pandemic, the average amount paid out in crisis grants in one local authority was £62 whilst in another it was £138 - more than twice as much. This is not a difference due to local variation in food costs but in what each local authority regard as the minimum subsistence level required." [Campaigning Organisation]

Reduced cost of living

A few respondents noted that the Draft plan acknowledges the impact of the rising cost of living on the right to food. They commented that people experiencing poverty increasingly have to choose between compromising on food or other essentials, such as heat or rent. However, they raised concerns that the current cost of living crisis will continue to push more people into poverty.

"We recognise that a lot of the more structural solutions to these issues currently lie outwith the scope of Scottish Government powers, but unless these issues are addressed seriously it's hard to see the demand for our emergency food provision reducing, let alone ending, in the next few years." [Community Organisation]

A few respondents commented on measures that have already been put in place to help reduce the cost of living, including funded early learning and childcare, the introduction of national money advice services, and the commitment to the expansion of eligibility to free school meals for all primary school age children. There was a view that these measures will undoubtedly have a positive impact, although as noted above, the rising inflation rate will impact on the effect such measures can have.

A few respondents commented that lack of childcare was a key barrier to paid work for lone parents; and suggested that funded childcare hours should be increased, with one suggesting 50 hours funded childcare per week.

Scottish Welfare Fund (SWF)

A few respondents agreed the SWF would continue to play a key role in making cash payments going forward. Several highlighted the importance of ensuring the Fund was adequately resourced for this task. A small number of respondents commented that SWF applications should be assessed consistently across the country; one respondent suggested there was a need for clear guidance for local authority decision-makers, particularly on the number of applications that can be made for crisis grants. Linked to this, respondents mentioned that it was important that sufficient resources were allocated to administering the Fund effectively: developing guidance, promotion to potential recipients, staff training, and so on.

Respondents also commented on how the Fund would operate. Issues raised included:

• There is a need to look at how the SWF can support more people through the benefit gap, as they wait for benefit payments to kick in.
• Quick decisions on SWF decisions are crucial in reducing the need for emergency food aid.

Debt and welfare advice

Respondents commented on the measures related to money advice:

• Some welcomed measures to provide information on entitlements in an inclusive way and to improve access and embedding services within a wide variety of local community settings, including GPs surgeries. One respondent suggested these should be targeted in areas of highest levels of poverty.
• Some welcomed the 'no wrong-door approach' to welfare advice.
• One respondent suggested building on the positive experience of using telephone and digital advice services to increase access to services.
• One respondent commented the term 'money advice' can be confusing, with some people thinking it relates to investment planning/asset management. They suggested 'debt advice' and 'welfare rights' are better understood by clients.

Maximising take-up

Some respondents commented that measures were needed to improve benefit take-up: with one respondent saying that take-up of Scottish Child Payment was especially low.

Information about social security and wider support services and how to access them needs to be made available and accessible to everyone. Respondents stressed that information should not rely on digital access, and should be clear, simple and easy to navigate.

"Have more information in a lot more areas, and then hopefully, more people will see it and be less fearful of being stigmatised, by asking for help." [Individual]

"Services need to be proactive at targeting and engaging people experiencing or at risk of food insecurity as some are reluctant to seek help. Signposting and leaflets are insufficient actions. Referrals needs to be proactive, consistent and followed up, which will require consent from the person concerned." [Other Organisation]

"I have found during my own struggles with unemployment due to severe ill health and financial hardship that… if you don't know the system or you are experiencing the whole process for the first time you wouldn't actually know what help is available to you or where you can access it." [Individual]

A few respondents mentioned taking further actions to ensure clients received all the benefits they are entitled to. A particular issue mentioned was ensuring that people with disabilities received their entitlements. For example, one respondent suggested offering people the choice to have their Adult Disability Payments consultation recorded. It was anticipated this would safeguard the accuracy of those consultations and avoid errors or mistakes being made which risk wrongly denying people their payments.

A few respondents stressed the need for support services to accessible and delivered locally. It was suggested that services might be encouraged to co-locate, making it easier for users to access entitlements, support services as well affordable food schemes like pantries, food clubs, and social supermarkets.

Cash-first referral leaflets

There was support for the referral leaflets. Respondents commented that a key barrier to accessing support, services and entitlements was lack of awareness and considered the leaflets play an important step in addressing this.

A few respondents suggested that further translation into languages commonly used in Scotland would help to increase access.

A few respondents stressed that the leaflets in and of themselves were not enough, there needed to be a robust local support infrastructure to support those needing advice and assistance and, critically, people needed to be able to access advice and funds quickly.

"The cash-first approach proposed by the Trussell Trust, the Independent Food Aid Network and others is entirely the right way to go, however it is obviously not enough to simply distribute leaflets. There also needs to be sufficient funds to ensure everyone has enough income to pay for day to day living expenses and avoid having to access emergency food aid." [Money Advice Providers]

Right to food

Some of the respondents commented specifically that they support the human rights approach in the Draft plan; and agree that the Right to Food should be incorporated into Scots Law.

A few respondents commented that it was essential the Right to Food was actioned: for people in the community, it was changes on the ground that really mattered. One respondent commented that the Right to Food should be at the centre of a national action plan, including measures to ensure that food is available, accessible, and adequate for all.

A few respondents also commented that they supported the measures set out in the Good Food Nation, with one suggesting that greater prominence could be given to the Good Food Nation actions in the Draft plan.

A few respondents commented on the dignity principles set out in the Government's Independent Working Group Dignity Report. A few respondents commented that the lack of culturally appropriate, healthy and fresh food from food banks undermined dignity principles, with several specifically referencing reliance on surplus food in this regard. One respondent commented that reaching consensus on how to implement 'dignity' can be challenging for those working on the frontline.

Specific actions required for target and at risk groups

Many respondents welcomed the particular needs of at risk groups have been recognised in the Draft plan. In particular, respondents highlighted the mentioned the following groups:

• People with disabilities who continue to face barriers to employment, entitlements and other services
• People with addictions who will require additional support
• People with NRPF for whom cash-first and cash grants may not be appropriate
• People with mental health issues who face barriers to employment and access to other services
• People experiencing in-work poverty, including those on middle incomes who are trapped financially and have to access food banks to survive
• Asylum seekers who continue to be on extremely low incomes despite Home Office support

"The cash-first system needs to specify inclusion of those on Section 4 Home Office support who have no access to hard cash, including those on S95/98. Provision of cash would enable them to buy food from shops that sell their traditional foods as these shops do not accept Aspen cards. They should not only have food vouchers for supermarkets." [Community Organisation]

Question 3 - what more we plan to do

Do you think that the suggestions for what more we plan to do will help to reduce the need for food banks as a primary response to food insecurity?

Overview of responses

Most of the respondents said they thought the suggested actions would help to reduce the need for food banks. There was support for the cash-first approach, and respondents especially welcomed proposals for effective support pathways. However, it was appreciated that significant resources would be required to ensure these measures were effective.

Some of the respondents said they thought the planned actions would not help to reduce the need for food banks. A few said the emphasis of the actions was on vouchers, grants and exploring (that is, not implementing) a minimum income guarantee, which would not solve the underlying problem.

A few of the respondents said they were unsure if the measures set out in the Draft plan will help reduce the need for food banks. Again, respondents noted they were supportive of the Draft plan and the measures set out in it, but said it was difficult to assess impacts, especially without information on timescales and resources allocated.

Table 6: Question 3, by respondent category (number of responses)

	Yes	No	Don't know
Individuals	97	38	23
Organisations	94	24	25
Campaigning organisation	31	2	4
Food aid provider*	19	10	8
Community organisation	18	8	7
Local authority	6	1	3
Money advice provider	5	1	1
Other	15	2	2
Total	191	62	48

*Note: There is a total of 116 food aid providers. 77 were the campaign responses. They did not respond to the closed questions. Base = 301

Specific issues

Minimum Income Guarantee and Universal Basic Services

On the whole respondents welcomed the proposed minimum income guarantee, with some also specifically mentioning they welcomed proposals for universal basic services. It was appreciated that they were a longer-term objective, with food banks – or their alternatives – to be retained as a short-term emergency measure. Specific points that were raised included:

• Introducing a minimum income guarantee and universal basic services is essential, and will make an enormous impact
• The minimum income guarantee should be sufficient to cover a basic standard of living, covering essentials such as food, housing, heating and travel. A few respondents suggested that a pilot should be implemented, locally or nationally, as soon as possible
• Concerns that Scottish Government does not have the power to introduce a national minimum income guarantee.
• Concerns about the cost of introducing a minimum income guarantee and universal basic services
• Concern that the minimum income guarantee and universal basic services may not include people who are NRPF
• Concerns that bureaucracy and lack of awareness are barriers to accessing universal basic services, such as funded childcare
• One respondent asked for clarity as to whether universal basic services would include food provision, and related advice and support services

"Exploration of a minimum income guarantee is hugely promising and could be a significant step in ending the need for food banks and ensuring everyone can realise their right to a healthy life." [Campaigning Organisation]

"Exploration of a Minimum Income Guarantee and Universal Basic Services is crucial in identifying and evaluating potentially transformative and systemic responses to food insecurity. We are however concerned that the level of investment needed to ultimately eradicate poverty will be far higher than the Scottish Government anticipates, and this warrants further analysis." [Community Organisation]

Cash-first approach

Cash payments: Some respondents commented that the cash-first approach is consistent with the vision to end food banks. They said it has potential to offer a dignified response for those in need which can reduce stigma and promote choice; and is linked to income strengthening measures and referrals to other supports that aim to address drivers of poverty. A few pointed to specific benefits of cash payments, in enabling people to purchase fresh cheap raw ingredients they can cook at home and being able to buy culturally appropriate foods.

While recognising the choice and dignity advantages of cash payments, a few respondents suggested limitations with providing cash to people (as actual money or into a bank account). These included:

• Those in debt may not be able to make full use of any money paid to them
• Homeless and other at risk people are unlikely to have a bank account and may find handling cash challenging. For example, they may be subject to financial abuse.

As with the vouchers, a few respondents suggested caution when giving cash to recipients. One commented that, for many, support with budgeting will be required before cash is provided. Others suggested that advice and support on healthy eating and cooking skills would be required if people are to be able to feed themselves and their family.

However, respondents were more likely to point to the benefits of cash payments: choice, flexibility, dignity. Some of these respondents commented that experience during the pandemic showed that cash payments worked well.

"The pandemic has demonstrated that a cash-first approach is effective. When schools closed at the beginning of the pandemic, alternatives to free school meals were provided via meal replacements, cash replacements or food vouchers. The availability of direct payments and the value of substitution varied across local authorities (from £10-20) per week. Take-up by parents increased if provision was via a cash payment. Families experiencing food insecurity should have choice in how their needs are best met, to deliver better results." [Campaigning Organisation]

"Making attendance at the Nourish Scotland and Dignity Truth Community workshops a compulsory training event for all local authority and volunteer staff who are providing food support in communities would tackle negative views about people who do need to access food provisions. Third sector organisations tend to have a good understanding of issues, dignity, human rights, and are capable of administering the cash-first approach positively." [Campaigning Organisation]

A few respondents asked for further clarification on how charitable cash payments would work. One commented that there was scope for abuse if "you are known as charity giving out money". [Community Organisation]

Cash-first pathways: A few respondents commented on the development of the cash-first approach. Most of these were broadly in favour but noted that significant resources were required to develop the services that underpin the approach.

One respondent commented that they anticipated resistance to this approach (that is, providing advice, not just a food parcel) from organisations/staff/volunteers working at the frontline, whose focus will be on providing immediate assistance for people in crisis.

A few respondents specifically requested clarity around the role of the measures listed in the Draft plan. In particular, that shopping cards will serve as a crisis response, alongside measures such as the Scottish Welfare Fund; and that shopping cards/vouchers will not replace cash-first options.

"Cash-first: we need a Road Map." [Campaigning Organisation]

Cash-first partnerships: A few respondents commented on the development of cash-first partnerships and were generally supportive of the approach. However, they were mindful of the task ahead and the level of planning and resource that would be required in order to be successful. Key points raised were:

• Given the scale of the task, it is critical that the partnerships are adequately resourced.
• In particular, local authorities will need to be properly funded.
• A seamless support system will need to be built across Scotland to ensure that everyone gets the right support, at the right time, in the right place.
• The 'Worrying about money?' leaflets are a valuable resource for food banks, larders and other support organisations.

One respondent [CoSLA] commented that a great deal of work had already been done during the pandemic to develop processes and platforms to facilitate local partnership working across the public and third sectors, both at national and local level. It was suggested that work be undertaken to explore how this could be built on, rather than create new processes.

Shopping vouchers

There were mixed views on the introduction of shopping vouchers.

Some of the respondents commented that they supported vouchers/cards. At a minimum they were considered a reasonable short-term alternative to food banks, offering more choice and flexibility to the users, and a step towards a cash-first approach.

"People feel undignified using food banks and being able to get a voucher to get food is a much better option. I have children with learning difficulties and eating disorders and there is rarely anything in a food bank parcel that caters for their needs. Going to a shop would mean getting stuff for everyone and with a much longer shelf life than the food parcel." [Individual]

A few said that vouchers offered an advantage over cash payments: controls could be placed over the types of goods purchased, to ensure that the vouchers were not used to buy items considered undesirable or non-essential One respondent commented that vulnerable recipients were at risk of having cash taken from them and felt that vouchers could be a safer option.

Respondents in favour of vouchers generally stressed that measures should be taken so that the vouchers do not stigmatise the recipient; they suggested that vouchers/cards should resemble 'gift vouchers', or be delivered as an app, or as some form of bank card.

"A supermarket card would give them [people in need] immediate access to obtain what they need in a way that does not make them different from any other shopper." [Individual]

There were some comments specifically relating to how 'vouchers', if used, should be implemented. Suggestions included:

• They should be non-transferable.
• A pre-charged card would be preferable, as it would be less obvious when used in a shop, it would also be more appropriate for people who do not have a bank account.
• Need to ensure that affordable food is available locally – so that the value of vouchers is not eroded by having to travel to supermarkets. Applies especially, but not exclusively, to rural areas.
• Ensure cards/vouchers are accepted in small, independent stores, including African/Asian stores, so that food available is culturally appropriate.
• A few suggested they should only be used for food/essentials.

A few suggested that community organisations may be better at administering the voucher scheme than the agency referring to the food bank, with one organisation commenting they are "usually better at providing a dignified, person-centred approach". However, it was felt that local organisations would require resourcing and support to fulfill this role. Some thought a limited number of agencies administering, or just the agencies that refer to food banks would be more effective. One suggested that people should not need to be referred to receive vouchers (in the way that some food banks accept people without referrals).

Rural areas: A few respondents commented on the practical issues associated with delivering a voucher approach in rural areas:

• Local Citizen Advice Bureau / community organisations administering the scheme will require resources to support outreach services for people unable to travel to their local office.
• Supermarkets/other sources of good quality reasonably priced food needs to be accessible.

Some of these respondents suggested that other alternatives such as direct payments might need to be considered, although cash payments do not resolve issues relating to food accessibility.

"Please bear in mind not everyone has access to large supermarkets. Some villages have no local shop, and some have only a small independent shop which is usually more expensive than large supermarkets and therefore users will have a more limited choice and get less for their vouchers." [Individual]

Voucher pilot: There were some comments around administration of the pilot. A few suggested that it would be beneficial to include organisations in addition to CABx in the voucher pilot. This would enable the experience and expertise of groups working with specialist groups, e.g. people with NRPF to also be captured.

Do not support vouchers: A few respondents did not support the use of vouchers/cards; some saw them as an unnecessary transition, some suggested they could lead to stigma for people needing to access support; they would restrict choice; and cannot be used to address non-food needs, such as energy, housing, cooking equipment. They commented that the crucial actions required were to maximise incomes, enable people to access support when they need it, and to access cash grants in a crisis.

"We would caution against replacing food bank referrals with supermarket vouchers. This approach fails to tackle the root of the issue, which is people not having enough money. Vouchers do not end food insecurity. We need to take a no wrong door approach to the delivery of advice services, to stop people falling through the gaps and ensure everyone gets the right support at the right time." [Food Aid Providers]

Other negative views include:

• A few respondents consider there will continue to be a place for food banks alongside vouchers/cash-first.
• Concerns that shopping vouchers are a quick fix: while they offer more dignified support than food parcels by offering users some choice in the goods purchased, they only replace food parcels rather than solve the underlying problems.
• Concerns that the proposed shift away from food banks/parcels to vouchers will enable people to sell their vouchers on for cash, and use the proceeds used to buy 'non-essentials'.
• One respondent [CoSLA] commented that vouchers were used in the trial on SWF and, as well potentially stigmatising service users, the approach received criticism from local authorities because it increased the administrative burden placed on them.

A few respondents were concerned with the ethics of vouchers. Points raised by respondents included: food vouchers should not increase profits of large supermarkets; where feasible vouchers should be used to support local businesses; vouchers should only be used in businesses that pay the Real Living Wage.

Holistic support

Respondents agreed it was vital that holistic advice and support was available to ensure people have the information they need to maximise entitlements and move away from poverty. It was suggested that the food banks plan could promote a national approach to minimise regional inconsistencies in advice and service levels.

Respondents emphasised the importance of the 'no wrong door approach'. All those engaged in providing services, including those proving emergency food aid, should be a gateway to referrals, information, signposting and advice to help people move away from their crisis.

"There should be a 'no wrong door' approach so that if someone access one aspect of a of practical support, for example a food bank or a school providing food parcels, that should be the door through which a network of advice, support and service becomes available. Advice and support services need to be well resourced and easy to access to ensure that no one falls through the gaps." [Campaigning Organisation]

Respondents agreed that there was a need for comprehensive, coordinated service delivery, with an effective referrals approach. One respondent suggested that for the holistic services to be effective they need investment in staff, for example by having money advice workers in the community, so that people can access support immediately rather than needing to be signposted.

"Immediate allocation of a worker rather than having to fill in paperwork before any appointment is given would reduce barriers to engagement with services." [Local Authority]

"Services need to be proactive at targeting and engaging people experiencing or at risk of food insecurity. Signposting and leaflets are insufficient actions. Referrals needs to be proactive, consistent and followed up which will require consent from the person concerned." [Other Organisation]

Exit strategies

Some respondents said that a detailed exit strategy was required: with some of these asking where people will go for signposting, emotional and practical support, when food banks close. It was suggested that food banks could be encouraged to develop closer links/integrate with support services; and alternative models such as pantries could be adopted during the transition stage.

A few respondents requested clarity on the trajectory from food banks to cash-first, and the role that shopping vouchers/cards play in that transition.

"We have clients we have been supporting for years because the referrals agents keep on referring them week after week because there are no other options for them…. We use shopping vouchers as a type of exit strategy, moving from food parcel to weekly voucher to monthly vouchers, but it only works with other holistic support - that is very rare." [Food Bank Providers]

One respondent suggested that support for food banks to develop 'exit strategies' for people who use their services would be positive and acknowledged that for some clients - those with complex needs - this could be a slow process.

Question 4 – what more could be done

Is there anything else that you think should be done with the powers we have at a national or local level to reduce the need for food banks as a primary response to food insecurity?

Overview of responses

Generally, respondents welcomed the measures the Government has been taking, in particular the Scottish Child Payments, Best Start Grants and Discretionary Housing Payments. Respondents were concerned that, despite these measures, poverty persists. They asked for existing measures to be strengthened and rolled out further, and for the Scottish Government to be given further powers to mitigate the impacts of UK policies – in particular hardship caused for people with no recourse to public funds; the hardship caused during the 5-week wait for Universal Credit and during benefit sanctions; and the unmet needs of some at risk groups.

Specific issues

Fair work

Respondents supported raising the Living Wage, with a small number of specific points raised:

• A few respondents advocated incentives to promote the adoption of the Real Living Wage and Living Hours accreditation, with a few arguing that the Real Living Wage should be mandatory.
• A few respondents commented the Living Wage should not vary by age – there should be a single Living Wage, and young people should be paid a lower wage for doing the same job.
• One respondent commented that the Living Wage should be paid for people on training schemes, to encourage them into work.
• A few respondents suggested that Scottish Government should limit/end zero hours contracts and 'bogus self-employment' (where individuals do the same work as formal employees but have a self-employed status), and limit agency work, as these mean people have very little job security, resulting in precarious financial conditions.
• One respondent suggested language and literacy support as a first step into employability.

Social security

Some respondents commented that access to the right entitlements, quickly and easily was critical in addressing food insecurity. A series of specific suggestions were made including:

• Scottish Child Payment (SCP): Promote the SCP to increase take-up among those who are currently eligible; make it easier to access, including consideration of automated payments. welcomed the doubling of the SCP, continue to uprate in line with inflation, with a few suggesting further significant increases (to £40); extend eligibility of SCP to older children
• Best Start: Measures to increase up-take of Best Start Grants/Foods, including improved promotion. Respondents also suggested increasing the Best Start Grant, then continuing to uprate it in line with inflation; and considering making the Best Start Grant universal.
• Automatic registration: To be scaled-up as quickly as possible to ensure people are in full receipt of their statutory entitlement to schemes such as Best Start Foods, shifting such schemes from 'opt in' to 'opt out'.
• Claimant waiting periods: Benefit processing time needs to be improved; consider bringing in a bridging payment to cover the waiting time for Universal Credit like Northern Ireland's Universal Credit Contingency Fund. Consider free school meals for all children of families on Universal Credit
• Benefit take-up: Measures to promote take-up of key entitlements including Universal Credit (UC) and Council Tax Reduction.
• Discretionary Housing Payments: More help is needed for housing tenants, for example through increased DHP funding, review of the DHP to ensure funding support is reaching all those affected by the benefit cap, and housing support for those at risk of eviction.
• Education Maintenance Allowance: Uprate EMA (Education Maintenance Allowance), to take account of inflation since its launch. Improve promotion of the allowance to eligible families.
• Affordable credit: Increase the level of (financial) support to Community Development Finance Institutions and Credit Unions. This will increase access to affordable credit for low-income households.
• 16-18 year olds: A holistic review is required of how to better provide social security entitlements to young people who are not in education.

"Easier access needs to be available for people to make a crisis loan application, and payments need to be paid into banks accounts on the same day as the agreed application, otherwise emergency food provision is still needed." [Food Aid Providers]

A few respondents suggested that the Scottish Government lobby harder for control over the key social security policies that are causing greatest hardship. In particular, several commented that benefit sanctions are one of main reasons that people come to food banks. Indeed, one respondent said:

"Without abolishing benefit sanctions it will be impossible to end the need for food banks." [Individual]

Support services

Many of the respondents commented that food insecurity is not just about access to finance; and several of these respondents mentioned a range of barriers to accessing food, including poor living conditions, social isolation, limited cookery skills, budgeting skills and nutrition knowledge.

Some respondents commented on the importance of people being able to access types of practical support to reduce the cost of living: in particular they mentioned support to access quality, well-paid employment; and financial support in emergencies.

A key recommendation designed to underpin the cash-first approach was that every local authority should have a strategy to ensure no-one is referred to a food bank without also being offered advice, including how to find out about any financial assistance they are entitled to.

Linked to this, respondents were clear there should be a 'no wrong door' approach to provision of support, with properly funded services provided effectively, promoted and sign-posted, and delivered locally.

There were also calls to increase investment in services that support at risk groups to ensure high quality support is available. This included targeted mental health services for people struggling with drug and alcohol addictions and people with experience of homelessness.

A number of comments were made on support around specific issues:

• Debt management: A few respondents commented on council tax arrears and, in particular, the administration of debt repayment. It was felt that current approaches are a major source of financial distress, and reform should be a priority. It was suggested the Scottish Government should support local authorities to achieve this, including by supplying additional funding for implementation. One respondent suggested strengthening local welfare and debt advice services, for example by bringing in a statutory duty to protect these functions.
• Child poverty: A few respondents, in particular those working with parents, highlighted the cost of sending their children to school. It was appreciated that clothing grants go some way to mitigating these costs, but there were several examples where this fell far short. There were clear recommendations from respondents, to be implemented alongside other measures such as The Cost of the School Day, such as provision of free school meals during the holidays, reviewing eligibility for clothing grants and free wraparound childcare for school-age children.
• Transport: There was support for the extension of free bus travel to young people, although there were reports of some people finding it difficult to apply for, and especially so for asylum seekers and refugees who may not have the documents required to apply. A review of access and eligibility was requested. A few respondents commented that free bus travel should be extended to all those on little or no income, including people in receipt of certain social security entitlements. It was stressed that arrangements ought to be made to enable refugees and asylum seekers to access free transport. One respondent suggested taking public transport into public ownership.

"Transport costs are at the top of the list of worries for the people I work with, some of whom are housed 1.5 hours walk away from our centre. People in the asylum system - by necessity - buy bus tickets instead of food, because they have to travel to appointments and then come to our food bank week after week for 'emergency' food aid. Addressing this issue seems realistic and achievable for the Scottish Government." [Individual]

Healthy food

Some of the respondents raised concerns around accessing healthy food on a low income, and made suggestions for approaches to address this.

• A few respondents commented that the cost of a healthy diet can be too high for some on a low income, contributing to food insecurity. It was suggested that Scottish Government consider funding organisations to enable local access to affordable, nutritious food particularly in areas of deprivation. This could include cooperative or community buying groups.
• A few respondents commented on the benefits of promoting healthy eating choices and skills in schools and within communities. Respondents stressed the need to improve access to quality food to improve people's diets and health. Funding support, partnership arrangements to deliver and promote healthy eating were all considered essential. Measures suggested included transport initiatives to improve access to healthy food, growing and gardening projects to increase awareness of food and where it comes from, and skills in making healthier food choices.

"Food pantries/community fridges as part of local communities can be a part of increasing and improving access to these [healthy] foods. They can work alongside food growing projects, healthy eating workshops, cooking classes and can help promote the community to eat more seasonally and sustainably." [Community Organisation]

• A few respondents raised specific concerns about 'food deserts', these include rural areas and other places where shops and supermarkets are only accessible by car, bus or taxi.
• One respondent suggested modification of planning policy to reduce the number/ proportion of fast-food outlets in a local area, to promote healthy eating.

Taxation

Several respondents commented that most tax raising powers rest at Westminster. Nonetheless, a few of these respondents commented that Scottish Government should continue to work to gain control of further tax raising powers. A few suggested that substantive redistribution of income/wealth was required to fund solutions/address poverty within Scottish society.

Scottish Welfare Fund

Some of the respondents commented on the Scottish Welfare Fund (SWF) and provisions for people with No Recourse to Public Funds (NRPF). Key issues were:

• Access to SWF: Improve access to the fund through promotion, and by increasing the level of funding available to meet needs. Speed of processing claims was emphasised, with a few respondents stressing the importance of payments being available on the same day. Respondents criticised how the limit on the SWF claims operates in practice^[2], and commented that if the ambition to reduce/end the need for food banks is to be achieved, much greater flexibility may be required to enable people to make multiple claims.
• Respondents commented that the value of Crisis Grant awarded to claimants varies between local authority areas; and suggested that minimum standards for assessment and award might be required.
• Disabled people: A few respondents commented that the level of funding, and the ease of accessing funding for people with disabilities was inadequate. There is currently a concern that (Disability Living Allowance (DLA) and Personal Independence Payments (PIP) are being used to exclude people from payments. Some commented that the review of SWF should ensure there is a pathway for disabled people to access SWF where it is required.
• No recourse to public funds: Consideration to be given to how more assistance can be given to people with NRPF. Some respondents suggested allowing people to work; some proposed a system of person-centred support, instead of a series of one-off payments. This could include access to SWF. It was also suggested that greater upstream collaboration between the Scottish Government and local authorities could reduce the cost of living for people with NRPF and prevent hardship from occurring. This could include consideration of data sharing and active referrals, and a review of how to reduce costs should be undertaken: one suggestion was local authorities waiving birth certificate search fees for applications.

Food networks

A number of comments were made about the benefits and disbenefits of food networks and food production approaches

• Range and quality of food from food banks: A few respondents commented that the range and quality of the food available from food banks could be limited. The options promoted in the Draft plan – vouchers, cash-first, together with a support system including options including pantries, community larders and so on – offered a better approach, with access to higher quality food, fresh produce, and a range of support services.
• Companionship: A few of the respondents commented on the social aspect of using services, such as community food initiatives. Respondents commented on the value of building social relationships for service users, conversations about recipes using their ingredients, the opportunity to have a chat with other members.
• Choice: Some of the respondents commented on the importance of ensuring dignity when developing solutions to food insecurity. It was noted that members ask for what they need rather than just taking whatever is being offered; there are often discussions about recipes for using the produce that is available, and one respondent mentioned that their service caters to wider needs, such as pet food. Initiative such as food larders and pantries were felt to deliver on this:

"Larders - people get choice and dignity of being able to make some contribution toward food." [Lived experience]

• Food growing strategy: A few respondents commented on the need to make it easier for people to grow their own food. Suggestions included teaching children about food and gardening in schools; increased resourcing of community gardens and allotments at the local authority level; technical support from local authorities (for example, support for equipment stores); supporting council tax reductions for those that grow food; and a nationwide strategy on growing food. A few respondents registered opposition to proposals that encourage 'grow your own'; arguing that people on low incomes want to access services and food simply and easily, the same way that people of average incomes do.
• Funding for services: There were calls for services providing support to at risk groups to continue to be funded and/or to receive additional funding to better respond to need. Such funding was requested for:
  • Local pantries, social supermarkets, etc.
  • Local charities supplying hot meals for those without cooking facilities.
  • Local charities supplying household goods, especially when not eligible for entitlements or emergency financial assistance.
  • Money advice and housing services which could also, if so funded, support their clients to address food insecurity.

Community development and education

There was a concern that reliance on food banks resulted from a lack of resilience in local communities. This was, in part at least, attributed to the decline in community development provision that had occurred over last decade or so. One respondent commented:

"Public health and food insecurity should be supporting people well before people reach crisis. Relying on Trussell Trust Food banks over the past 10 years has set back community-based support as they have gained a foothold in areas where there was support. People have now learnt to visit food banks rather than be empowered out of a crisis." [Individual]

A few respondents commented that people needed much greater support if use of food banks – or their alternatives – was to decrease. Advice on healthy eating, money advice and budgeting were considered key, with a few suggesting that developing skills and confidence in these areas should begin at school. Key topics suggested included interest rates; inflation; bills; mortgages; direct debits; and banks.

"All children should learn to plan, shop and cook good healthy meals to a budget." [Individual]

Equalities monitoring

One respondent commented that the Draft plan envisages a far greater role for third sector organisations to deliver services, including the administration of distributing shopping vouchers (which would include the assessment of applications). The respondent was concerned that there was both potential for at risk groups to face discrimination and no mechanism to formally address complaints or concerns. It was suggested consideration be given to putting in place national standards that would underpin the relevant services.

"Some volunteers hold and carry widely held societal prejudices into their voluntary work. This could result in some minority groups at greatest risk of food insecurity such as refugees and/or people from BME communities or those with drug or alcohol problems being denied assistance when they most need it." [Campaigning Organisation]

Engagement, partnership and co-production

A theme running across the responses was the need for joined-up partnership working to publicise and streamline processes for people who are using services. One respondent commented:

"Some of the people who are seeking help are relatively "new" to poverty and the stress and anxiety that they experience is traumatic enough so all efforts to simplify help at the point of need with dignity and respect will be reassuring." [Individual]

There was broad support for the approach set out in the Draft plan with respect to partnership working. There were comments on developing this further and on other organisations to engage with. Respondents mentioned working with frontline organisations such as Trussell Trust, IFAN, Scottish Pantry Network, Citizens Advice Scotland, and local authority services. A few local groups stressed it was important to include organisations such as theirs in consultations, as they may work with different service users to the large frontline organisations.

"They [large organisations] only see a subsection of food bank users and may not understand their unique circumstances. Projects such as ours, who are well established in local areas and who have gained the trust of service users have a much deeper understanding and often provide a range of services around poverty including support and advocacy…. We understand the issues preventing people from having a healthy or adequate diet and try to address them." [Community Organisation]

The types of local organisations mentioned included local alliances, churches, trades unions, mutual aid community groups, community fridges, destitution cupboards.

Some also stressed the value of involving people with lived experience of financial insecurity and food insecurity, suggesting this could be done in various ways including research (for example focus groups, citizens forums), inclusion in partnership structures and adopting co-production approaches.

"There is a continuous need for the voice of lived experience supporting the national and local design of service support/referral to ensure the crisis and prevention plans continue to evolve and develop." [Campaigning Organisation]

Question 5 – measuring impact

Do you have any views on how we intend to measure impact, and what would give you confidence that we are moving in the right direction?

Overview of responses

Many of the respondents commented that they agreed with the approach to measurement set out in the Draft plan. Most of those commenting were elaborating on the proposed approach, making suggestions for specific measures that could be considered including the use of national datasets and data from food banks, and suggesting further issues to be considered such as the food affordability and equalities issues.

Some respondents said the key measure of policy success would be when food banks had all closed. Others were clear that the number of food banks/use of food banks was not a sufficient measure of the success of policy.

Monitoring and evaluation

Datasets

Typically, respondents suggested quantitative measures (or identified factors that needed to be quantified), but often commented that qualitative discussion with people and service providers is needed to achieve a more in-depth understanding of a range of issues such as who is using services, why and how services are being used, the reasons for changes in service use.

National data sets: There was support for use of national data sets, including the existing Family Resources Survey (FRS) and the Scottish Health Survey (SHeS) to benchmark, and to measure change and impact. One respondent suggested a more detailed survey, to collect data at the local authority level, would also be valuable, and could cover issues such as awareness and uptake of the Scottish Welfare Fund and other support services, as well as entitlements such as the Scottish Child Payment.

Limitations identified with this approach were that not everyone who experiences food insecurity will be covered by national surveys, especially those who are most disadvantaged – e.g. rough sleepers, people living in insecure housing, and households in multiple occupancy.

A few organisations commented that the SHeS has been collecting useful information on how lack of money to afford food affects people in Scotland. There were a few concerns that the FRS sample size for Scotland is too small to enable detailed analysis – especially at sub-Scotland level. It was therefore suggested that no changes be made to the data collected by SHeS in the meantime.

Data from food banks: Respondents agreed with working with national food banks and with community food networks to monitor and understand wider impacts. The following suggestions were made to improve the utility of food banks data:

• A robust baseline is needed, with some suggesting that data on current use is only partial. Therefore, further work is therefore required to improve the quality of the dataset.
• A few suggested that data should be collected at local authority level from all food aid providers.
• It should include the number of adults and children benefiting from the food provided.
• A standard size of food parcel needs to be agreed and used (for example, 1 day/2 day/3 day).

"It is important to know the landscape of emergency food provision across the country and the interaction they have with local food poverty groups to ensure that you have a baseline and therefore accurate recording of impact." [Local Authority]

Limitations identified: A few respondents commented that the quality of data from the food banks may vary, as a consequence of the capacity within food banks, resources available, willingness to participate, and so on. A few also stressed that the use of food banks is an incomplete measure of need, as many people living with food insecurity do not access a food bank.

One respondent suggested that, if food vouchers are introduced, data from supermarkets should also be used. It was further suggested that the supermarket data could be used to monitor what the vouchers were being used to buy and, if 'mainly junk', the options available could be restricted to healthier choices and other essentials.

Monitoring of levels of need for food banks: A suggestion was made that a reduction in the use of food banks does not equate with a reduction in the need for food banks. It was suggested that a robust measure of the extent to which household income is sufficient to meet food needs was therefore needed. These respondents considered this measure would provide the cleanest indication of need, and consequently of impact.

Approaches suggested included using the Joseph Rowntree Trust Destitution definition as the basis of a Scottish measure, the development of an absolute measure of poverty for Scotland or estimating the proportion of the population not in absolute poverty.

Referral pathways and the impact on the need for food banks. Respondents commented that it would be important to explore the relationship/impact between referral pathways and food bank (or shopping vouchers) usage. Suggestions included collections of relevant monitoring data, including SWF information, and Scottish Child Payment data with referrals via cash-first pathways; as well as independent evaluations.

Qualitative data

Some of the respondents commented on the importance of engaging with people with lived experience of food insecurity and delivering services:

• Involvement of people with lived experience of food insecurity: Respondents commented on the value of involving people who are 'experts by experience' in the design of monitoring and evaluation frameworks as well as in the data collection and analysis. One respondent commented that this will require training and support. Others noted that measures will need to be put in place to ensure that hard to reach groups are included in the studies. These include people without English as a first language, disabled people, especially those with mental ill health, people in insecure housing/no fixed abode, and Gypsy / Traveller communities.
• Staff involved in delivering services: Respondents also considered it important to include representatives from the range of organisations delivering relevant services in the design and review of monitoring and evaluation frameworks. One respondent commented that this should include community cafes.

Only a small number of specific suggestions for qualitative analysis were made. These were:

• Case studies to explore/illustrate the impacts of the policy; and examples of behavioural change.
• Research to explore the views of people using/who have been using the services – have they been enabled to move on successfully from food insecurity; how the new actions have improved their access to food, reduced their financial strain and improved their overall health and wellbeing; what has worked well/less well.
• Research to collect feedback from children on how the changes have affected them and their diet.

Other issues to be included the monitoring and evaluation

Respondents suggested a range of other issues that should be included in the monitoring as they considered them linked to, or relevant to, the experience of food insecurity. In many cases, there were no suggestions as to how this information could be collected systematically at a local or national level. It may be that some of this information is not amenable to quantification and would be better explored qualitatively.

• Employment-related information: including the number of living wage organisations, changes in employment contract types to reflect job security (e.g. zero hours contracts), levels of in-work poverty.
• Support services: access to income maximising advice and support, person-centred-advice and support, health, training and housing services. Respondents echoed the sentiments in the Draft plan that cash-first solutions needed to be accompanied by holistic support structures, and therefore asked that robust and flexible measures for these services also be included.
• Impact of cash-first payments: on people experiencing financial hardship.
• Food affordability: proportion of income needed to afford a healthy diet; proportion of income spent on food.
• Rural areas: access to/availability of affordable food in rural areas.
• Surplus food redistribution by area: to identify areas that might require additional support. Mixed views on how redistributed food waste should be measured: while some suggest by weight, others suggested using meals/nutritional value/types of food.
• Community initiatives: such Olio and Good to Go apps, pay it forward schemes, community gardens, supporting local production and allotments.
• Wellbeing measures: such as hope, happiness, sense of connectedness.

Some respondents, suggested that all policy changes which relate to social security should include a requirement to measure the need for and use of food banks in their evaluation plans.

Confidence

Respondents tended to want the monitoring and evaluation to be transparent and clear. It is worth noting that one respondent simply asked "what is meant by measuring food insecurity?" [Individual]. The terminology used will need to be accessible if a wide range of people and agencies are to participate in the process and understand the outputs.

One respondent suggested that a theory of change would be useful in developing a more robust and appropriate monitoring and evaluation framework.

Some respondents suggested their confidence would be increased knowing that the development of the monitoring and evaluation approach was undertaken collaboratively with people who have lived experience of food insecurity.

Indicators

Several specific – and not so specific – indicators were suggested as good evidence the policy was working:

• Some respondents suggested a decrease in people using food banks. This was often accompanied by a request for qualifying evidence, such as information on number of people in employment and the number in good quality jobs (targets would be for an increase in employment and an increase in the proportion in good quality jobs).
• Some respondents suggested a reduction in people facing food insecurity.
• Some suggested a reduction in claims for SWF, especially those in relation to food insecurity.
• A few suggested improved uptake of entitlements such as free school meals.
• A few suggested evidence that referral pathways are well understood and are based on dignity (and monitoring information which shows a reduction in demand and repeat demand from individuals/households).
• One suggested the number of organisations that provide lists of food banks to people in receipt of social security is reduced.

Other issues

Some respondents highlighted issues of concerns about the data collection or analysis:

• A few stressed that the monitoring data, and the reports from any evaluations carried out, should be published. This would ensure transparency, monitoring and sharing of best practice.
• Some of the respondents stressed that clear targets and timeframes need to be set within the policy, with a few suggesting that these should be set in legislation. Linked to this, a few commented that the plan needs a clearer indication of governance and accountability for each of the actions and impacts.
• A few respondents stressed that standardised systems/definitions ought to be developed and agreed to enable data to be collated nationally, compared across areas, and across time. The example of food bank parcels is identified above.
• Some said a basic living income should be the norm, with emergency support for those who require it.

Finally, a small number said they did not support the monitoring and evaluation. They felt that third sector and charitable organisations who were acting altruistically should be left alone. One said specifically that the government should not be allocating resources to measuring the activities of the charitable and third sector, but it should instead focus on improving its own services.

Question 6 – other issues for consideration

Is there anything else that you think should be considered in the development of this plan?

Overview of responses

In the final question many of the respondents took the opportunity to underline the points they had made earlier in the consultation. The main issue that emerged across this section was to ensure the variety of experience across the country and between different communities and at risk groups was properly reflected in the provisions made in the Plan. Respondents agreed with the proposals in the Draft plan that partnership working that engages a diversity of interests will be critical to delivering this ambition, and a range of potential key players were suggested.

Specific issues

Regional variations

Some of the respondents commented that the factors facing rural and islands areas should be addressed within the plan. These include:

• A higher cost of living than elsewhere in Scotland, with, among other factors, higher energy, freight, and travel costs; often higher housing costs, as well as higher food prices and in some cases limited choice.
• Higher fuel and heating costs in rural areas. A few suggested that the Government could offer further subsidies to rural districts (including domestic heating oil where there is no mains gas).
• Fewer childcare facilities than on mainland Scotland, which represents a significant barrier to employment for many residents, particularly among women.
• Local economies skewed to low paid, seasonal work.
• Absence of some key services in remote rural areas: for example, some areas do not have public transport, internet connectivity and, as noted above, supermarket/large shops.
• There are additional barriers to accessing support services: services may only be available on a part-time basis; people may have to travel some distance to the service provider, which incurs a cost, and may not be possible by public transport; and there are some issues of confidentiality/stigma in small communities.

Target groups/equalities

Some of the respondents commented that it was important to adopt a person-centred approach to delivering services. A few highlighted the complexities of people's lives, and a few highlighted the needs faced by those from diverse communities or with particular needs. It was agreed that holistic support was important in addressing the needs of a diverse population. Several groups were mentioned by respondents in the Draft plan as requiring additional support. These included:

• Asylum seekers and refugees: Respondents commented that daily rates of asylum support are £5.66, which means people are juggling paying for all their essentials including food, transport, appointments and clothing from a tiny budget. Suggestions included concessionary travel (that can be accessed using the documentation refugees and asylum seekers generally have) and a welcome clothing grant administered by a charity.
• People from minority ethnic communities, including Gypsy / Traveller community. A few respondents noted that there is little available data in Scotland on the use of food banks and food insecurity by ethnic minority groups. Some suggested a need to improve information, some suggested improved promotion and delivery of services.
• Children and students: A few respondents suggested free school meals for all schools pupils, with one suggesting this includes further and higher education students
• Older people: A few respondents commented that older people are especially likely to feel shame or stigma at the thought of accepting charity, so may self-exclude from food banks. Other issues mentioned were mobility and other health issues such as dementia that may present barriers to accessing services; and may be especially likely to be digitally excluded, so less likely to be able to access service online. It was suggested that community-based services, such as community meals and food-sharing initiatives may be more appealing to older people.
• Carers: A few respondents identified carers as being at higher risk of food insecurity. It was noted this group is often very isolated.
• Lone parents and families with children under five: A few respondents identified this group as being at higher risk of food insecurity. It was suggested that health professionals could play role in providing support and access to services.
• Single men, especially those with addictions, recently left prison, homeless. A few respondents noted that single men make disproportionate use of food banks, and suggested that additional measures will be required to support these groups

A few respondents noted that producing more materials in translation would improve accessibility for people in ethnic communities; increasing access to benefits and other financial support including SWF, as well as to wider services.

Many respondents stressed that development at the strategic and operational level had to be undertaken involving those with direct experience of providing and using/needing the service. Some said this must include a wider range of service providers than the national organisations named in the consultation. Respondents said that local, community-based organisations including local food aid providers will have different experience and expertise to offer. It is essential they are engaged in and on board with the exit strategy.

"There needs to be a lot more research into the issue along with deeper consultation with 'on the ground' organisations who really understand their user base and the problems they face daily… Projects such as ours, who are well established in local areas and have gained the trust of service users… We understand the issues preventing people from having a healthy or adequate diet and try to address them." [Community Organisation]

People with lived experience: Respondents commented that those with lived experience of food insecurity/food banks, together with those who have direct experience of delivering services, should be involved in the development of policy and practice. Examples of organisations mentioned: local food initiatives, community fridges, destitution cupboards; churches; mutual aid and community groups.

"There is a continuous need for the voice of lived experience supporting the national and local design of service support/referral to ensure the crisis and prevention plans continue to evolve and develop." [Individual]

Other organisations to engage

Registered social landlords: Respondents commented that many RSLs provide specialist debt, money and welfare advice to tenants; and debt management support to those in arrears. It was noted that, adequately funded, further work could be undertaken around food insecurity at both the individual tenant level and to implement community initiatives.

Supermarkets and other retailers: There was a view that food retailers needed to be more engaged in discussions around policy delivery. It would be particularly helpful to have retailers engaged around supporting local and national food charities and the administration of food vouchers/cards. A few respondents also commented that food retailers are significant low wage employers, and called on the government to take advantage of this policy initiative to put pressure on retailers to become Real Living Wage employers.

Delivery approaches

• Social food sector: One respondent set out a proposal for a model which adopts the principles used by housing first approaches which aim to rehouse homeless people quickly into long-term housing quality social housing, and put in place support to sustain the tenancy. The social food sector would ensure dignified provision of affordable, high-quality food alongside wide-ranging wraparound supports. It was emphasised that these supports would need to be well-resourced, well-co-ordinated, and link national, local and community services. The social food sector would be seen as integral to, not in conflict with, the delivery of cash-first approaches. [Campaigning Organisation]
• Regulator: A few respondents mentioned concerns about capacity to monitor progress to address food insecurity. One respondent suggested a regulator with powers to hold national and local authorities to account and the ability to require deployment of policy mechanisms (such as those set out in the Draft plan) together with the necessary public funds. [Campaigning Organisation]

General issues

Incentives for healthier eating: A few respondents commented that unhealthy options can be easier to purchase and cheaper than healthy options (fast foods and processed foods, versus fruits, vegetables and home cooked meals). A few respondents suggested developing price incentives to redress the balance. Others suggested improved cookery classes for all age-groups through schools, and more cooking classes to be made available within local communities for adults.

Address media/social media perceptions of poverty: to try and remove the stigma of securing advice and support. A few respondents noted the pandemic had demonstrated that 'anyone can fall on hard times'; others noted that many who face food insecurity are in-work.

"Target the misconception of people living the highlife on benefits and looking for something for nothing." [Individual]

Fraud prevention: A few respondents either allude to, or directly mention, that the Draft plan lacks any mention of fraud and does not contain a fraud prevention strategy.

Emergency planning: One respondent commented that if the Plan is successful, and food banks are no longer required, contingency planning for crisis food support for the most vulnerable for national emergencies such as a future pandemic or extreme weather event etc. will have to be put in place. They commented that the emergency food aid given out during the pandemic would have not been so effective if it had not been able to use existing food banks.

Publicity: One respondent stressed the importance of publicising the measures contained in the Draft plan. They said that, while this was important everywhere, it would be especially important in the apparently much better-off communities, which are not well-served by advice and support services, but which nonetheless contain people who are struggling.

Non-food items provided by food banks: A few respondents commented that food banks do not just supply food; they provide much-needed items like clothes, Christmas gifts, toiletries, period products, fuel top ups and transport support. Reassurance was sought that provision would be made for these items if food banks cannot provide them.

Asylum seekers: One respondent agreed that the provision for asylum seekers in the Plan should also consider the 'Ending Destitution Together' strategy and should consider the recommendations made by experts by experience in the 'Ongoing Emergency' and 'How Will I Survive' publications.

Child poverty: A few respondents welcomed the Tackling Child Poverty Delivery Plan, and called for/assumed the synergies would be developed.

Wider issues

Social security and other income maximisation actions

• Social security: A few respondents commented that the social security system is confusing and difficult to navigate, with some of these people saying the payments are inconsistent, making budgeting difficult. They said a simplified system would reduce stress and anxiety about money and food.
• Cost of living measures: Improving home insulation and incentivising further self-sufficiency in heat production in Scotland so we are less reliant on imports from outwith Scotland and have better control of wholesale prices.
• Extension of free meals: One respondent commented that the investment in free school meals is positive, and suggested that the model could be developed, for example to cover other people such as vulnerable adults in the community.

Services

• Youth work approach (Promoted by YouthLink): Tailored programmes that work with young people and their families, taking a whole community/family/person approach.
• Investment in basic infrastructure: Investment in basic infrastructure (e.g., buses, local facilities in local communities) are needed to allow people to access the support they need, much of which has been centralised and is not locally accessible.
• Addictions: Some of the respondents commented that addiction was a key cause of poverty, and also a real barrier to people accessing and benefiting from support and from moving out of poverty. Respondents suggested that much greater help and support was needed to address this.

Healthy food

• Social farming interventions at community and household levels which could be replicated in many communities in Scotland. Communities and households that grow their own food should be incentivised in a form of technological or financial assistance to increase the yield of their produce.
• Third sector organisations who have the willingness to develop and deliver similar food growing strategies should be supported by the government in a form of financial capital or incentives.
• Derelict and unused lands could be used as community farms both in urban and rural areas.
• Food literacy programmes that educate people about the value of growing food and consuming food in a sustainable manner could complement any community food growing programmes. These should focus on educating people about food systems which include topics on food sources and how to produce and consume food more sustainably.
• Incentivising more local production of the essential food we require in Scotland through innovative methods (such as vertical farming) and reducing reliance on imports.
• Cash transfer schemes to boost local agricultural production: directly purchasing produce from small local farmers and distributing this produce in community shops such as food pantries at discounted prices.

Taxation

There were suggestions for modifications for taxes that are devolved to the Scottish Government that could reduce costs for low-income households. These included: shift from the council tax (property-based taxation) to a Local Income Tax; and adjust income rate and thresholds: reducing the lower rates of income tax and increasing thresholds.

Food networks

There was a tension across the responses between those who advocated strongly for merits of a food redistribution approach and those were equally passionately opposed.

Some of the respondents supported food redistribution and wished to see it continue to be supported by the new Plan. Examples of how it currently worked included organisations who source good quality food near to sell-by date and redistribute/sell to local people at low prices. The key factors cited were affordable food, quality produce, available locally. Some initiatives noted their services were available to people not eligible for food banks, increasing accessibility and reducing stigma. Respondents also stressed the environmental benefits of reduced food waste.

• One organisation stressed that the food distributed by FareShare was surplus produce, not waste:

"FareShare works with surplus, not waste (as is often stated by its detractors), produce and arguably, reasonably, why should those facing food poverty be denied access to such produce." [Community Organisation]

• One organisation commented that surplus could play a very positive role in communities, but not if people relied on it:

"If people are using community fridges simply in order to reduce food waste, then this can only be seen as a positive thing for a community, and it can be a fantastic way to bring environmental messages and community connection to a village. However, once this turns to people becoming reliant on this food then there is a greater social problem that cannot be fixed by swapping the dependency to another way such as giving out food vouchers." [Campaigning Organisation]

• One respondent stressed that the Draft plan needs to enable small, local organisations to (continue to) access donated food, rather than supermarkets distributing via large networks, such as FareShare.
• One respondent asked what will happen to the surplus food that is currently redistributed by food banks when there are no more food banks 'Will it go to landfill? That's not good for the planet' [Individual].

Conversely, a few commented that while the FareShare network had played an invaluable role supporting food providers throughout the pandemic, the distribution of surplus food was at odds with the Dignity Principles. These respondents called on Scottish Government to end any further funding of surplus food redistribution.

"As a food bank we have accessed FareShare several times, but it is not the answer to food insecurity it is often claimed to be. Surplus food has a place in society, but it's not to feed people who can't afford food. It's a lazy way, and an insulting way, of addressing this problem. People who cannot choose what to eat shouldn't be given food that is out of date. Feedback from our clients is that they feel it is second class food for second class people, that's not the Scotland we want to live in. We should live in a country where if you want to buy or eat surplus food, it is because that is your choice. That is dignity." [Food Aid Providers]

One respondent [Zero Waste Scotland] suggested ways to address these issues. They support redistribution of high-quality surplus food, where that cannot be prevented, and where that aligns with broader government policy objectives (including ending the need for food banks and healthy eating). However, they also note that the impact on the dignity of those accessing food in this way must be a key consideration. They promote normalising the use of surplus food across communities and the wider population, enabling choice, and ensuring that it is supplied in a dignified way: for example, through the expansion of community fridges, food surplus social supermarkets, and low-cost community meals.

Planning guidance

Reduction in the number of fast-food outlets/controls on numbers approved. One respondent commented their local town has a takeaway for every 950 residents, and that none of those does 'healthy' food.

Housing

• Housing costs are a critical driver of poverty: respondents suggested actions including rent caps in the public and private sectors and continuation of discretionary housing payments, as well as development of more affordable and social housing.
• Housing standards: Respondents commented housing costs are disproportionate for those living in damp, poorly insulated, hard to heat housing, and supported measures to invest in affordable and social housing, and proposed:
  • Work with housing providers to ensure that all families in temporary accommodation have financial support plans in place.
  • Affordable energy standards for temporary accommodation/social rented housing.
• Fuel Critically, respondents identified the cost of domestic fuel a key issue facing service users, and commented that those on lowest incomes tend to be placed on the highest tariffs (pre-payment meters). It was noted that a few food banks already provide support with fuel costs. It was suggested that additional support with fuel costs should be considered, for example, fuel cards and access to emergency assistance to pay for fuel (including oil heating). One respondent highlighted the impact of daily standing charges, which apply even if no fuel is used; and suggested that pressure needs to be exerted to have such standing charges reduced to zero, so that people on low incomes and private renters have more flexibility around when they use their utilities.

Themes

Key issues raised

Overall support for the Draft plan: There was general support for the Draft plan, although some respondents had concerns that the measures set out in the Draft plan were insufficient to address the huge task ahead; and that the Draft plan may lack detail especially on timescales and resourcing. A sizable minority, while supporting the Draft plan's objectives, nonetheless considered there may remain a place for food banks, or something very like them – where social security fails, for people who slip through the net, or for people who really cannot cope with cash for whatever reason.

There was very strong support for the human rights approach set out in the Draft plan.

Policy alignment: Respondents on the whole agree that the Plan should align with wider policy objectives including Tackling Child Poverty Delivery Plan and the Good Food Nation ambition; and there was strong support across the consultation response to incorporate the Right to Food into Scots Law. There were calls for further clarity on the Government's position on surplus food, and the relationship between surplus food and food insecurity.

Is the vision achievable? Although the response to the closed question 1 was overwhelmingly positive, throughout the consultation respondents identified potential barriers to success. The most common were: the cost of living crisis, which is driving more people into poverty, and likely to continue to do so for the short-term at least; and concerns that Scottish Government does not control enough of the economic and fiscal drivers to effect significant change.

Resources: Respondents commented that significant resources will be required over the long-term if the Plan is to be successful: income measures including the proposed minimum income guarantee; developing and supporting the new infrastructure that will be required for ending the need for food banks – advice and support for users; training for staff and volunteers. There were concerns, even from many of those supportive of the Plan, that funding for the measures required for success would be insufficient. Several stressed the not inconsiderable task ahead persuading those who are reluctant to give up the food bank approach of the benefits and validity of the proposed system.

Poverty: Respondents generally agreed that the Scottish Government should work to address poverty, and the key causes of poverty, rather than a focus on food banks per se. Respondents supported the measures set out in the plan designed to tackle poverty: strengthen incomes, especially through fair work, maximising entitlements and work to explore a minimum income guarantee and universal basic services; improved access to advice and support, with a no wrong door approach, and services delivered in community/neighbourhood settings; and implementation of effective referral pathways.

Many respondents said that addressing poverty required a systemic response, that included housing, education and training, health and social care, economic development, environmental services, and so on. And required multidisciplinary teams from public, private, third sectors, as well as the involvement of people with lived experience.

Support: A minority of respondents commented that people use food banks because they are less well able to manage their money, shop, cook, and so on. This was especially likely to include people with addictions, people with mental health problems, and people with no fixed accommodation/living on the streets. Some of these respondents stressed the importance of emergency food aid and a strong inter-agency team to support work to towards maximum independence. Others focused on minimising opportunities for food aid to be 'misused' (that is, sold-on and the money used for other purposes).

Inter-agency working: A few respondents commented on the agility and responsiveness of food banks, and of community-led food banks in particular. There were some concerns that the Plan would introduce unnecessary layers of bureaucracy. It was suggested that services should be coordinated by the local authority, but preferably delivered at the community/neighbourhood level by third sector/community organisations.

Cash-first: Respondents on the whole were supportive of a cash-first ambition. There were some qualifications: respondents sought reassurance that measures would be taken so that people living in rural areas would not be disadvantaged; and some respondents sought reassurance that alternatives could be put in place for those users who struggled to cope with managing money.

Shopping vouchers: The topic that generated the greatest range of views across the consultation was potential the role for shopping vouchers. Generally, it was appreciated that vouchers offered more choice to people than food parcels. However, their disadvantages were considerable in terms of stigma, being restricted to specific shops (possibly some distance/a bus ride away), and the costs of administering the vouchers.

A small number of respondents considered vouchers were preferable to cash payments because the items 'purchased' could be restricted.

Alternative food distribution models: A wide range of food distribution models were mentioned throughout the consultation. These ranged from community larders and fridges that are used to redistribute food surpluses and tend to be unstaffed, through to locally-run food co-ops and social supermarkets, and community gardens; which provide food at little or no cost but have broader social, community or environmental objectives, and which are a part of local joint-working partnerships. Respondents would find clarity around the potential role for different models in the exit strategy helpful in their continuing discussions with local and national government.

Co-production: Respondents agreed that people with lived experience of use of food banks or food insecurity should inform all stages of the Plan's development, including the design and delivery of the measures set out in the plan, and monitoring and evaluation. They stressed the barriers faced by and the very different experiences of marginalised groups when they access services and paid work. Consequently, measures need to be taken to ensure the participation of people from at risk groups. These include, but are not limited to, disabled people, addictions, mental illness; as well as Gypsy / Traveller communities, asylum seekers and refugees.

"I'm a volunteer, I haven't got first-hand experience of using a food bank…I am glad that the system will change - but let's do it with the voices that matter most at the forefront." [Individual]