Enhanced heating regimes: consultation

Building on the Draft Fuel Poverty Strategy

15. Initial proposals on the enhanced heating regime and what households it should be applied to when calculating fuel poverty, were included in the Draft Fuel Poverty Strategy.  The draft Strategy said we would move to apply the enhanced heating regime to those households where:

a) at least one member has self-reported as having a physical or mental health condition or illness lasting or expected to last 12 months or more;
b) or, in the absence of the above, at least one member is aged 75 and over.

Age

16. This was based on evidence, set out below, and advice from the Panel who noted that: 

‘……age per se is not a particularly useful criterion for classifying people as vulnerable to cold-related health impacts. In the absence of any long-term ill health or disability, the Panel took the view that age should not become a proxy for vulnerability, until a much older age than is presently used as a threshold in Scotland (which is 60 years). A threshold nearer 75 to 80 years might be more appropriate;….’^[6]

17. In accordance with their view, we agreed that age on its own did not necessarily mean enhanced heating was required. Instead, our analysis of 2017 data indicates that 60% of households with any adults aged between 60 and 74 inclusive will be classed as needing this enhanced heating regime because of specific health issues or because they also contain another person aged 75 or over. 

18. Our current modelling indicates that around 80% of households classified as needing an enhanced heating regime under the previous definition will remain so under the new definition but the new multiple heating regimes allow us to tailor our approach to apply the most appropriate heating regime and to think about other groups who may need enhanced heating.  For the reasons set out above we are proposing to accept the lower end of the age range recommended by the Panel,
age 75, as the point at which an enhanced heating regime would be applicable.

19. However, if any additional medical evidence is brought forward in the future that indicates a different age threshold is more appropriate then we can review this aspect of the definition and it will be possible to revise the regulations.

20. It should also be noted that this age threshold is also consistent with our approach to our Warmer Homes Scotland fuel poverty scheme. Eligibility criteria for that scheme was agreed with input from key stakeholders, including Age Scotland and Citizens Advice Scotland, to ensure support is focussed on those with low incomes, including the working poor, fuel poor families, plus those aged over 75.

Health related conditions

21. The Panel also considered the issue of health related conditions that would make a person more vulnerable to the effects of fuel poverty and to whom an enhanced heating regime would be more appropriate. They noted that it would be extremely challenging to define a list of long-term illnesses or disabilities that would indicate a person requires an enhanced heating regime because some medical conditions and disabilities can affect people differently and as a result you generally wouldn’t categorise individuals with any specific medical condition or disability as making a person ‘vulnerable’. Depending on the medical condition or disability, different people might have very different functional ability with some needing a lot of assistance for daily living whilst others may be fully independent, and this can mean they can have different fuel requirements.  

22. We discussed this issue with the Fuel Poverty Advisory Panel who also thought that identifying a specific list of conditions was not practical.  Instead they proposed that as well as those households with an individual that self-identified as having a long-term mental or physical illness having an enhanced heating regime applied, an enhanced heating regime should also be applied to households where
a member of the household was in receipt of a disability or a care related benefit.   We support the view of the Panel and are proposing that an enhanced heating regime is applied to those households where an individual is in receipt of a disability or care related benefit and to those households with an individual that has a long term mental or physical illness.