Fuel Poverty Strategy for Scotland: consultation analysis

7. Outcomes and principles

Summary of Questions 19 to 21

• Many respondents made a statement of support for taking an outcomes-focused approach, including because it would shift the focus onto the impact on people rather than properties.
• Gathering qualitative feedback on the impact that fuel poverty or energy efficiency measures have had on individual households was seen as challenging.
• A number of respondents agreed that the outcome-focused approach would encourage national and local policy and delivery partners to work together effectively.
• Many also agreed that the principles detailed in the 3 bullet points are adequately reflected in the outcomes framework. However, there were concerns that the needs of rural and island communities are not clearly acknowledged.
• A majority of respondents, 72% of those answering the question, thought the proposed framework would help to strengthen partnerships on-the-ground.

7.1. Section 7 of the Consultation Paper looked at outcomes and principles. It noted that the aims remain true to those that were identified in the 2012 Fuel Poverty Evidence Review and that the following principles will underpin the approach:

• The Fuel Poverty Strategy will be firmly based on the principle of social justice and creating a fairer and more equal society, irrespective of whether individuals live in urban or rural Scotland;
• The Scottish Government's approach to fuel poverty eradication will be set on a statutory framework, measured and overseen by Ministers and delivered via partnership structures at a local level. Building on the assets of individuals and communities will be at the heart of this partnership and early intervention and prevention will be crucial to success; and
• The needs of individuals and families will be at the heart of service design and delivery and the Fuel Poverty Strategy will address all four drivers of fuel poverty: income, energy costs, energy performance, and how energy is used in the home.

7.2. The Consultation Paper also noted that developing an outcomes framework for fuel poverty is designed to enable Scottish Government and its partners to adopt a shared understanding of what needs to be achieved for those who are in, or at risk of falling into, fuel poverty.

Question 19 - What are your views on, or experience of how an outcomes-focused approach would work in practice?

a) Would it encourage national and local policy and delivery partners to work together effectively, and if not, what alternative approach(es) do you propose could be used instead?

7.3. A total of 64 respondents commented at Question 19 and 50 respondents at Question 19a although around 1 in 3 simply referred back to the previous question. A breakdown of the number of comments received by respondent type is set out in Table 20 below.

Table 20: Number of comments by respondent type

Type of respondent	Number of comments at 19	Number of comments at 19a
Organisations:
Community or Tenant Group or Federation	1	1
Energy Company	3	3
Health and Social Care	3	2
Housing Association	8	5
Housing Body or Group	3	1
Inter-agency Group or Partnership	4	3
Local Authority	21	17
Other	4	2
Research Group	2	2
Third Sector	11	9
Organisations	60	45
Individuals	4	5
All respondents	64	50

7.4. Around 1 in 2 of respondents who answered the question began their comments with a statement of support for taking an outcomes-focused approach. Strengths and positive impacts anticipated as stemming from taking an outcomes focused approach in the field of fuel poverty included:

• It would shift the focus away from properties, numbers of energy efficiency measures installed, or funding invested and onto impact on people and specifically on to people who need support the most. This point was made by around 1 in 6 of those who answered the question.
• It can be beneficial if partner bodies are aware of the impact their own actions and activities can have on end users, and how these activities relate to those of other agencies.

Challenges for outcome focused approaches

7.5. Respondents also noted some of the challenges inherent in any outcome-focused approach or in taking an outcome-focused approach in this policy area. Comments included that:

• The main challenge is to agree what the outcomes are and who is responsible for them. Taking an inclusive approach to this work would be helpful.
• Monitoring outcomes is not always achievable within the time frame of shorter term projects.
• An outcomes-based approach can only work if programmes are longer term to allow for improved collaboration with all stakeholders to ensure funding is targeted in the correct places.
• The approach should not only focus on the outcomes but also the actions, processes and resources required to deliver these.
• Gathering qualitative feedback on the impact that fuel poverty or energy efficiency measures have had on individual households may be a challenge.
• It can be a resource heavy approach. There was a request that any additional requirements, such as additional qualitative monitoring or research, should be adequately funded.

The overall approach

7.6. Other comments highlighted what respondents would be looking for in terms of the outcomes focused approach and included that:

• It is important not to mandate a top-down approach but to work with smaller organisations to ensure that their expertise and local voice is heard at every stage.
• It would be helpful for the outcomes to be included as part of the reporting criteria for partners, ideally with detailed activities disaggregated.
• It will be important to assess, adequately acknowledge, respect and meet the variety of needs of people with, or who share protected characteristics.
• The plan and process should be SMART ^[20] tested.

7.7. In terms of how progress should be measured, comments included that:

• Measuring progress against a baseline figure for fuel poverty will be key.
• It will be important to use actual data and the experiences of those receiving support and is not entirely reliant on modelled data.
• The new Advisory Panel may wish to develop means of keeping contact with, and gathering qualitative information from, local delivery organisations across Scotland.
• A level of quantitative measurement should be retained.
• The work of HES relating to fuel poverty should be integrated in to the outcomes-focused approach.

7.8. On the outcomes themselves, and how the approach should be set out within the Strategy, comments included that:

• It would be helpful to have local outcomes as well as national ones. Localised plans were also suggested. However, it was also suggested that local outcomes can only be guaranteed if the Scottish Government adopts a grant-based approach to supporting locally-based and trusted organisations of quality services.
• The Strategy should set out the anticipated impacts and expected sources of funding for individual programmes or actions.
• There should be clarity around which parts of the policies, plans and strategies will contribute towards the intermediate and long-term outcomes.
• The Scottish Government must specify timely reporting of both outputs and outcomes.

7.9. There were also comments about how the outcome-focused approach would work in practice. These included:

• Further information on the reporting requirements for organisations would be welcome.
• Guidance should be provided which sets out a consistent approach on how and what organisations should be reporting.

Other issues

7.10. Other respondents suggested other outcomes which they would wish to see included. Suggestions were:

• Healthcare impact on both those receiving support and on the wider healthcare system.
• Eradication of the disparate rate of fuel poverty that BME groups and some other equalities groups face.

7.11. A small number of respondents did not agree with the focus on outcomes. It was suggested that delivering strategy objectives would be more achievable if there was a focus on key indicators as opposed to being outcomes focused.

Effective joint-working

7.12. At Question 19a, a number of respondents (around 1 in 8 of those answering the question) simply agreed that the outcome-focused approach would encourage national and local policy and delivery partners to work together effectively. Further comments included that it will support a collective vision that all partners can share. It was also suggested that it will help foster more closely aligned and successful partnership activity and will encourage national and local policy and delivery partners to work together effectively.

7.13. It was also noted that the high-level outcomes are consistent with, and seek to achieve broadly similar aims as, the National Health and Wellbeing outcomes for Health and Social Care Partnerships and CPP Local Improvement Outcomes. The importance of seeing fuel poverty as not only a housing issue was also highlighted, and it was also suggested that the Strategy should be linked to relevant existing work and plans, such as that being done in the field of Public Health.

7.14. Some respondents cited certain conditions or circumstances which they felt needed to be in place to support effective joint-working. These included that:

• Local delivery organisations are consulted on the best approaches to delivery of outcomes.
• Partners are provided with clear guidance and support on how to report against an outcome-based framework.
• The capacity of the local delivery organisations is built.

7.15. Other suggestions as to how partners could be encouraged to work together included that with clear sections for different stakeholders within the Strategy can be more easily translated into actions that are achieved collaboratively.

7.16. Further comments included that the UK Collaborative Centre for Housing Evidence ( CaCHE) ^[21] could work with a group of frontline fuel poverty alleviation practitioners to draw up a realistic list of the outcome measures required.

Question 20 - Do you think the principles detailed in the 3 bullet points above are adequately reflected in the outcomes framework?

7.17. A total of 60 respondents commented at Question 20. A breakdown of the number of comments received by respondent type is set out in Table 21 below.

Table 21: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	2
Energy Company	2
Health and Social Care	3
Housing Association	7
Housing Body or Group	2
Inter-agency Group or Partnership	4
Local Authority	20
Other	3
Research Group	2
Third Sector	11
Organisations	56
Individuals	4
All respondents	60

7.18. Around 1 in 3 of respondents who answered the question agreed that the principles detailed in the 3 bullet points are adequately reflected in the outcomes framework.

7.19. Other respondents made general comments about the overall approach as set out within the Consultation Paper, including how the principles should be reflected in the outcomes framework. These comments included that:

• The principles could be more prominently reflected in the framework
• Both the principles and outcomes framework should be reviewed once a detailed plan is prepared.
• More detail is required, including in relation to the policies, programmes and resources that are expected to deliver the three principles. An example given was how the proposed policy to introduce minimum standards of energy performance in the private rented sector and to consult on standards and incentives in the owner-occupied sector will be delivered.
• The Health and Social Care Strategic Plan should be referenced.

7.20. Around 1 in 9 of those who answered the question made comments about the overall approach as expressed through the three principles. Comments tended to focus on areas which were not seen as being given sufficient coverage within the three principles. As at previous questions, the needs of rural and island communities were argued not clearly acknowledged and taken into account. There was a specific suggestion that the Scottish Government should commit to the principle of giving rural communities as much opportunity and practical support as possible to develop and control their own, renewable-based projects. It was also suggested that ‘Island Proofing’ and ‘Our islands, Our Future’ should be included in the ‘Influential policies and programmes’ section.

7.21. Comments highlighting other issues which respondents thought should be covered included:

• The core human rights principles of accountability and participation are weak.
• The three principles fail to acknowledge the importance of the impact of fuel poverty on people with, or who share protected characteristics. In particular it was suggested that age, long-term health conditions and disability have not been recognised sufficiently.
• There should be a stronger focus on targeting inequality.
• There is currently no acknowledgement of the right to an adequate standard of living, the right to housing, the right to food or the right to health within the policy objectives. It was suggested that it will not be possible to realise these rights without taking a rights-based approach to fuel poverty.
• Support and capacity building of local partnerships could be covered.
• The roles of local, community and individual assets are largely missing from the framework.

7.22. There was also a concern that the aim to ensure that dwellings occupied by fuel poor households have lower carbon emissions may cause some conflict as under current circumstances low-carbon fuels will not necessarily be the most cost-effective for fuel poor households. A fundamental concern was that the proposed definition of fuel poverty (as covered at Question 1) will lead to failure to adhere to or meet the three principles.

7.23. Other comments addressed one of the three principles themselves. Each of the three principles is set out in turn below along with analysis of the comments made.

The fuel poverty strategy will be firmly based on the principle of social justice and creating a fairer and more equal society, irrespective of whether individuals live in urban or rural Scotland.

7.24. Comments included that the first principle is not adequately reflected in the outcomes framework because:

• The outcomes are almost all targeted at low income households. If (as discussed at Question 1) ‘low income’ is determined by the UK MIS and AHC then inequality felt by island communities is not being addressed.
• The focus appears to be on the gathering of statistical information and property condition rather than a focus on outcomes for people.

7.25. Other comments included that one of the important dimensions of equality and fairness is tenure-neutrality and that private sector tenants in particular can be at a disadvantage both in terms of suffering fuel poverty and being less able to respond to it. A fuller consideration and statement of Fuel Poverty Strategy and the private rented sector was suggested.

7.26. It was also suggested that sustainability should be embedded in the first principle, alongside social justice, particularly in light of increasingly ambitious climate change goals. It was proposed that the first principle be amended to read ‘The fuel poverty strategy will be firmly based on the principles of social justice and sustainability and creating a fairer and more equal society, irrespective of whether individuals live in urban or rural Scotland’.

The Scottish Government's approach to fuel poverty eradication will be set on a statutory framework, measured and overseen by Ministers and delivered via partnership structures at a local level. Building on the assets of individuals and communities will be at the heart of this partnership and early intervention and prevention will be crucial to success.

7.27. Comments included that it is vital that areas, and particularly islands, are allowed the flexibility to develop a partnership that suits their local context and the unique issues they face. It was also noted that there is no mention of Community Planning Partnerships having ownership of this agenda, or of embedding fuel poverty targets in their Local Outcomes Improvement Plan.

7.28. Other comments were that:

• The second principle is not adequately reflected in the national strategy.
• The emphasis on early intervention and prevention would justify ensuring that householders are socially well-connected and supported.

The needs of individuals and families will be at the heart of service design and delivery and the fuel poverty strategy will address all four drivers of fuel poverty: income, energy costs, energy performance, and how energy is used in the home.

7.29. Comments made included noting the difference between a ‘needs based’ approach and a ‘rights based’ approach and it was suggested that the latter recognises the Scottish Government’s obligations to ensure people’s human rights are met. It was also suggested that participation is the cornerstone of a human rights-based approach but that there is no reference to how people who understand and have experienced fuel poverty will be able to guide the Strategy or hold the Government and other public authorities to account in the event of failure. On a similar theme, there was a call for the Scottish Government to clarify what level of support it will provide to people living in fuel poverty in order to be involved in the design and delivery of support and services.

7.30. Other comments included that:

• The fourth driver, ‘how energy is used in the home’ is a narrow interpretation of the factor of ‘occupant behaviour’. Putting the needs of individuals and families at the heart of service design should embrace the social dimensions of fuel poverty.
• The Strategy places more emphasis on energy performance than the other three drivers of fuel poverty.
• The correct intervention for taking some households out of fuel poverty may sometimes result in increased carbon emissions.
• There needs to be enough flexibility and recognition that delivery of services in rural areas will often be more labour intensive and time-consuming than in urban areas.
• A clause could be added to take into account the needs of future generations.

Question 21 - In your opinion, would the proposed framework help to strengthen partnerships on-the-ground?

a) If so, how?

b) If not, why?

7.31. Responses to Question 21 by respondent type are set out in Table 22 below.

Table 22: Response by Respondent type

Type of respondent	Yes	No	Not answered	Total
Organisations:
Community or Tenant Group or Federation	2		2	4
Energy Company		1	5	6
Health and Social Care	2		3	5
Housing Association	2	1	5	8
Housing Body or Group			3	3
Inter-agency Group or Partnership	1		4	5
Local Authority	11	4	6	21
Other	1	1	5	7
Research Group		1	1	2
Third Sector	2	1	16	19
Total organisations	21	9	50	80
% of organisations answering	70%	30%
Individuals	2		9	11
% of individuals answering	100%	0%
All respondents	23	9	59	91
% of all respondents	25%	10%	65%
% of all those answering	72%	28%

7.32. A majority of respondents, 72% of those answering the question, thought the proposed framework would help to strengthen partnerships on-the-ground.

7.33. A total of 36 respondents commented at Question 21a and 20 respondents at Question 21b. Please note that some of those who commented (primarily at 21a) had not answered the closed question. A breakdown of the number of comments received by respondent type is set out in Table 23 below.

Table 23: Number of comments by respondent type

Type of respondent	Number of comments at 21a	Number of comments at 21b
Organisations:
Community or Tenant Group or Federation	2
Energy Company	1	2
Health and Social Care	3
Housing Association	4	4
Housing Body or Group
Inter-agency Group or Partnership	3	2
Local Authority	16	7
Other	1	1
Research Group		1
Third Sector	4	2
Organisations	34	19
Individuals	2	1
All respondents	36	20

7.34. Those who thought the proposed framework would help to strengthen partnerships on the ground, most frequently pointed to the importance of working collaboratively to tackle fuel poverty. This was raised by around 1 in 7 of those who commented. Respondents also pointed to the importance of fuel poverty being established as a clear priority for the partnerships and the organisations they work with, (raised by around 1 in 9 of those who commented) and to all those involved understanding how they and others can contribute towards achieving shared outcomes. It was also suggested that the framework could help strengthen links between key services and support referrals to the national delivery schemes and to the other support networks available.

7.35. Otherwise, around 1 in 9 respondents who commented noted some of the conditions they believed would need to be in place for the collaborative approach to work successfully, including the availability of sufficient funding. It was also suggested that political buy-in and leadership from the top of local authorities will be as important, if not more important than the framework.

7.36. In terms of the framework itself it was suggested that it needs to be transparent and simple, that a simplified framework for local areas would be required and that local partners should be involved in further development of the framework.

7.37. Those who did not think the proposed framework would help to strengthen partnerships on the ground, and some respondents who did not answer the closed question, sometimes suggested that the framework needs to be developed further or needs to be clearer, including in relation to the connections.

7.38. Otherwise there was a question as to why the Scottish Government is focusing on partnerships and an associated concern that this focus risks placing additional operational demands disproportionately on the many small and under-resourced organisations who are doing valuable jobs in tackling fuel poverty.

7.39. On the framework itself, comments included that it needs to have clearer objectives and provide clarification on individual roles and responsibilities, funding, monitoring and evaluation and community participation. It was also suggested that the framework should set out statutory targets for local authorities and that it should refer to CPPs having ownership of resolving fuel poverty and the importance of embedding fuel poverty targets in Local Outcomes Improvement Plans.