Fuel Poverty Strategy for Scotland: consultation analysis

8. Assessing impacts

Summary of Questions 22 to 24

• A majority (59%) thought the proposals would have a positive impact for people with protected characteristics, including by targeting those most in need.
• However, there was a concern that the proposed definition of fuel poverty does not properly recognise the issues faced by rural and island communities. It was noted that there is a higher proportion of older people in many rural and island communities.
• The proposal that MIS thresholds will not be adjusted for households where at least one member is long-term sick or disabled was seen as having the potential to have a negative impact on people with a disability.
• In terms of implications for delivery organisations, local authority respondents were amongst those who pointed to the need for additional funding.
• Opportunities for business development and job creation were identified as potential benefits.
• A majority (65%) thought there would be a positive impact for children’s rights, most frequently because any initiative to reduce inequalities or target fuel poverty in households with children is welcome.

8.1. In Section 8 the consultation paper explains the assessments being carried out to evaluate the impact of implementing the proposals. It asks for respondents’ views on impacts in three areas – Equality, Business and Regulatory, and Children’s Rights. The Equality Impact Assessment ( EQIA) will help to understand policy impacts on people because of their age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, or sex and sexual orientation.

Question 22 - Do you think any of the proposals set out in this consultation will have an impact, positive or negative, on equalities as set out above? If so, what impact do you think that will be and, if negative, how do you think these could be mitigated?

8.2. Responses to Question 22 by respondent type are set out in Table 24 below.

Table 24: Responses by respondent type

Type of respondent	Positive Impact	Negative Impact	No Impact	Not answered	Total
Organisations:
Community or Tenant Group or Federation	3			1	4
Energy Company				6	6
Health and Social Care	1	1		3	5
Housing Association	1	4		3	8
Housing Body or Group	1	1		1	3
Inter-agency Group or Partnership	2	1		2	5
Local Authority	11	1	2	7	21
Other		1	1	5	7
Research Group		1		1	2
Third Sector	3	2	1	13	19
Total organisations	22	12	4	42	80
% of organisations answering	58%	32%	11%
Individuals	2	1	0	8	11
% of individuals answering	67%	33%	0%
All respondents	24	13	4	50	91
% of all respondents	26%	14%	4%	55%
% of all those answering	59%	32%	10%

Figures do not sum to 100% due to rounding

8.3. Of respondents who answered the question, 59% suggested there would be a positive impact for people with protected characteristics, while 32% thought impacts would be negative and 10% did not foresee any impacts.

8.4. A total of 56 respondents provided an additional comment, with a breakdown of the number of comments by respondent type is set out in Table 25 below.

Table 25: 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	4
Housing Association	6
Housing Body or Group	2
Inter-agency Group or Partnership	5
Local Authority	19
Other	5
Research Group	1
Third Sector	7
Organisations	53
Individuals	3
All respondents	56

8.5. Respondents who took a generally positive view of the impacts of the proposals (around 1 in 5 of those who commented) suggested benefits would include reducing inequality, targeting those most in need and making fuel poverty a priority. However, some concerns about the outcomes in rural and island areas and the effect of raising the age threshold were also expressed.

8.6. Respondents taking a generally negative view (around 1 in 5 of those who commented) often referred to their fundamental concerns that the proposed definition of fuel poverty does not properly recognise the issues faced by rural and island communities.

8.7. A small number of respondents suggested they were unable to judge the likely impacts of the proposals because of a lack of information on delivery mechanisms or over-reliance on proxy data and statistics.

8.8. Other general points included alternative assessments that could or should be carried out including:

• A full Equalities Impact Assessment.
• An integrated Health Inequalities Impact Assessment ( HIIA). Incorporating health, equality and human rights impact assessments, this was suggested to be valuable in assessing the potential to reduce health inequalities.
• An Equality and Human Rights Impact Assessment. Development of both qualitative and quantitative means of identifying impacts was suggested to be a key priority for the implementation of the Strategy.

8.9. The importance of outreach work to connect with equalities groups and help them engage with services was also highlighted. It was noted that those who find it most difficult to afford their fuel bills may be unlikely to seek help to reduce their costs and that ensuring equality for this group should be at the heart of the Strategy.

8.10. Collection of equalities information as a core element in the monitoring process was also suggested to be important, as was involvement of organisations representing equalities groups in the design, delivery and evaluation of the programme.

8.11. Attention was also drawn to the Scottish Government’s 2015 report ‘Review of Equality Evidence in Rural Scotland’, with a suggestion that many of the groups identified therein will be vulnerable to the effects of fuel poverty, and that this should be used to target and prioritise resources.

Protected characteristics

Age

8.12. Negative impacts identified with respect to age were sometimes associated with the respondent’s view of the wider negative effects of the proposals for rural and island communities, many of which have a high proportion of older people.

8.13. Around 1 in 7 of those who commented suggested the proposed change in the age threshold to have potentially negative impacts on those between 60 – 75 years and as not taking account of variations in life expectancy across Scotland. While one respondent suggested retention of eligibility for those who are vulnerable to be sufficient mitigation, others pointed to the importance of additional work recommended by the Definition Review Panel (i.e. to develop a specific list of health and disability categories, as well as age bands, which would satisfactorily encompass the term ‘vulnerable to the adverse health and wellbeing impacts of living in fuel poverty’) to mitigating potential impacts.

8.14. Children under 5 were also identified as potentially experiencing negative impacts if there is no enhanced heating regime for households with children under 5. It was suggested that although the consultation paper notes there is a lack of evidence on the need for a higher temperature for bedrooms of children under the age of 5, no allowance is made for households needing to heat their home for longer periods of time, as they might spend more time at home.

Disability

8.15. Negative impacts identified centred on the proposal that MIS thresholds will not be adjusted for households where at least one member is long-term sick or disabled. This was suggested as having the potential to have a negative impact on people with a disability and their carers. This was raised by around 1 in 5 of those who commented.

8.16. It was also noted that independent living is an important human right enshrined in the Convention on the Rights of Persons with Disabilities and it was argued that the definition of fuel poverty should address the increased costs that households including a disabled person or person with a long-term illness face.

8.17. The addition of a disability enhancement of £83 a week to the MIS for other living costs faced by disabled people was proposed in mitigation.

Race

8.18. It was suggested there may be a positive impact for BME groups as the new definition could allow more BME households to fall within the scope of fuel poverty programmes. It was also argued that outcomes for BME communities must be monitored and recorded to ensure that disparate effects are not missed.

8.19. Lack of measures to reduce fuel poverty among the Gypsy/Traveller community living in caravans and mobile homes was highlighted. Work with the community to identify steps that could be taken to reduce fuel poverty was suggested, including specific work around examining energy prices on some local authority sites. Issues including being unable to switch fuel supplier and the use of prepayment meters were identified as contributing to high energy costs.

Pregnancy

8.20. The absence of an impact assessment relating to pregnant women was noted and it was suggested that this is an issue that needs to be addressed urgently. Reasons given included health issues and the need for early intervention in tackling inequality as it was suggested that children born into poverty are more likely to continue in poverty and experience additional inequalities.

Sex and sexual orientation

8.21. Deduction of childcare costs from AHC was suggested as of particular benefit to women as more will be considered fuel poor and eligible for assistance.

8.22. Absence of an enhanced heating regime for children under 5 was suggested to have a potentially negative effect for women as the most likely to remain at home with children under 5.

General points on assessing impact

8.23. Respondents also made a small number of general points relating to impacts including:

• Querying the absence of an island impact assessment.
• Suggesting there should be assessment against the requirements of the new socio-economic duty.
• Suggesting a broader approach, linking this Strategy to other Scottish Government strategies and legislation. Specific suggestions included Child Poverty, Transport Poverty, Mental Health, the upcoming Healthier Futures Strategy, the new Social Security Bill and the Race Equality Framework.

8.24. Moving on to the second type of impact, the consultation paper explains that a Business Regulatory Impact Assessment ( BRIA) allows assessment of the likely financial costs and benefits and the associated risks of the proposals that might have an impact on the public, private or third sector.

Question 23 - What implications (including potential costs) will there be for business and public sector delivery organisations from these proposals?

8.25. A total of 53 respondents provided an answer to Question 23. A breakdown of answers by respondent type is set out in Table 26 below.

Table 26: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	3
Energy Company	2
Health and Social Care	3
Housing Association	6
Housing Body or Group	3
Inter-agency Group or Partnership	4
Local Authority	18
Other	4
Research Group	1
Third Sector	7
Organisations	51
Individuals	2
All respondents	53

8.26. Around 1 in 8 respondents who answered the question commented that they are unclear what the implications might be at this stage, sometimes pointing to lack of detail in the current proposals.

Additional work or costs

8.27. Requirements for additional staff time, numbers, specialism or training were suggested as implications of the proposals, with specific elements mentioned including:

• Requirements for additional work to collect and assess data and, in particular, the proposed doorstep approach.
• Increased burdens in terms of reporting and monitoring.

8.28. It was suggested that additional costs associated with enabling work could reduce the funds for delivery, or that additional funds would be required. Good partnership working and making best use of available data were suggested to have the potential to reduce costs.

8.29. A small number of respondents pointed to increased costs to both businesses and delivery organisations, particularly when working in remote rural and island communities. Flexibility around funding and delivery were suggested to be important and the need for rural proofing or island proofing were again raised.

Additional funding

8.30. Local authority respondents in particular were amongst those who pointed to the demand on existing resources and the need for additional funding or longer-term funding. Around 1 in 5 of those who answered the question made this point. The Scottish Government was urged to work with councils and others to make a realistic estimate of costs as the basis for a discussion about what can realistically be achieved with the resources available, as well as the potential impacts on other programmes.

8.31. Energy efficiency improvements were noted as requiring significant investment through SEEP as well as actions to encourage investment in the private sector. SEEP funding of around £10bn over the first ten years was estimated to be needed, with a suggestion that 45% of this should come from public funds.

8.32. Government support for rural landlords to upgrade traditional buildings was also suggested to be needed to reduce the risk of these properties being lost from the private rental market.

Economic benefits

8.33. Around 1 in 6 respondents who answered the question identified opportunities for job creation as a possible benefit, with a smaller number suggesting the potential for business development and that sustainable funding sources could give private companies the confidence to set up in remote areas. Energy efficiency improvements were particularly noted to bring economic benefits, and to be a labour-intensive industry. Warmer Homes Scotland was suggested as offering a good model to support local jobs and training which could be replicated and scaled up.

8.34. Where possible, it was suggested, local supply chains should be supported, although also that local businesses may not be able to cope with demand. A further cautionary note sounded was that any policy changes that adversely affect delivery to island communities could damage local supply chains and could lead to job losses.

8.35. Development and delivery of local energy systems were also noted to provide business opportunities.

Other benefits

8.36. Respondents also suggested that any additional costs should be offset by benefits including improved healthcare outcomes or that they expected long-term outcomes should be positive. Specifically, it was suggested that improving the energy efficiency of all fuel poor homes to EPC band C would deliver savings of £40-80 million per year to the NHS.

8.37. The final question in the consultation paper concerned children’s rights. It was explained that a Children's Rights and Wellbeing Impact Assessment ( CRWIA) will allow assessment of whether the proposals will advance the realisation of children's rights in Scotland and protect and promote the wellbeing of children and young people.

Question 24 - Do you think any of these proposals will have an impact, positive or negative, on children's rights? If so, what impact do you think that will be and, if negative, how do you think these could be mitigated?

8.38. Responses to Question 24 by respondent type are set out in Table 27 below.

Table 27: Responses by respondent type

Type of respondent	Positive Impact	Negative Impact	No Impact	Not answered	Total
Organisations:
Community or Tenant Group or Federation	2			2	4
Energy Company				6	6
Health and Social Care	2			3	5
Housing Association		2	1	5	8
Housing Body or Group		1		2	3
Inter-agency Group or Partnership	1	1		3	5
Local Authority	12		3	6	21
Other		1	1	5	7
Research Group		1		1	2
Third Sector	5		1	13	19
Total organisations	22	6	6	46	80
% of organisations answering	65%	18%	18%
Individuals	2	1	0	8	11
% of individuals answering	67%	33%	0%
All respondents	24	7	6	54	91
% of all respondents	26%	8%	7%	59%
% of all those answering	65%	19%	16%

Figures do not sum to 100% due to rounding

8.39. Of respondents who answered the question, 65% suggested there would be a positive impact for children’s rights, while 19% thought impacts would be negative and 16% did not foresee any impacts.

8.40. A total of 45 respondents provided an additional comment, with a breakdown of the number of comments by respondent type set out in Table 28 below.

Table 28: Number of comments by respondent type

Type of respondent	Number of comments
Organisations:
Community or Tenant Group or Federation	1
Energy Company	2
Health and Social Care	3
Housing Association	6
Housing Body or Group	2
Inter-agency Group or Partnership	4
Local Authority	18
Other	1
Research Group	1
Third Sector	4
Organisations	42
Individuals	3
All respondents	45

8.41. Around 1 in 4 of those who commented expressed a view that any initiative to reduce inequalities or target fuel poverty in households with children is welcome. The desirability of the Fuel Poverty Strategy adopting a rights-based approach was suggested by several respondents.

8.42. It was also argued that while the introduction to the consultation paper recognises the negative impact of fuel poverty on children’s health and wellbeing, this is not reflected in the Strategy. Specifically, it was suggested that reference to duties placed on local authorities and NHS Boards under the Child Poverty (Scotland) Act 2017 could help to connect priorities and strengthen action, particularly at a local level.

Positive impacts

8.43. Among reasons given for suggesting positive impacts were better targeting of households in fuel poverty, or that use of the MIS, AHC income, and deduction of childcare costs means that more households with children will be included as fuel poor and eligible for assistance.

8.44. Benefits identified for children included improved living conditions and quality of life, better health and wellbeing, and improved educational achievement. A small number of respondents also referred to the value of improved social inclusion and to children having a better sense that society cares about them and their families.

8.45. Respondents anticipating positive impacts sometimes added caveats to the effect that this would not be the case if the new Strategy places rural areas at a disadvantage or that they were assuming the Strategy would address all main and fluctuating drivers of fuel poverty.

Negative impacts

8.46. Negative impacts arising from the new definition of fuel poverty were suggested, including that resources may be diverted away from households with children. Other negative impacts included that the timescales being adopted are too long.

8.47. References to the United Nations Convention on the Rights of the Child ( UNCRC) included suggestions that:

• Removal of the enhanced heating regime for children under 5 might affect the right of children to an adequate standard of living under article 27.
• The Scottish Government should incorporate the UNCRC and also the United Nations Convention on the Rights of Persons with Disabilities ( UNCRPD) into the final Strategy.

Mitigating action suggested with respect to the first point above was to assess whether there is sufficient evidence on the impact on children under 5 of reducing the enhanced temperature and the number of hours of heating.