The future of energy in Scotland: consultation analysis

3. Transforming Scotland's Energy use

3.1. Chapter 4 of the draft Energy Strategy focused on the consumption of energy in Scotland and outlined an energy efficiency target in line with the European Commission's proposed 30% target for 2030. Four priorities and 23 actions were outlined; respondents were asked to comment on these. These priorities were:

• Priority 1: Addressing the need to reduce demand and increase energy efficiency through the development of Scotland's Energy Efficiency Programme ( SEEP).
• Priority 2: Helping energy consumers to manage their bills, harnessing smart technology in the home and supporting new business models in the retail energy market.
• Priority 3: Supporting the introduction of viable, lower carbon alternatives across all modes of transport.
• Priority 4: Delivering enhanced competitiveness and improved energy efficiency in Scotland's manufacturing and industrial sectors.

Priorities for transforming energy use

Q8: What are your views on the priorities presented in Chapter 4 for transforming energy use over the coming decades? In answering, please consider whether the priorities are the right ones for delivering our vision.

Summary of main themes:

• There was overall support for the priorities outlined.
• A number of overriding themes emerged across the priorities, including:
  • a need to create a priority towards the reduction in energy demand as well as increased energy efficiency;
  • a need to highlight the importance of behaviour change and public buy-in;
  • the potential role for a central agency to deliver Scotland's Energy Efficiency Programme; and
  • a need for further integration across policy areas.
• There were a few suggestions for additional priorities to be incorporated into the final Strategy.

3.2. Comments on this question came from 162 respondents across all respondent groups.

3.3. There was support for the priorities coming from most of these respondents (127). Comments from these respondents included that the priorities are aligned with the vision or that they support local heat and energy efficiency strategies. Only two Individuals felt these were the wrong priorities.

Key themes common to all priorities

3.4. There are a number of overriding themes across the four priorities, some of them simply reiterating the priority, and these are addressed below. Additional themes relating to individual priorities are then outlined in the following paragraphs.

3.5 A need for a reduction in energy demand as well as increased energy efficiency: Many respondents referred to the need for this, with some concerns that increased energy efficiency could actually lead to an increase in demand. Allied to this, some of these respondents commented that the Scottish Government targets within the draft Climate Change Plan of a 6% reduction in the domestic sector and 10% in the commercial sector are too modest and at odds with the aim of decarbonising the heat supply in 80% of residential buildings and 94% of non-domestic buildings.

3.6 Linked to this, there were a small number of references to the need for the draft Energy Strategy to include an integrated whole systems benefits analysis.

3.7. Similarly, there were a number of calls to set more ambitious targets to reduce demand by 2030, for example, the UK Committee on Climate Change ( UKCCC) recommends that 65% of new car sales should be electric by 2030, compared with only 27% as set out in the draft plan.

3.8. A need for behaviour change and public buy-in: Many respondents from across most sub-groups commented on the need to bring about behavioural change to ensure the uptake of technology and the programmes required to achieve these priorities.

3.9. Linked to this, there were also comments from some respondents on the need for the provision of advice to consumers, businesses and communities.

3.10. A need for a central agency: Several respondents, mostly within the Third Sector / NGO or Community sub-groups noted the need for a central agency or national centre with responsibility for overall collaboration within the sector and to work with industry in the development of commercially viable energy efficiency solutions. Some of these respondents felt this role would sit well with Scottish Environment Protection Agency ( SEPA) who could be responsible for the collective development (along with other statutory bodies and other publicly-funded bodies such as CPPs) of strategies and implementation plans that reduce the carbon footprint of existing building stock and ensuring that new developments have low or net zero carbon levels.

3.11. The need for integration across policy areas: A small number of respondents noted that the draft Energy Strategy is fragmented at present. For example, one respondent noted the need for a holistic approach, not focusing only on energy but also incorporating environmental, economic and fuel policies.

3.12. Some respondents within the Energy sub-groups (mostly in the Non-Renewable sub-group) noted their concerns over the UK Government proposed increase to the Climate Change Levy from 2019, noting that this will increase charges to businesses as well as having the potential to undermine engagement with consumers and prevent new market entrants; this also runs counter to the UK's and the Scottish Government's decarbonisations objectives.

3.13. A small number of respondents noted the need for a greater emphasis within the Strategy using an "energy efficiency first" principle.

3.14. As at earlier questions many respondents reiterated points they had already raised, and which are covered in the cross-cutting themes chapter.

3.15. The following paragraphs outline key points made in relation to each specific priority.

Priority 1: Addressing the need to reduce demand and increase energy efficiency through the development of Scotland's Energy Efficiency Programme ( SEEP)

3.16. This section of the report should be read in conjunction with the consultation analysis of responses to the Consultation on Scotland's Energy Efficiency Programme ( SEEP), which provides greater detail on views of SEEP.

3.17. A number of key points were raised by a small number of respondents, most of whom were in the Third Sector / NGO, Community and Local Government sub-groups. A small number of respondents welcomed the inclusion of energy efficiency as a National Infrastructure Priority; although there were also a few calls for a statutory foundation for SEEP, which would incorporate targets, clear pathways and governance arrangements; with some comments that SEEP needs further development to ensure it can deliver on aspirations to reduce demand and increase energy efficiency. In relation to energy efficiency, a small number of respondents felt that greater priority needs to be given to energy efficiency, for example, all homes to be band C rated by the year 2025. A small number also commented on the need for a larger supply chain as well as opportunities for the supply chain.

3.18. There were some calls for SEEP and LHEES to be integrated, primarily because local authorities are not seen to have the necessary skills and resources to be able to manage these initiatives on their own. A small number of respondents also noted that there would need to be careful management for this priority.

3.19. A small number of respondents commented that progress to date can be attributed to 'low hanging fruit' (measures such as double glazing or loft insulation) and that it will not be easy to maintain the pace of progress to date without the adoption of new technologies.

Priority 2: Helping energy consumers to manage their bills, harnessing smart technology in the home and supporting new business models in the retail energy market

3.20. A small number of respondents noted that this priority needs to acknowledge the role played by smart technology in the non-domestic sector in order to ensure that the benefits of smart technology are realised beyond the domestic sector.

3.21. There were a few comments on the need for a fabric-first approach to existing buildings.

3.22. A small number of respondents noted that there is too much focus on smart meter roll out and that there is a need to consider other elements such as the development of the Internet of Things, remote access or new technologies. Allied to this, there were a few comments that more discussion is needed on smart meters and smart city energy systems, with one or two comments that smart technology is currently overrated and there should be industry-standardisation of smart meters. There was also comment that there needs to be stronger recognition of the wider range of enabling functions of smart meters, although a small number of respondents noted that some rural properties will not benefit from smart meters due to a lack of connectivity.

3.23. A small number of respondents noted their support for specific initiatives such as Our Power and Tower Power which have been used to reduce heat and fuel costs.

3.24. A small number of Individuals felt there should be more focus on renewables.

Priority 3: Supporting the introduction of viable, lower carbon alternatives across all modes of transport

3.25. Several respondents, primarily within the Local Government and Energy sub-groups noted there is too much focus on electric vehicles ( EVs) and asked for more support for a wider range of transport types, including heavy goods vehicles ( HGVs), buses and other public vehicles. They also felt there needs to be more emphasis on active travel and cycling and less overreliance on cars. However, some of these respondents noted that there are significant challenges around the electrification of HGVs.

3.26. A small number of respondents, within the Local Government and Third Sector / NGO sub-groups, felt that there is no clear strategic direction from the Scottish Government or Transport Scotland at present and suggested there is a need for a national approach in order to achieve maximum impact; linked to this, there is also a need for clear policies and pathways, with the Scottish Government mapping out more significant progress in the transport sector.

3.27. A small number of respondents, primarily within the Local Government and Energy sub-groups felt that the issue of grid constraints have not been dealt with under this priority. For example, they noted concerns that the electrification of the transport sector will place pressure on the existing grid in terms of capacity.

Priority 4: Delivering enhanced competitiveness and improved energy efficiency in Scotland's manufacturing and industrial sectors

3.28. There were few common threads emerging specifically in relation to this priority, with comments made by only a small number of respondents.

3.29. A small number of respondents noted that there is no discussion as to how this priority will be achieved, for example, what subsidy arrangements might be provided and / or for what industries. Allied to this, there were suggestions of introducing a carbon tax that recognises energy or carbon in imported goods so that businesses will be encouraged to be based in Scotland and / or avoid carbon leakage.

3.30. A small number of respondents also commented that this priority should also include reduction in waste, particularly in relation to energy in the manufacturing and industrial sectors.

3.31. A small number of respondents felt that the potential for energy savings in some sectors is limited and that it would be better to focus on sectors offering greatest potential (public sector and domestic) for energy efficiency improvements.

Additional priorities

3.32. A small number of respondents made suggestions for additional priorities or issues that need to be covered in the Energy Strategy. These included:

• Engaging all elements of civic society in bringing the priorities into a holistic national programme.
• Greater focus on fuel poverty; fuel poverty should be as integral to the whole programme as carbon reduction targets.
• Food / agriculture not specifically considered; for example agriculture is a significant source of greenhouse gas emissions, and there is a need for research on how to reduce the impact of these sectors.
• No reference to passive measures to reduce energy consumption through design of new developments; this is needed as part of an integrated approach.
• The actions identified should include specific reference to developing the supply chain opportunities that arise from investments. Also, that there is a need for a much larger supply chain to meet these priorities.

Actions for transforming energy use

Q9: What are your views on the actions for Scottish Government set out in Chapter 4 regarding transforming energy use? In answering, please consider whether the actions are both necessary and sufficient for delivering our vision.

Summary of main themes:

• Many respondents, across groups, simply voiced support for the actions in general or for specific actions.
• Some suggestions made reiterated points made to the previous question; some cut across all the actions.
• Respondents noted a number of cross-cutting themes.

3.33. Comments on this question came from 138 respondents across all respondent groups.

3.34. There were a total of 23 actions set out under these 4 priorities, and a full listing of these is in Appendix 3. The number of actions under each priority were as follows:

• Priority 1: Reduce demand and increase energy efficiency - 5 actions
• Priority 2: Smart technology and new business models - 5 actions
• Priority 3: Lower carbon transport alternatives - 8 actions
• Priority 4: Scotland's manufacturing and industrial sectors - 5 actions

3.35. There was support for some or all of these actions coming from almost half of these respondents, many of whom, across various sub-groups, reiterated comments made at the previous question regarding the overall priorities, or noted their support for the actions. A very small number noted their opposition to these actions.

3.36. Many respondents, across groups, simply voiced support for the actions in general or for specific actions; these supportive comments were all brief, along the lines of 'the respondent supports x'.

3.37. A number also gave their views on actions under each of the priorities (albeit small numbers commented on each) and / or suggesting additional actions. These comments and suggestions are outlined in Appendix 3.

3.38. Some suggestions cut across the actions overall, many of which are referenced in the cross-cutting themes chapter. These suggestions related to:

• A need for more ambitious targets to encourage the modal shifts on a scale necessary to make notable reductions in energy demand.
• The need for consistent approaches to be adopted across Scotland, albeit that they need to allow a degree of flexibility to meet local needs.
• The need for awareness raising among customers, and for public engagement, allied to access to advice and support.
• The need for collaboration and partnership working across all relevant stakeholders.
• A need for monitoring / evaluation / appraisal.

Setting an energy efficiency target

Q10: What ideas do you have about what energy efficiency target we should set for Scotland, and how it should be measured? In answering, please consider the EU ambition to implement an energy efficiency target of 30% by 2030 across the EU.

Summary of main themes:

• There was overall support for an energy efficiency target, although several respondents felt this needs to be more ambitious and there were requests for clarification of the baseline year.
• Key elements for any target included a need for this to be explicit, to have a clear pathway, to be transparent, and to be long term with interim targets based on specific milestones, with regular monitoring and reporting.
• There were requests for integration across the transport, heat and electricity sectors.

3.39. Comments on this question came from 126 respondents across all respondent groups.

3.40. Many of these (55), across all respondent groups, noted their support for an energy efficiency target for Scotland, with some commenting on the need to align this with the EU ambition to implement an energy efficiency target of 30% by 2030 across the EU.

3.41. A need for a more ambitious target: Several respondents, primarily within the Third Sector / NGO, the Community and Local Government sub-groups and Individuals, commented that this target should be more ambitious, with some comments that the target needs to incorporate efficient energy use across a wide range of energy sources. A small number of these respondents provided an alternative target, mainly that this should be raised to 40%, although one Individual suggested it should be set at a level of 50%. Reasons given included that the energy efficiency actions outlined in the draft Climate Change Plan for 2018-2032 should be delivered by 2025 and there is scope for additional savings from energy efficiency to be made in the domestic sector.

3.42. A small number of respondents noted the need to clarify the baseline year. For example, a respondent in the Local Government sub-group noted:

"It is unclear from the consultation document what the baseline year is for the 30% energy reduction target. Is the baseline 2005-07 and the 30% target is building on the success in reaching the 12% reduction target by 2020? Or will the Scottish Government set a new baseline year for this 30% target?"

3.43. A small number of respondents did not support the EU target.

3.44. Setting an energy efficiency target: In considering how an energy efficiency target for Scotland should be set and measured, some respondents made general comments about a number of issues they felt would impact on this. A small number of respondents noted that there is a need for any target set to be explicit, to have a clear pathway and be transparent, and that the target would need to be long term with interim targets based on specific milestones. There were also a small number of requests for regular or annual reporting and with progress being monitored using a range of indicators linked to an understanding of other factors that are influencing any change.

3.45. Several respondents, primarily within the Energy sub-groups, felt that integration between the transport, heat and electricity sectors is key, with some also noting that there need to be links across different policy areas. That said, some respondents commented on the need for individual sector targets as it would be unfair to expect all sectors of the economy to contribute equally. Allied to this, there were some calls - primarily from the Local Government sub-group - for recognition of local conditions in target setting.

3.46. Small numbers of respondents referred to measurements that could be used in monitoring an energy efficiency target; and these included:

• Should be measured in same way as EU target.
• Reduction of carbon dioxide emissions, as set out in the Climate Change Act and the Climate Change Plan.
• Reduction in the number of households in fuel poverty.
• Variables including the weather, economic cycles and energy prices (mainly from respondents in the Local Government sub-group). This could also include additional factors such as the number of miles travelled or the number of homes heated.
• The intensity of energy use (mainly from respondents in the Local Government sub-group).
• Behaviour change such as increased energy efficiency on the part of consumer.
• Setting a minimum EPC standard, for example, that all homes should be EPC Band C by 2025, together with penalties for social landlords who fail to comply. That said, there were also a small number of comments that an alternative data source should be used or that there needs to be changes and improvements to the EPC methodology.
• The reduction of energy use in building stock, with some reference to the need for retrofit in existing residential and non-residential buildings; or passive energy measures such as improved insulation.
• The elimination of waste energy such as by-product heat.
• The number of households or businesses switching to renewable energy.
• The amount of energy needed to generate a unit of GDP.
• A target linked to the Climate Change Plan's ambition for energy efficiency.
• Improvements to the overall system efficiency of energy supply.

3.47. A small number of respondents noted that any target should be informed by past trends and available resources and pointed to the need for data sharing.

Additional recurring sub-themes

3.48. There were a number of recurring sub-themes in comments at this question. Most commonly these included:

• Uncertainties around Brexit and the need for clarity on this before signing up to a new EU based energy efficiency target.
• The role(s) that could be adopted by the Scottish Government in support of any target, including close working with local authorities and other stakeholders in delivery of the Strategy, the provision of financial investment and / or incentives.
• A need for changes to building regulations and building standards.