Social housing net zero standard consultation: interim equality impact assessment

4. Extent/Level of EQIA required

4.1.1 The Scottish Government considers that an equalities impact assessment (EQIA) is required for this policy.

4.2 Stage 1: Framing

4.2.1 From what we know about socio-economic conditions and evidence of impacts of those in poorer households in equality outcome groups, it is likely that:

(a) People in these households will benefit from homes that are easier to heat, but

(b) The same people are at risk if the costs of meeting higher standards fall disproportionately on housing in the social rented sector.

4.3 Stage 2: Data Gathering

4.3.1 At Stage 2, the Scottish Government considered evidence about the potential impacts on people in regard to the following characteristics:

• Age
• Disability
• Sex
• Gender reassignment
• Sexual orientation
• Race
• Religion or belief
• Pregnancy and Maternity

4.3.2 A summary of the evidence relevant to the impact of this policy on the protected characteristic groups is set out below. This has been prepared from information currently known to the Scottish Government. The consultation will invite views of stakeholders on the evidence base. Our initial view is that the following areas should be explored further:

(1) Further analysis, if possible, on the relation between age, tenure and energy efficiency or fuel poverty;

(2) Further engagement with representatives of the Gypsy/Traveller community (this should build on the work of subgroup 4 of the EESSH2 Review);^[12]

(3) Invite views on any concerns among disabled people about the technology that may be needed to get to net zero;

(4) Note any additional data on gender reassignment emerging from the wider work of Housing to 2040.

The Scottish Government also gathered qualitative and quantitative data from:

• National Statistics: Scottish Household Survey, 2019
• National Statistics: Scottish House Condition Survey, 2019^[13]
• National Statistics: Poverty and Income Inequality in Scotland 2016-19
• National Statistics: Scottish Surveys Core Questions 2019
• National Statistics: 2011 Census
• Survey: The Scottish LGBT Equality Report 2015
• Qualitative Study: Melone, H., 2019
• Evidence Reviews: Liddell & Morris, 2010; Marmot Review Team 2011

4.4 Stage 3: Assessing the Impact

4.4.1 An initial impact of the assessment of the new standard for the protected characteristic groups, and any opportunity to promote better relations between groups, is set out below.

4.4.2 Further views will be sought as part of the public consultation, and a review of this EQIA will be carried out following the analysis of responses.

4.4.3 Summarised key findings of this EQIA are included below. A table is included in appendix A summarising the findings for each characteristic in more detail.

Have positive or negative impacts been identified for any of the equality groups?

This EQIA identified a range of potentially positive and negative impacts of the new Social Housing Net Zero Standard proposals and actions that will be undertaken to mitigate the negative impacts.

Is the policy directly or indirectly discriminatory under the Equality Act 2010?

There is no evidence that the policy is directly or indirectly discriminatory under the Equality Act 2010

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

N/A

If not justified, what mitigating action will be undertaken?

N/A

4.4.4 These impacts are considered against the Scottish Government’s Public Sector Equality Duty below, which requires authorities to have due regard to the following:

• eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010;
• These proposals will have no impact.
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
• There is a potential for impacts in regard to this aspect of the Public Sector Equality Duty, these impacts are discussed at length in the following section.
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
• These proposals have no impact.

4.4.5 Key findings have been that some people may experience negative impacts as a result of one or more protected characteristics. This has the potential to have negative results on the advancement of equality of opportunity between those who share certain protected characteristics and those who do not (as set out in the Scottish Government’s Public Sector Equality Duty). In particular these possible negative impacts centre around challenges with:

Age

• Cost (running costs of clean heating systems due to lower income levels); and,
• Engagement (accessibility of advice and services, sensitive to disruption in their home, being informed, included and supported).

Disability

• Cost (running costs of clean heating systems due to lower income levels); and,
• Engagement (accessibility of advice and services, sensitive to disruption in their home, being informed, included and supported).

Sex

• Cost (running costs of clean heating systems due to lower income levels).

Paternity and Maternity

• Cost (running costs of clean heating systems due to lower income levels).

Gender reassignment

• Cost (running costs of clean heating systems due to lower income levels).

Sexual orientation

• Cost (running costs of clean heating systems due to lower income levels).

Race

• Cost (running costs of clean heating systems due to lower income levels); and,
• Engagement (accessibility of advice and services, being informed, included and supported).

Religion or belief

• Cost (running costs of clean heating systems due to lower income levels); and,
• Engagement (accessibility of advice and services, being informed, included and supported).
• Impact on Cultural cooking practices.

Marriage and Civil Partnership

• None.

4.5 Stage 4: Recommendations and Conclusion

Access to advice and support

4.5.1 The Scottish Government currently provides free and impartial advice and support through Home Energy Scotland (HES). HES provides in-depth advice to householders on clean heating technologies and on how to reduce their energy bills.

Potential for increased costs

4.5.2 The Scottish Government are engaging with local authorities and registered social landlords on the affordability of the new Social Housing Net Zero Standard, and the support needed for the sector. We are committed to the principle that meeting our climate change targets should be a just transition, so that the burden does not fall unfairly on those least able to pay, and to make sure that no one is left behind.

4.5.3 Landlords are encouraged to make use of available funding sources, which includes the Social Housing Net Zero Heat Fund and other Scottish Government schemes.

4.5.4 At least £1.8bn over this Parliament is committed to be made available to help retrofit heat and energy efficiency measures. This includes the Social Housing Net Zero Heat Fund – investing in a sector already leading the way in the heat transition.

4.5.5 The Social Housing Net Zero Heat Fund launched in August 2020 and is making at least £200 million available to social landlords until 2026 for the retrofit of their existing housing stock.

4.5.6 The fund supports both the deployment of clean heating and ”fabric first” enhancements, helping landlords deliver warmer and more energy efficient homes.

4.5.7 Projects are eligible for up to 60% of the costs of clean heating systems and 50% of energy efficiency measures.

4.5.8 Rural and island communities face different challenges when delivering decarbonisation projects in social housing, so the fund has introduced uplifts to the average grant cap. For projects in rural areas, the average grant cap per property will be increased by 11% and in remote areas by 22%. Rural and Remote areas can be identified using the 6-Fold Scottish Government classification.

4.5.9 Our Scottish Fuel Poverty Advisory Panel oversee implementation of our Fuel Poverty Strategy, providing an important means of external scrutiny on our progress towards meeting the statutory targets and collectively holding the Scottish Government to account on its delivery. As the Fuel Poverty 2019 Act requires the Scottish Government to formally consult with the panel on the strategy, we expect their further advice to Scottish Ministers by Summer.

Improving thermal comfort

4.5.10 High standards of energy efficiency are essential to reduce the overall demand for energy. Alongside energy saving behaviours these measures can help to ensure running costs remain affordable.

Cultural and religious use of open flames for cooking

4.5.11 Many buildings use the same fuel for heating and cooking, particularly natural gas. When buildings switch away from using fossil fuel boilers, decisions on cooking appliances may also need to be made. As we consult through on these proposals, we will work with stakeholder groups to ensure that the outlook of those impacted by this change are fed in.

Public Sector Equality Duty (PSED)

4.5.12 The Public Sector Equality Duty (PSED) – requires relevant organisations to:

• eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010;
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

4.5.13 To ensure that we take an inclusive approach, we will identify and support people across the range of protected characteristics, ensuring that support is available as required. We will give due regard to the three requirements of the Public Sector Equality Duty (PSED) for all protected characteristics.

Monitoring and Review

4.5.14 The EQIA has been valuable in raising the overall awareness and understanding of the key issues affecting people with protected characteristics.

4.5.15 The impacts of the proposals being consulted upon on the protected characteristics have been considered as a result of the assessment.

4.5.16 During the consultation process, the Scottish Government will continue to work with a wide range of stakeholders, including organisations that work with or represent people with one or more of the protected characteristics to gain further insight into the impacts of these proposed policies. This insight will be fed into development of the new Social Housing Net Zero Standard.

4.6 Stage 5: Authorisation of EQIA

Declaration I am satisfied with the equality impact assessment that has been undertaken for the Consultation on a new Social Housing Net Zero Standard and give my authorisation for the results of this assessment to be published on the Scottish Government’s website.

Name:

Position: