Equity loan scheme - call for evidence: consultation

Chapter 4 Fuel Poverty and Consumer Protection

4.1 As set out in the Fuel Poverty Act, we want to see the energy efficiency of homes with fuel poor households improved so they reach an energy efficiency rating equivalent to Energy Performance Certificate C by 2030 and B by 2040. This aims to balance the ambitions of achieving net-zero with ensuring a Just Transition and improving the lives of those in fuel poverty.

4.2 It is recognised that increased energy efficiency and a fabric first approach alone will not be enough to reduce emissions to meet our climate change targets, however such measures are seen as a critical pre-cursor to the deployment of many zero emission heating systems to ensure that the transition to zero emissions heating does not lead to increased running costs. This will remain at the core of our approach to all fuel poverty interventions.

4.3 We will review the eligible measures for any expansion of the Equity Loan to remove fossil fuel solutions and include zero emission heating solutions such as heat pumps. Where zero emission heat solutions are not technically feasible or financially viable, or where they would otherwise lead to higher running costs for fuel poor households, secondary technologies will be considered such as solar PV and thermal storage, alongside energy efficiency improvements and fabric repairs.

4.4 The need for consumer protection in the zero emissions heat and energy efficiency sector - particularly for those in vulnerable circumstances - has been highlighted by consumer organisations as an area of current and growing concern as the rate of installations increases. As we design new heat and energy efficiency delivery schemes, we will aim to create the necessary environment to allow exemplary practice to become the norm and to ensure that confidence in energy efficiency and zero emissions heat measures is not undermined by poor or illegal practice. We will learn lessons from the design and implementation of consumer protection frameworks in similar schemes, both at home and further afield. As consumer protection is reserved to the UK Government, we will work closely to ensure protections are fit-for-purpose in Scotland.

4.5 Should the Equity Loan proceed with expansion to full scheme, we propose adopting the latest retrofit standards to ensure consumers receive high quality work carried out by skilled operatives. We are also considering the use of the UK Government endorsed TrustMark quality assurance framework which includes a Consumer Code and Consumer Charter.

Questions

7. a: Do you agree that a nationwide Equity Loan can support the reduction of fuel poverty in Scotland?

b:Do you have any suggestions on how a future scheme could better support a reduction in fuel poverty in Scotland? Please explain your answer.

8. a: The Equity Loan Pilot uses the EPC recommendations as a basis for eligible measures which can be funded by the loan and we will be consulting on a reformed EPC assessment process to better align with wider net zero objectives as part of our Heat in Buildings Strategy. Do you agree with using the EPC in this way for a future scheme?

b:Can you provide any alternatives? Please explain your position.

9. a: Do you agree with the proposed approach to consumer protection set out above?

b: Are there any additional consumer protection measures that can be considered within Scottish Government competence? Please explain your position.