Heat in buildings strategy: equality impact assessment

Background

Policy Aim

8. Following the passage of the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, Scotland has set a statutory target for net-zero greenhouse gas emissions by 2045, with interim emissions reductions of 75% (by 2030) and 90% (by 2040).

9. This followed the First Minister's recognition of a global climate emergency. In response, the Scottish Government set out the initial action it would take, as part of the Programme for Government 2019-2020.

10. The Scottish Government committed to publishing a draft Heat Decarbonisation Policy Statement, providing an update to the 2015 Heat Policy Statement in the summer of 2020, but due to the ongoing Covid-19 pandemic this was delayed until the winter of 2020/21.

11. Scottish Ministers then took the action to merge the Statement with an update to the Energy Efficiency Route Map creating the Heat in Buildings Strategy, a single policy framework to eliminate emissions from buildings by 2045.

12. In December 2020, the Scottish Government published a Climate Change Plan update , which set out that to meet our emissions reduction targets, emissions from buildings must fall 68% by 2030 against 2020 levels.

13. The draft Heat in Buildings Strategy was published in February 2021. Following consultation, and analysis of responses, the Scottish Government has now published a final Heat in Buildings Strategy.

14. This final Heat in Buildings Strategy sets out a pathway to zero emissions buildings by 2045 and details a series of near-term actions to put us on a clear path towards this, as well as a range of further, longer-term commitments to accelerate the transformation of the nation's building stock. It sets out the principles we will apply to ensure our zero emissions heat delivery programmes support our fuel poverty objectives.

Summary of desired outcomes of the Heat in Buildings Strategy

15. The Strategy sets out a vision for over 1 million homes in Scotland to convert to zero emissions heating by 2030 and the equivalent of 50,000 non-domestic buildings. Emissions will have to fall by 68% by 2030 as compared to 2020 and to maintain progress towards our statutory emissions reduction targets, heating installations must scale up to provide at least 124,00 systems installed between 2021 and 2026. The installation rate will need to peak at over 200,000 new systems per annum in the late 2020's which is above the natural replacement rate for boilers.

16. In terms of energy efficiency, the Strategy sets out that where technically and legally feasible and cost-effective, by 2030 a large majority of buildings should achieve a good level of energy efficiency, which for homes is at least equivalent to an EPC Band C, with all homes meeting at least this standard by 2033.

17. The Strategy is aligned with wider Scottish Government policy on housing, energy, and climate change. The actions it sets out are reflected in our Housing to 2040 Strategy, which also presents further details on how our housing can support achievement of Scotland's net zero ambitions, whilst also delivering against wider objectives.

18. We envisage that the delivery of our Heat in Buildings Strategy will secure a wider set of outcomes that will benefit Scotland's people and places. These Heat in Buildings outcomes are aligned with our National Performance Framework, and will guide our decision making and support the development of a holistic, people-centred approach to the transition ahead. They are:

• Heating our homes and buildings no longer contributes to climate change
• The cost of heating our homes and business is affordable and those occupying them have a high comfort level
• We have reduced our demand for heat and poor energy efficiency is no longer a driver of fuel poverty
• The systems we use are smart and resilient and provide us with a reliable source of heat
• We have a secure supply chain with high value, local, sustainable jobs across Scotland and people have been helped to transition to new, secure jobs as part of a just transition
• Our indoor and outdoor spaces are filled with cleaner air
• Our heating systems enable and efficiently use Scotland's renewable energy resources
• Electricity and non-electrical fuels are produced from sustainable sources in a way which is consistent with net zero emissions and biodiversity targets
• Our heating systems enable the flexible and stable operation of our energy networks

19. The Heat in Buildings Strategy forms the foundation of our ongoing work, which will build on the insight and evidence generated by the consultation and wider input. Next steps include:

• We will develop our approach to heat in islands and remote rural contexts in our forthcoming Islands Energy Strategy in 2022 (which will complement the existing National Islands Plan).
• We have separately committed to publish a refreshed Energy Strategy and an Energy Just Transition Plan in Spring 2022. This will allow us to further refine our approach to heat in buildings, ensuring a coherent whole-system view and further embedding our evolving policies within our wider approach to delivering on a just transition.
• We will set out our approach to eradicating fuel poverty in the Fuel Poverty Strategy by the end of 2021.
• We will develop a bespoke Public Engagement Strategy for heat in buildings.
• We will co-produce with the sector a Supply Chain Delivery Plan focussed on the development of energy efficiency and zero emissions heat in the buildings supply chain in Scotland.
• We will establish a Green Heat Finance Taskforce by the end of this year.

20. The Strategy sets out that as we transform our homes and buildings over the next two decades we will do so in a way that continues to help eradicate fuel poverty and protect our most vulnerable citizens.

21. In addition to this, the Scottish Government's ambition to eradicate child poverty is set in statute through the Child Poverty (Scotland) Act 2017. The headline measure is to reduce relative child poverty from around 24% (240,000 children) to fewer than 10% (100,000) children by 2030-31, with an interim target of 18% (180,000 children) to be met by 2023-24. We will publish our second Tackling Child Poverty Delivery Plan in March 2022.

22. Further, the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 requires that by 2040, as far as reasonably possible no household in Scotland is in fuel poverty and, in any event, no more than 5% of households in Scotland are in fuel poverty and no more than 1% of households in Scotland are in extreme fuel poverty, and the median fuel poverty gap is no more than £250 adjusted for 2015 prices.

23. As we transform our homes and buildings by making them more energy efficient and installing low and zero emissions heating, we will consider local surroundings and resources, whether in dense urban or suburban areas or smaller rural towns and villages or in our remote and island communities. As such, the transition to zero emissions buildings may look different in different communities and will require approaches tailored to place.

Public Sector Equality Duty

24. In developing our strategy the Scottish Government is mindful of the three needs of the Public Sector Equality Duty (PSED):

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

25. Where any negative impacts have been identified, we have sought to mitigate/eliminate these. We are also mindful that the equality duty is not just about negating or mitigating negative impacts, as we also have a positive duty to promote equality.

Who will it affect?

26. The Heat in Buildings Strategy will impact building owners, including homeowners and landlords (including social housing providers) as well as their tenants, owners of business and commercial premises, public sector building owners, and residents across Scotland in communities and geographies of all types regardless of the protected characteristics. However, we expect the Strategy to affect different groups in different ways. Evidence suggests that the following groups may be more impacted than others:

• Those in or at risk of fuel poverty
• Those with lower incomes and lower wealth
• Tenants
• Those in comparatively disadvantaged or deprived areas
• Those in hard to treat properties or in remote and rural areas which may have a more restricted technology choice.

27. Further, it is possible that impacts may be varied and potentially more acute based on protected characteristics (age, disability, sex, gender reassignment, sexual orientation, race, religion or belief, pregnancy and maternity).

28. The costs of the heat transition will impact everyone and if there were no support provided, those in these groups may see increased costs for the conversion to low and zero emissions heating systems, as well as potentially increased running costs. The Strategy is clear that support will be targeted at those least able to bear these costs.

29. The actions from the Strategy will be able to provide multiple benefits to all people living in Scotland by:

• Reducing greenhouse gas emissions thus helping to meet our climate change targets;
• Making our homes and buildings warmer and more comfortable
• Reducing our demand for heat and removing poor energy efficiency as a driver of fuel poverty;
• Introducing systems which are smart and provide a reliable source of heat;
• Creating a secure supply chain with high value local sustainable jobs across Scotland and helping people to transition to new, secure jobs as part of a just transition; and,
• Providing cleaner air in outdoor and indoor spaces.

What might prevent the desired outcomes being achieved?

30. The desired outcome for the Strategy is for at least 1 million homes in Scotland to be zero emissions by 2030 alongside the equivalent of 50,000 non-domestic buildings.

31. Significant stakeholder time and knowledge has gone into the drafting of the Strategy. We have consulted extensively through a full public consultation and stakeholder workshops and established an External Advisory Group (EAG). This group is made up of external Stakeholder representatives, including from the energy and housing sectors, who provided input into key policy areas during the development of the Strategy.

32. Key risks that might prevent the desired outcomes from being achieved, specifically in relation to this EqIA, include:

• Lack of adequate engagement and information for the public
• Lack of support for the installation of low and zero carbon heating systems

33. We are developing a bespoke public engagement strategy for heat in buildings, which will raise awareness of the support and advisory services available and to encourage home upgrades. This builds on the objectives and guiding principles of our Public Engagement Strategy for Climate Change, as well as our existing support and advice programmes.

34. We also have a range of delivery programmes which currently provide, and will continue to provide, support for consumers (such as CARES, Area Based Schemes, and Warmer Homes Scotland). These are outlined further in this EqIA.