Home Energy Efficiency Equity Loan pilot - call for evidence on potential national rollout: analysis of responses

Fuel Poverty and Consumer Protection

Q7a. Do you agree that a nationwide Equity Loan can support the reduction of fuel poverty in Scotland? Please explain your answer

Twenty-six respondents provided a comment in their answer to this question.

Positive impact on fuel poverty

The most prevalent theme was agreement that a nationwide scheme could have a positive impact on reducing fuel poverty, either in isolation or in conjunction with other initiatives. Two-thirds of those who responded agreed either that this was the case, or felt that it had been demonstrated by the pilot.

A commonly mentioned reason was that the loans provided access to funds for people who may not be eligible for other schemes. One respondent noted that the scheme also includes support for disrepair, which can often be a barrier preventing energy efficiency upgrades under other schemes where support for repairs are not included. There was also an appreciation that the scheme aided specific vulnerable groups, particularly older people.

Broader suggestions for changes to the scheme

The next most commonly mentioned theme was suggestions for improvements or additions to the scheme to make it more effective. As this was the focus of Q7b, these comments have been included in the analysis at that section of the report.

Other less commonly mentioned themes

A few respondents highlighted other benefits of the approach. These centred on the improved condition of the property more generally, leading to more comfortable living conditions and better health and wellbeing. One called for these additional benefits to be included in future awareness campaigns for the scheme to boost participation. Another noted the scheme's contribution in helping people to improve their circumstances while reducing the amount of public money used to do so.

Other comments made by a small number of respondents included the need to address fuel poverty for those in rented accommodation as opposed to homeowners helped by the pilot; for housing associations to borrow to improve heating and ventilation; and for people who are able to work to be helped to find employment to cover the costs of improvements.

One individual did not believe the scheme would have much impact on fuel poverty, stating: "It is a long-term solution to the climate challenge. It will not have any positive impact in the short term at least, on fuel poverty. Those in fuel poverty are also those least able to take out a new loan."

Loan Holder Survey Feedback

Several loan holders described a reduction in the cost of their heating bills. This was more common among loan holders who had installed low emissions heating solutions. Sixty-one per cent (11) of those who installed heating solutions observed a reduction in their heating bill; the equivalent figure among loan holders who installed energy efficiency measures was 43% (12).

Loan holders commented on changes in their heating costs taking part in the pilot:

"I would say it has reduced by a reasonable amount...I would say maybe 25%." (Loan holder)

"In terms of electricity bill, it's massively different compared to what was before the gas was installed." (Loan holder)

"I would say it's reduced about 20 pounds a month." (Loan holder)

One loan holder noted an indirect cost saving; they were no longer paying insurance, as their new boiler came with a five-year warranty.

Some loan holders found it difficult to compare their heating costs before and after the measures were installed. They described a lack of certainty because of other contributing factors, such as new energy tariffs, more time spent at home due to COVID-19 and weather conditions.

Many loan holders also described having warmer homes due to new insulation, more efficient heating systems and double-glazed windows. Twenty-six respondents who installed energy efficiency measures gave quantitative information about their feelings of warmth before and after installing the measures. Nineteen per cent (5) reported they 'always' felt warm in winter before the installation, but this increased to 81% (21) after. Meanwhile, the proportion who indicated they 'never' felt warm in winter decreased from 31% (8) to 4% (1) (Figure 2).

Among those who installed heating solutions, 22% (4) reported 'always' feeling warm in winter before the solutions were installed, but this increased to 83% (15) after. Similarly, the proportion who confirmed that they 'never' felt warm in winter after the measures were installed was only 6% (1) compared with 33% (6) before (Figure 3).

Q7b. Do you have any suggestions on how a future scheme could better support a reduction in fuel poverty in Scotland? Please explain your answer

Twenty-three respondents provided a comment in their answer to this question.

Changes to the scheme setup

Suggestions for changes to the setup of the scheme were most prevalent. These comments addressed the specifics of the scheme, and the potential to tackle fuel poverty by making participation easier and more appealing.

Most common were suggestions around the application process and supporting applicants in making the best use of funds and the right decisions for their home. Most recognised the target audience requires a significant level of support. Respondents from the Care & Repair organisation felt applicants could be better supported if their managing agent was customer-focused, e.g. a Care & Repair officer, or if owners could make a direct application to a support organisation thereby bypassing the Energy Saving Trust. There was also a suggestion that Home Energy Scotland could provide a support mechanism. One respondent called for an online application option.

"Owners and landlords will also need support in the use of the funds made available including to ensure that they use appropriate technology, reputable installers and that the condition and maintenance of the property is sustained in the medium to long term. Whilst we do not think the use of an architect or other building professional to oversee the work should be a requirement of the scheme we do think that some effort is required to ensure that owners, including landlords, get the right advice and support before, during and after the works." (ALACHO)

A few respondents commented on the use of contractors. These included ensuring: that all retrofits are of high quality via appropriate regulation; separation of roles between those recommending measures and installing them; that any requirements around contractor compliance or accreditation does not prevent smaller contractors from being involved - particularly in remote and rural locations; that there is a sufficient workforce in Scotland who are skilled in evaluating and installing energy performance measures; and that contractors should be part of the Scottish Government to prevent any unnecessary profiteering from the scheme.

Opportunities for education and information were mentioned by a few respondents. Two felt the scheme should be supported by educating loan holders - and the public more generally - on how to best use the installed measures and how to run their home most efficiently. Two felt the scheme would benefit from better marketing and communication to support take-up. Another suggested marketing or information campaigns about the scheme should also raise awareness of how living conditions would improve.

Other improvements to the scheme mentioned by one or two respondents included:

• calls for a more streamlined legal process and simplified legal support;
• the Association for Decentralised Energy suggested "it would be helpful for future schemes to align with consumer protection measures and there could be a blend of grant and loan funding for vulnerable consumers. This allows less debt to accumulate and could encompass longer payback periods." An individual called for the scheme to include grants and for different rates of interest on the loan;
• that the cost should be paid for from the profits of the carbon credit trading market;
• ensuring the scheme includes new products, e.g. blinds made of solar panels;
• one respondent questioned whether enabling costs are covered within the £40,000 loan and what impact this may have on money available for measures.

In the loan holder feedback survey, some reiterated previous comments about time delays in the process, and one household identified three issues they thought should be considered in any future expansion of the loan scheme:

• the limits on the number of properties an applicant could get support for, therefore a "good conscientious landlord would not be eligible for this";
• a perceived conflict between energy efficiency improvements and planning regulations: "You can't double glaze windows in a listed building - this means you have to look at incredibly expensive alternative ways";
• the loan limit in the pilot acting as a barrier to implementing all of the work needed on a larger property: "We got up to the maximum value of the loan but couldn't do all the windows."

Reviewing eligibility criteria

The second most prevalent theme was reconsidering or widening the pilot's eligibility criteria. These comments primarily focussed on widening the criteria to allow more fuel poor households to access assistance. Specifically, a small number of respondents called for the scheme to be available to all homeowners to maximise take-up. A few noted that many households in higher council tax bands could be asset rich but cash poor and living in larger and less energy-efficient houses.

Singular comments included Age Scotland's suggestion that "future schemes could ensure local authority areas with the highest proportion of older people, and fuel poor households (including extreme fuel poverty) are prioritised first". South Lanarkshire Council suggested considering how social landlords can be supported in their efforts to reduce fuel poverty.

"By expanding the scheme to cover the whole of Scotland so that greater numbers of fuel poor households can benefit; By expanding the scheme to cover properties in all council tax bands (i.e., not just council tax bands A-C) so that greater numbers of fuel poor households can benefit." (Energy Saving Trust)

"Open the scheme up to all owner-occupiers rather than those in only Council tax band A-C. Again, many owners will be asset rich but cash poor and find themselves living in large and expensive properties that they struggle to heat or improve the energy efficiency of, thus find themselves in fuel poverty but with limited financial support available to them." (Organisation, anonymous)

One loan holder reflected in the feedback survey that the use of council tax banding as criteria for eligibility might prevent some people in need from accessing the scheme.

"The council tax banding seems a bit of an artificial boundary. You get people living in fuel poverty in houses that are of a higher council tax band that couldn't qualify for this purely because of that. I can understand why council tax banding was used for the trial, because it was a quick and simple thing to measure. But if you're going to roll it out across the whole of Scotland, as a measure, not just to tackle climate change, but to help tackle fuel poverty, then allowing people who are in fuel poverty, and that can be measured to qualify for the scheme, whether they live in a large house or not, I think would be a nice thing." (Loan holder)

Broader comments on the scheme

Some respondents raised more general issues with the scheme, which they felt should be considered before further expansion. These were mentioned by a small number of respondents and included:

• two respondents requested clarity over the aim of the scheme. They questioned whether the scheme aims to achieve a reduction of fuel poverty or a goal of zero-carbon. They noted that these do not go hand in hand; for example, running costs may increase if the focus is on improvements to decarbonise a home;
• calls for a fabric first approach in the scheme were made by two respondents, focussing on improving the condition of the property before energy efficiency measures are installed;
• introducing the PAS 2035 / TrustMark requirements to provide a level of consumer protection and confidence in the works undertaken;
• considering rising fuels costs and how these could offset financial savings resulting from improvements;
• acknowledging that Scotland's geography means there will be significant variation in project delivery costs.

Suggestions beyond the scope of the scheme

A few respondents made suggestions relating to fuel poverty which are outwith the scope of the scheme. These included: calls to stop outsourcing windfarms and to feed profits from wind and hydro schemes into a fuel poverty fund; for increased pay in Scotland to allow people to improve their homes; for councils to take better care of social housing stock; to assist people with their fuel bills (though this respondent acknowledged that the scheme is a more effective way to use money); and to add home economy to the core school curriculum.

Stakeholder webinar feedback

There was some discussion in the stakeholder webinar of the scheme's role in reducing fuel poverty. Much of the conversation aligned with the theme of widening the scheme's eligibility criteria to allow those in other council tax bands or in larger properties to participate. One stakeholder raised the challenge of involving people living in fuel poverty who may be more reluctant to engage with authorities or utility providers. They called for the scheme to partner with organisations that can support and reassure vulnerable people experiencing fuel poverty.

Q8a. 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? Please explain your answer.

Twenty-eight respondents provided a comment in their answer to this question.

Agreement with using the EPC in the future

The most common theme in response to Q8a was agreement that the EPC could be used in a future scheme. Over two-thirds of those who responded endorsed the EPC, of which one third explicitly agreed, and the remainder agreed but noted concerns or reservations as described below.

"Though there are some concerns about the accuracy of EPCs and whether they treat low carbon energy sources appropriately in their methodology, we agree that EPC bands are widely used by a range of stakeholders. While alternative approaches such as specifying SAP point improvements could also be considered, we believe that for the sake of consistency, using EPC bands is the best approach." (The Building Societies Association)

Potential enhancements, additions or alternatives to the EPC

While there was some support for the EPC, a similar number of responses described how the EPC scheme could be improved or used in conjunction with other assessments.

A few described the limitations of the EPC, highlighting improvements that would be needed in the future:

"The limitations surrounding EPC assessments and their subsequent recommendations are now better understood, such as the fact they are largely based on standard assumptions of occupants and that they do not take into account variations including in occupant behaviour or the state of repair of a property." (Age Scotland)

"Without a reformed EPC regime we cannot support this as the sole mechanism for qualification. For example, blown double glazing units or warped ancient wooden door won't flag on an EPC, and yet efficient doors and glazing are essential to secure decarbonised heating and overall efficiency." (Tighean Innse Gall)

"Cost indicators [on the EPC], at this time, are not applicable for remote rural locations.  In our experience dealing with timber frame properties from late 1960s to present day the EPC limits possibilities for retrofitting wall insulation. The EPC states on older timber frame properties no insulation assumed but does not offer recommendation for improving rating with wall insulation. This therefore restricts access to Government grant/loan funding for a large number of properties in Shetland." (Organisation, anonymous)

Some suggested the need for the scheme to use EPC alongside other assessments. A few mentioned the new PAS 2035 and PAS 2030 standards requiring a whole-house retrofit survey.

"A property Retrofit Survey in line with the revised PAS 2035 would provide a holistic approach and would provide a better understanding of the requirements for the property which would in turn outline the measures for consideration." (Organisation, anonymous)

"We believe that a bespoke assessment of the property would provide a more robust basis for the measures being installed, particularly given the focus on fuel poor households and lower value properties. If equity is being withdrawn from the home to fund measures, these need to form part of a coherent package of upgrades to the home over time. In this respect the EPC alone, in its current format, would not be sufficient." (Organisation, anonymous)

Other suggestions were mentioned by one or two respondents and varied considerably:

• two respondents suggested that EPC recommendations need to be improved to take account of new and alternative technologies;
• another felt that the EPC should better reflect heat source and ongoing changes made to the home;
• one noted that the EPC does not provide information in relation to the reduction of carbon. Another called for clarity over the weighting given to the EPC metrics e.g. "if the Energy Use and Carbon metric is seen as higher importance than the Cost metric, it is important to understand the impact that this may have on the fuel poor";
• another noted their calls for carbon and cost to have equal prominence on the EPC;
• one suggested the EPC should only be included in the process after energy efficiency improvements have been installed.

Ensuring the quality of the EPC

Some respondents described concerns over the quality of the EPC, with a few suggesting ways to improve the oversight of the EPC system.

In describing quality issues with the EPC, respondents used phrases such as 'contained many inaccuracies and 'a waste of time'. They noted errors in reports due to a lack of full property inspections or limited consideration of the specific features of buildings.

Two respondents questioned the EPC process, believing it is open to abuse and misuse by people making money from unnecessary work. One suggested oversight could be improved with a continuous, transparent quality assessment for EPC assessors to ensure the quality of the recommendations and advice provided is robust.

"In my experience as a project officer, the use of an EPC before any energy efficiency improvements are carried out is a waste of time. On a number of occasions, I was asked by EST to carry out another home visit as my recommendations in support of the client application were different from those in the EPC, and I was informed by the client that the EPC representative either spent a short time in their home, did not carry out a full inspection of the property and/or their report was incorrect." (Individual)

References to the EPC consultation process

A few responses referred to the anticipated consultation on a reformed EPC assessment process, noting they supported the consultation or intended to respond to it. One noted a link to the Scottish Building Standards consultation where similar proposals are outlined.

Stakeholder webinar feedback

While there was some agreement that the EPC can be used as a tool to determine changes to a property, feedback from stakeholders during the webinars highlighted the same concerns over EPC quality as detailed above. These included the fact that the EPC may not accurately reflect what measures are possible within a property or may suggest quick fixes to reduce energy costs which are not the best long-term measures to reduce carbon emissions.

Q8b. Can you provide any alternatives? Please explain your answer.

Fourteen respondents provided a comment in their answer to this question.

Of these, four indicated a preference for using the EPC scheme, or said that no changes were required. The same number provided comments on how the EPC could be improved. These included: how an additional retrofit survey in line with PAS 2035 could aid the scheme; and that a skilled scheme administrator or Care & Repair Officer should be allowed to determine how to proceed with elements that are not covered in an unreformed EPC.

"A potential alternative would be to develop a more in-depth Retrofit Report that must be conducted by a qualified and experienced Chartered Surveyor with in-depth knowledge of energy efficiency measures, and the building type in question, after the completion of an EPC. This could be used as a basis for eligible measures. Alternatively, if the recommendations included in EPCs are improved as part of broader reforms, they may become a suitable basis." (Royal Institute of Chartered Surveyors)

Other singular responses included calls for:

• re-introducing the Home Energy Scotland advisor's energy report for applicants, which was removed from the process during COVID;
• a cost-benefit analysis per property, to ensure the scheme can help as many people as possible with the pot of money available;
• the addition of airtightness testing along with the EPC, particularly in exposed rural and island areas;
• a focus on wider climate change mitigation actions, e.g. hydrogen infrastructure, improved space standards for homes and changing building regulations.

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

Sixteen respondents answered this question.

Endorsement of the proposed approach to consumer protection

The most prevalent view expressed was of support for the proposed approach set out in the consultation paper. A few respondents made broad comments endorsing the proposals. Some highlighted the value of specific elements of the suggested approach, including the intention to adopt the latest retrofit standards and to give consideration to using the UK TrustMark quality assurance framework.

"Propertymark believes that the Scottish Government's proposed approach to consumer protections adequately addresses concerns about the potential conflict between emissions and fuel poverty targets and will help ensure consumers receive high-quality work carried out by skilled operatives through use of the latest retrofit standards." (Propertymark)

"We think it is sensible to have a quality assurance framework that is consistent with that in other parts of GB, and provided it ensures in practice that installations are of high standard, customer satisfaction is high and that any issues are addressed swiftly, the Scottish Government should adopt the UK government's TrustMark quality assurance framework." (Energy Savings Trust)

Webinar participants also commented on the value of TrustMark accreditation. They highlighted that the scheme provides assurance for consumers that contractors meet standards related to quality, insurance and staff training.

Challenges in implementing the proposed approach

Some respondents identified challenges to implementing the proposed approach. Most notably, a few reported that there could be difficulties in ensuring that installers have the necessary accreditations, particularly in remote and rural areas, due to a reported lack of infrastructure for training and development.

"TrustMark registration demands adherence to PAS 2035 / PAS 2030: 2019 retrofit standards. Rural and remote rural supply chains are not ready for this transition. Had this applied to the pilot in the Western Isles no work would have been started. The professional infrastructure for training and development of the workforce is not there in northern Scotland. The capacity and ability of the local supply chain to meet these requirements are not there. Home equity will not be delivered in the Highlands and Islands by anyone if you go with this approach and ultimately no consumers there will benefit from anything. Consumers will be protected from any work being carried out as no one will be in a position to deliver any. Who will do the work?" (Tighean Innse Gall)

"Potential limit on the number of installers in rural and island areas unless there is additional mechanisms put in place to support small local businesses gain required accreditations. Opportunities are more likely to be taken up by large developers which have the resources to meet any upskilling/retraining and ongoing paperwork requirements, and this, therefore, may restrict competition or see works being undertaken by firms outside the Islands." (The Building Societies Association)

This view was also shared by some webinar participants, who noted that the process of acquiring accreditation could place a burden on contractors. These webinar participants observed that if TrustMark accreditation were made a pre-requisite for contractors to take part in the scheme, it could limit the number of contractors who would be available to carry out the required work, particularly in rural areas.

Other challenges, each identified by one respondent, were:

• the TrustMark framework's requirement for contractors to carry out a home visit - the respondent suggested that this visit would be more cost-effective for contractors and convenient for homeowners if it was carried out by video call instead;
• a risk that homeowners' investment would not be reflected in their property value: one anonymous organisation said, "this could lead to customer detriment as the homeowner when selling their property after having such measures installed, would be left worse off in terms of proceeds compared to selling the property without having had the work done". This respondent suggested that this could be mitigated by placing a cap on the amount to be repaid "at the lower of the agreed equity share of the sale price or the loan amount at 2.5% APR also protects people in cases where the market value of the property may fall";
• the need for a "regulated expedited field office that can fact check reported cases" (Individual).

Reservations about the proposed approach

Two individuals expressed reservations about the proposed approach. One said the proposals were "insufficient" while the other suggested that more details were required: "It doesn't explain how, just that you would like to make things better".

Additional measures

Two respondents proposed additional consumer protection measures in response to Q9a. These responses have been included in the analysis of Q9b below.

Q9b. Are there any additional consumer protection measures that can be considered within Scottish Government competence?

Eighteen respondents provided an answer to Q9b.

An organisation to promote consumer interests

The most common theme in responses to Q9b was to suggest the appointment of an organisation to help promote consumer protection. In their comments, respondents highlighted important aspects of consumer protection, including advice and support, contractor standards and inspections.

Three respondents felt that a consumer protection organisation's role should include a focus on providing advice and support directly to consumers.

"With its core function of providing consumer advocacy and advice; with a view to reducing harm and increasing confidence between both consumer and business, we believe the newly formed Consumer Scotland body should actively consider any future rollout of the Equity Loan programme under its future work plan for 2022-23, especially considering the scheme aims to target older and more vulnerable households as a priority." (Age Scotland)

"The Council would promote the use of Home Energy Scotland to provide independent advice, particularly to vulnerable homeowners where they may feel pressurised into making life-changing decisions." (Glasgow City Council)

Two others suggested that a consumer protection organisation could drive quality standards among contractors.

"Potentially a national delivery agency could be a way forward to drive standards and control delivery, linked to the construction industry, ensuring qualified installers are trained and skills are available." (Organisation, anonymous)

Another view reported by two respondents was a role for consumer protection in relation to the work inspection process.

"Care & Repair have been successful in the protection of consumers for 30 years and therefore the best way to ensure consumer protection is for Care & Repair nationally to deliver home equity in future and conduct a 100% inspection rate as they have in the pilots. TrustMark deliver a 5% inspection rate, so it seems perverse to lower standards in Scotland by the Scottish Government introducing new UK driven ones." (Tighean Innse Gall)

Quality assurance framework for contractors

While quality assurance was most frequently discussed in responses to Q9a, some respondents further advocated at Q9b for a quality assurance framework such as TrustMark. These respondents felt this would be beneficial to provide assurance that installers meet quality standards and protect consumers against any rogue contractors.

"Consumer protection measures linking back to the use of the PAS2030 and PAS2035 standards to ensure various suitable improvement options are available to the home owner under equality assured framework, with appropriate redress." (Elmhurst Energy)

Warranties

A few respondents called for warranties for any work carried out and the goods installed. One felt the Scottish Government could have a role in providing these warranties.

"A Scottish Government backed warranty for works carried out incorrectly (to be assessed by an independent chartered professional)." (Individual)

Process for consumer redress

Two respondents emphasised the importance of establishing a route for consumers to seek redress if they have problems with the work carried out or the equipment installed.

"Ultimately consumers need to know that work has been carried out to a high standard and that if it is not there is a system in place to rectify any problems quickly (ideally a single point of contact for recourse)." (Energy Saving Trust)

Post-purchase support

One organisation suggested that contractors should carry out post-purchase visits with consumers to make sure they can use the new equipment.

Newer heating systems tend to have more complex controls than standard systems.  It's important that homeowners know how best to use the system to heat a house efficiently, a 'soft landing' service from the contractor/installer would help this. There should be a duty to… ensure that there is a requirement for post-installation visits to ensure that the owner is clear and comfortable about using system and system is working to optimum level. (Organisation, anonymous)

Q10. The expansion of the pilot could provide a greater opportunity for eligible homeowners to participate in scheduled refurbishment works being undertaken by local housing associations and local authorities. Do you have suggestions on how best to achieve such a working partnership?

There were 23 responses to this question. These covered a range of ways to support partnership working with housing associations and local authorities, including faster and simpler application processes, direct payments to partners, alignment with other schemes and resourcing.

Reducing delays in the application process

The most common view among Call for Evidence respondents and webinar participants was that reducing the delays in the application process experienced during the pilot could help to encourage housing associations and local authorities to take part. Participants noted that some applications were completed within one month, but more complicated cases could take up to six months. There was one example where the process took two years. Respondents who shared these examples suggested that delays like this could make the scheme unappealing to local housing associations and local authorities.

"The shockingly long delays in approvals made it impractical for social landlords to depend on this funding. One local authority stated: 'after Care & Repair submitted the application it went into a black hole'. If an efficient team, as previously suggested, is set up to oversee the application process, we are confident that the scheme terms will have an appeal to social housing landlords." (Care & Repair Scotland)

Webinar participants discussed the complications that a lengthy application process could cause. The longer the application process goes on, there can become a need to revisit quotes, surveys and EPC evaluations if they have expired, and this can delay the planned work significantly. Participants felt that this issue needs to be addressed to encourage more local authorities and housing associations to engage with the scheme.

"I know certainly for our housing association partners, I know that the length of time it's taken to get some of the loans approved has really challenged their procurement. You know, procuring contracts and tendering them, thinking works are going to start, but then the grant, the Equity Loan has not been approved in time, and it holds up whole projects." (Webinar participant)

"Part of the problem is, as you resolve the legal issues and cleanse the title, the difficulty is the time it takes to do that, it means your mortgage redemption figure, your valuation, your EPC all become out of date, and then have to be revisited. And then if costs change, then that has to be revisited as well." (Webinar participant)

Payment process

Some respondents expressed a view that the Scottish Government could provide the funds from the scheme directly to local authorities or housing associations instead of the homeowner, as is currently the case. They suggested this approach could help local authorities and housing associations to 'front fund' works without the risk of owners withholding payment, as well as protecting contractors from any risk of owners refusing to pay them on completion of the work.

Webinar participants also suggested that mandated payments for local authorities and housing associations would make the scheme more attractive for them.

"It [giving the funds to the homeowner] puts the council at big risk because we pay the contractor and we have to sit and wait for the funding to come through from the applicant." (Webinar participant)

"It causes tremendous problems if you've been working with an RSL [Registered Social Landlord] for the best part of nine months, and they are anticipating that when they carry out the work, that the money is going to be there, and then they find out it's not, that's just a major embarrassment for the scheme. So that side of things needs to be looked at as well, about how we can get to a point where we can guarantee partners, that our money will be in place when they are ready to go." (Webinar participant)

Alignment with other schemes

A few respondents called for the home Equity Loan scheme to be aligned with other schemes to help establish a working partnership with local authorities and housing associations. For example, one noted that the scheme could be used to cover owner contributions required for works under the Energy Efficient Scotland Area Based Scheme (EES: ABS) programme. Webinar participants also suggested that the scheme could be aligned with the EES: ABS programme.

"From an ABS perspective, moving to a three-year programme might give us a bit more of a lead in time to allow us to work with owners in future project areas… we have that longer lead-in, it will be beneficial for people who do want to use this route to fund measures… I think that there are opportunities for local authorities to work more closely with owners who want to want to participate and give them options around how to pay for that." (Webinar participant)

Administrative and resource issues

Another theme identified in the discussion among webinar participants and raised by one Call for Evidence respondent, concerned the resources that local authorities and housing associations require to administer the scheme.

"I think having the staff to run the project would be very difficult." (Webinar participant)

Similarly, one respondent to the Call for Evidence noted that some local authorities have more resources than others, which could lead to inconsistencies in delivery across the country.

Mixed tenure properties

Participants reported that implementing the scheme in mixed tenure properties could add another layer of complexity. There were examples in which different timescales caused difficulties: where a housing association or local authority has completed work on the properties they own in a block before private owners in the block have funding in place.

"You can understand why these people [private owners] want the works done. And we have a contractor that wants to do the work but the process is not allowing that to all flow in the manner in which it could." (Webinar participant)

Awareness-raising

Two individuals who responded to the Call for Evidence suggested that there could be a role for local authorities and/or local housing associations in contacting homeowners directly to suggest energy efficiency improvements to their property. This communication could also include an outline of the costs involved and information about the availability of the scheme to help fund the work.

Other suggestions

Other suggestions to facilitate the involvement of local authorities and local housing associations, each identified by one respondent, include the following:

• offering discounted or subsidised rates as an incentive for homeowners to take part;
• appointing a dedicated member of staff to coordinate the Equity Loan scheme and build relationships with local authorities and local housing authorities;
• ensuring that staff involved in delivering the scheme have the necessary training and knowledge.

Opposition to involving local authorities and local housing authorities

Two respondents opposed the idea of working in partnership with local authorities and housing associations. One felt that this approach could reduce the resources available for people in more remote areas; the other did not explain their view.

"This approach could easily swallow up the entire scheme, leaving people in rural isolated locations behind." (Individual)

Q11. Do you have any suggestions on how to ensure delivery of the scheme is efficient and robust, including the legal process and customer support service whilst ensuring value for money?

Twenty-four respondents answered Q11.

Support and advice for homeowners

The most prevalent theme in responses to Q11 concerned the importance of support and advice to help homeowners navigate the complexities of the scheme. Respondents suggested that homeowners required various forms of support; such as independent legal advice, general guidance about the terms of the loan and information about what to expect in the application process and beyond.

"The benefits to homeowners should be clearly communicated, along with ensuring there are no hidden or additional costs. Guidance or detail of what should be expected when a homeowner takes part in the scheme, and what they realistically will achieve by utilising it in terms of energy improvements should all be part of the package of support." (South Lanarkshire Council)

"The Council considers there is a leading role for local authorities and housing associations to offer advice, provide funding options, and extol the benefits that owners would receive in return. This could be a similar model to the Scottish Government's ABS programme with the provision of aftercare advice and support. In addition, we would see this supported by an enhanced role for Home Energy Scotland to assist owner through the process including the provision of energy advice, behavioural change and use of new heating systems within the home." (Glasgow City Council)

A few respondents supported a blended approach to engaging with homeowners, with a mixture of online, phone and face-to-face support. Two respondents praised the online and telephone toolkit available for homeowners but suggested it could be complemented by face-to-face support to reach those who are unable to access support in that way.

"The toolkit is a good idea to support those who are able to use it effectively. Also, group support at various stages would help e.g. info sessions to a community/housing scheme, even if only a handful of those residents progress through the full process it will increase awareness and literacy around the processes." (Individual)

One respondent repeated a view expressed earlier in the Call for Evidence that the support currently delivered face-to-face could be provided more efficiently by phone.

"The online toolkit / phoneline is certainly a good step but it won't be a catch-all unless customers who don't have access to the internet or are not tech savvy have family or friends to support them." (Organisation, anonymous)

Legal process

A few respondents noted the lengthy nature of the legal processes involved in the pilot and the delays this causes for applications. These respondents suggested there was scope for streamlining through, for example, a pro-forma for applicants to complete online and/or a framework of solicitors to support applicants.

"We believe that further work could be undertaken to overcome delays with the legal process to ensure that households can benefit from the support offered by the scheme much earlier. For example, a framework of solicitors who are clear on the scheme's terms available to potential applicants could improve the legal process timescales." (Energy Saving Trust)

One respondent expressed a concern that the loan could cause a legal issue for homeowners when they want to sell their property and suggested the Scottish Government take action to avoid this situation.

"The scheme should not make the loan an encumbrance for the homeowner, a flexible exit phase should be included to nullify the loan before selling the property or transferring the ownership. It would be also essential for the Government to educate the legal practices to ensure no further issues with the financials occur when a property is to be sold or change ownership." (Elmhurst Energy)

Delivery organisation(s)

A small number of respondents observed that careful consideration should be given to the organisation(s) that deliver and co-ordinate the scheme. They expressed a view that the public sector is not best placed to deliver the scheme but did not fully explain their reasons for this view. Two respondents emphasised the importance of the delivery organisation(s) having the resources and capacity to deliver the scheme effectively.

"Fund a small unit that will oversee the process and allow agents for the owners to have direct access so that administrative and legal delays can be quickly resolved." (Care & Repair Scotland)

Customer feedback

Two respondents highlighted the importance of customer feedback in identifying potential improvements to the scheme.

"Improvements are likely to be best identified through a proper review of customer experiences and journeys. We understand that some of this work is already underway." (Glasgow City Council)

Other suggestions

Individual respondents shared suggestions to ensure efficient and robust delivery of the scheme, including the following:

• establishing an advisory group to monitor the performance of the scheme, including the Scottish Government, delivery organisation(s) and other relevant organisations;
• compiling a list of approved contractors similar to the Constructionline Gold standard;
• for the Scottish Government to inspect work carried out;
• involving a RICS-accredited Chartered surveyor in establishing the value of the house to calculate the loan to ensure "accuracy and fairness in the provision of the loan and the repayment value at time of sale" (Royal Institution of Chartered Surveyors);
• providing support for installers to enable more to take part in the scheme, thereby encouraging competition and keeping costs as low as possible.