Local Energy Policy Statement: consultation analysis

Main Findings

Scottish Government Local Energy Policy Statement: General Questions

1. Are you clear on the purpose of the statement? Please explain your view.

Key figures

• 39 responses (84.7%) were received for this question 
• 31 respondents agreed with the question (67.4%)
• 8 respondents either did not agree or did not know (17.4%)
• 100% response rate from public sector organisations

	Yes	No	Don’t Know	Not Answered
Community groups (5)	4	-	-	1
Local Authorities (8)	5	-	3	-
Public sector (6)	6	-	-	-
Academic Institutions (3)	1	1	1	-
Trade bodies and interest groups  (11)	8	1	-	2
Renewables industry (11)	7	1	-	3
Individuals (2)	-	1	-	1
Total (46)	31	4	4	7

Summary 

• As the table above illustrates, the majority of respondents (67.4%) stated they were clear on the purpose of the statement – including all respondents replying on behalf of public sector organisations. 
• A sizeable minority of respondents (17.4%), across all respondents groups, were either not clear on the purpose, or did not know. 
• For those who did respond, there was a belief that more emphasis on decarbonisation and net zero emissions were required from the outset. Similar to the above, this was consistent across all different types of respondents group.
• While the majority of respondents stated that they were clear on the purpose of the document, a number of concerns were raised regarding how this will actually look in practise/ translate into action (i.e. “what happens next?”).
• In addition to this, there were also calls from those representing Local Authorities and public sector organisations to demonstrate how the Local Energy Policy Statement would link with other Scottish Government programmes.

2. What are your views on the 10 principles?

Key figures

• 41 responses (89%) were received for this question 
• 100% response rate from community groups, Local Authorities, public sector organisations and academic institutions 

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	6	-
Academic Institutions (3)	3	-
Trade bodies and interest groups  (11)	10	1
Renewables industry (11)	8	3
Individuals (2)	1	1
Total (46)	41	5

Summary 

• This question generated the most interest/ highest number of responses and, across all groups, the majority of respondents were supportive of the Policy Statement’s key principles and associated outcomes – particularly those within the communities, industry and trade bodies/ interest group categories.
• However, while each individual key principle received specific comments, the main areas of commonality across the principles and respondents –as a whole – were that:
  • The key principles were vague (although a small number of respondents did state the principles, in their current written form, were too text-heavy).
  • More clarity was required, especially regarding what is meant by “consumers” and “low regrets”.  This was also raised in the usage of these terms in the statement.
  • More emphasis on decarbonisation was required. There were a number of calls for this to be embedded within a principle – and no longer simply an outcome.
• Also, concerns were raised, from a small number of Local Authorities, that these principles would prove too difficult to monitor over a sustained period of time. 
• Finally, there was concern raised at the lack of reference to historic “environment, places and landscape policies”. A separate response received also highlighted how Scotland’s historical environment should be taken into account within the Policy Statement – preferably within one of the principles. This response stressed how the historic environment can be used in a positive way, as it can be “re-used and adapted to assist with, and take advantage of, local energy projects”.

3. How can the Scottish Government encourage stakeholders to adopt the principles set out within this document?

Key figures

• 36 responses (78%) were received for this question 
• 100% response rate from community groups, Local Authorities, and academic institutions 

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	4	2
Academic Institutions (3)	3	-
Trade bodies and interest groups  (11)	8	3
Renewables industry (11)	7	4
Individuals (2)	1	1
Total (46)	36	10

Summary 

• Four (50%) Local Authorities believed that the Scottish Government should compile clear guidance for those involved in the development of future local energy systems, and that the Scottish Government should launch an advertising campaign to increase awareness and publicity. There was wide-spread agreement for this across all groups who responded, with a general feeling that public engagement and education is key – and that this was an area where the Scottish Government could and should lead.
• A quarter (25%) of Local Authorities believed that the principles should be closely aligned with the outcomes of Local Heat and Energy Efficiency Strategies (LHEES). It is worth noting that this was raised by a number of other Local Authorities elsewhere within the response forms submitted (for example, including at Question 2) – further strengthening the view amongst Local Authorities for greater linkage between both the Policy Statement and LHEES.

• Across various groups, there was support for the Scottish Government to take measures to ensure that funding for future projects should only be issued to projects which adhere to these principles. There was recognition that, as the Scottish Government only has certain devolved powers, this could potentially be one route that the Scottish Government could take to help ensure future local energy projects adopt the principles set out within this Policy Statement.
• A suggestion was also raised that there could be a public register of all stakeholders who have demonstrated their commitment to the principles.
• Comments received from those representing trade bodies and interest groups, in particular, highlighted that the Scottish Government should take the lead at a national level. This would include adopting and complying with these principles in all future energy decisions across the Scottish Government’s estate.

4. Are you clear about the roles of all the different stakeholders who may be involved in the development of local energy systems?

Key figures

• 32 responses (69.5%) were received for this question 
• 23 respondents stated they were clear (72%)
• 9 respondents were not clear (28%)

	Yes	No	Not Answered
Community groups (5)	4	-	1
Local Authorities (8)	4	2	2
Public sector (6)	4	-	2
Academic Institutions (3)	-	2	1
Trade bodies and interest groups  (11)	6	2	3
Renewables industry (11)	5	2	4
Individuals (2)	-	1	1
Total (46)	23	9	14

Summary 

• Over three quarters of those who replied to this question (78%) selected “Yes” – stating that they were clear about the roles of stakeholders. This included the majority of those representing community groups (80%) and public sector organisations (66.7%).
• However, 9 respondents (28%) specifically stated they were not clear about the roles of the different stakeholders involved in the development of local energy systems. 
• There was general support across respondents (31%) that more clarity regarding the specific roles and responsibilities of each stakeholder group would be welcome – alongwith recognition that these would be flexible and could evolve/ grow over the lifespan of a project.
• Requests were also made for the Policy Statement to include further guidance on who would be responsible for facilitating joint working between the different stakeholder groups, and who would have responsibility for maintaining this throughout the project duration. Similar to the above, this was common throughout all types of respondent group.
• Various suggestions were received regarding additional key stakeholders who could, potentially, be included within Policy Statement’s stakeholder matrix diagram. These included:
  • Land owners
  • Stakeholders linked to/ representing transport/ heat interests
  • Housing associations
  • House builders/ construction industry
• Finally, it was also noted that there should be recognition within the Policy Statement that there may be different/ competing interests between the various stakeholder groups involved.

Scottish Government Local Energy Policy Statement: Theme 1 - People

5. How can we ensure that all socio-economic groups in all regions across Scotland will benefit from the transition?

Key Figures

• 36 responses (78.3%) were received for this question 
• 100% response rate from Local Authorities, academic institutions, and individuals

	Response Received	Not Answered
Community groups (5)	4	1
Local Authorities (8)	8	-
Public sector (6)	4	2
Academic Institutions (3)	3	-
Trade bodies and interest groups  (11)	7	4
Renewables industry (11)	8	3
Individuals (2)	2	-
Total (46)	36	10

Summary 

• There were some areas of commonality across Local Authorities, including the view that the Scottish Government should take steps to:
  • Build trust with consumers and an expectation that they will be treated fairly.
  • Lead on more engagement to inform consumers.
  • Ensure costs are affordable and fair.
  • Establish more solid links between those undertaking local energy projects and communities.
• However, across other groups (particularly communities and public sector organisations), there was a desire to see more leadership from Local Authorities in terms of collaborating more closely not only with communities (through, for example, local actors or champions), but funding bodies as well.
• Almost all groups felt that the Scottish Government should ensure that access to low cost funding streams across all socio-economic groups was important, as well as investment in education for end users and consumers. One comment in particular stressed the need to ensure any process (whether selecting which type of renewable energy source or the process of applying for funding itself) put in place was simplified.
• Respondents from various organisations believed there were a number of unintended consequences which could impact on the principle of a just transition, such as:
  • A “postcode lottery” in terms of costs to consumers.
  • The risks associated with higher consumer bills by switching to electricity.
  • The future energy system being “digitally exclusive” – thereby, excluding certain vulnerable groups.

6. How can we ensure that people and communities across the whole of Scotland can participate in local energy projects?

Key Figures

• 35 responses (76.1%) were received for this question 
• 100% response rate from community groups and Local Authorities

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	5	1
Academic Institutions (3)	2	1
Trade bodies and interest groups (11)	7	4
Renewables industry (11)	7	4
Individuals (2)	1	1
Total (46)	35	11

Summary 

• The general consensus amongst respondents was that the Scottish Government should spearhead a national advertising campaign to raise awareness which would, ultimately, lead to increased involvement in future local energy projects from people and communities across Scotland.
• There were similar calls across all respondents for the need to ensure effective channels of communication were put in place. This was seen as a useful way of ensuring that the benefits of transitioning to more localised energy were clear for people from all backgrounds to understand.
• While not specific to any one question in particular, one respondent highlighted the role which a Scottish Local Energy System Industry Forum could potentially play in bringing different parties together and fostering greater collaboration.
• A small number (14%) of Local Authorities and public sector organisations stated that it was important for the Scottish Government to give consideration to ways in which vulnerable groups, who have not been engaged before, can be identified and participate. Suggestions on how to achieve this included the Scottish Government establishing a network of local contacts across all regions in Scotland to reach out to these individuals/ groups.

Scottish Government Local Energy Policy Statement: Theme 2 - Places

7. What do you think the wider benefits of developing local area energy plans might be?

Key Figures

• 32 responses (69%) were received for this question 
• 100% response rate from Local Authorities

	Response Received	Not Answered
Community groups (5)	4	1
Local Authorities (8)	8	-
Public sector (6)	5	1
Academic Institutions (3)	2	1
Trade bodies and interest groups (11)	6	5
Renewables industry (11)	7	4
Individuals (2)	-	2
Total (46)	32	14

Summary

• Many respondents (including 50% of Local Authorities) believed that this could result in a wider-spread of jobs across Scotland, and more local employment opportunities could become available, as a result. Examples given included not only the actual installation of any new local energy system (i.e. job creation on a temporary basis), but also subsequent roles for any on-going management and maintenance works throughout the lifetime of the plant/equipment (which could, potentially, mean more opportunities for permanent employment as well).
• Greater collaboration between stakeholders was also envisaged by 37.5% of Local Authorities: with some highlighting that these could act as a catalyst for future partnerships.
• Another benefit recognised across different groups was the greater participation of communities and individuals in the wider-energy system. In particular, this belief was consistent across a significant percentage of those responding on behalf of public sector organisations (50%).
• One respondent also underlined the various indirect benefits (for example, improved air quality through reduced emissions) and social benefits (e.g. stress reduction within fuel-poor homes) associated with the development of local energy plans at scale – highlighting how these plans can provide more than just the “expected” direct benefits.
• The more general comments received varied from group to group, and a brief summary of the other key benefits highlighted were:
  • Reduced fuel poverty 
  • Building more energy resilience in communities across Scotland
  • Greater energy democracy 
  • Drive more wider local regeneration 
  • An increase in community benefit payments (£) from local renewable energy installations

8. How can we encourage greater collaboration between the key parties involved in the development of local energy plans?

Key Figures

• 31 responses (67%) were received for this question 
• 100% response rate from community groups, Local Authorities and academic institutions 

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	3	3
Academic Institutions (3)	3	-
Trade bodies and interest groups  (11)	6	5
Renewables industry (11)	6	5
Individuals (2)	-	2
Total (46)	31	15

Summary 

• There was a strong message that the Scottish Government needs to make the benefits and desired outcomes of local energy plans clear to all parties. This would also include ensuring that success stories are shared widely. 
• A number of correspondents (mainly in the public sector category) stated their belief that the Scottish Government (or a similar body) should create a knowledge sharing portal, that could be accessible for anyone looking to undertake a local energy plan.
• The messaging from different groups was consistent: that the Scottish Government should have some sort of framework or forum to facilitate joint working/ collaboration/ discussion.
• Finally, a small number of replies suggested the Scottish Government provides some form of Good Practice Principles for local energy plan development – similar to the Scottish Government’s existing suite of Good Practice Principles for Renewable Energy Developments.

9. How do we ensure that whoever is leading a local energy plan is fully integrated into the LHEES process?

Key Figures

• 29 responses (63%) were received for this question 
• 100% response rate from community groups and Local Authorities

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	3	3
Academic Institutions (3)	2	1
Trade bodies and interest groups (11)	6	5
Renewables industry (11)	5	6
Individuals (2)	-	2
Total (46)	29	17

Summary 

• With regards to the responses from Local Authorities, a number of respondents felt that it is the responsibility of the Scottish Government to take the lead to raise awareness and provide clear guidance on how this can be achieved.
• There was also a view, which was common across a number of Local Authorities, that the Scottish Government should set clear boundaries regarding the differences between the two types of plan. For example: what specifically a Local Heat and Energy Efficiency Strategy will be expected to cover vs. what a more “general” local energy plan will encompass.
• Also, Local Authorities used this question to make it clear that they desired more clarity from the Scottish Government about what is expected of them regarding LHEES.
• The majority of comments received were from Local Authorities. However, some additional points were made by other groups. While this messaging was not (mostly) consistent, there was a general view that LHEES should be integrated/ incorporated into wider-local energy plans.

Scottish Government Local Energy Policy Statement: Theme 3 – Networks & Infrastructure

10. What infrastructure challenges are you aware of that present an obstacle to delivering local energy projects?  What actions would help solve the issue?

Key Figures

• 36 responses (78%) were received for this question 
• 100% response rate from community groups, Local Authorities, academic institutions and individuals

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	4	2
Academic Institutions (3)	3	-
Trade bodies and interest groups  (11)	8	3
Renewables industry (11)	6	5
Individuals (2)	2	-
Total (46)	36	10

Summary 

• There was almost universal agreement between respondents that grid constraints/ limitations were the main barrier. Industry, in particular, felt DNOs could engage more and provide additional support to help applicants through grid connection process.
• A number of community groups reported that dealing with DNOs could be challenging, as there was an expectation that community groups had the same level of technical and/ or capacity as that of business organisations. Community groups asked for DNOs to recognise that they were not professionals and to adopt their approach to suit individual community groups circumstances.

• Similar to the above, respondents across various groups believed that DNOs should prioritise renewable energy projects more – especially given the current global climate emergency and both Scotland and the UK’s wider-net zero ambitions. 

• While not an infrastructure challenge in itself, a number of respondents (mostly Local Authorities) took this opportunity to raise the issue of the negative impact that planning policy has towards renewable developments – even if this was unintended.
• Although a host of responses were received, the most consistent replies mentioned challenges associated with both delays to the rollout of smart meters across Scotland, and the high capital costs associated with low carbon projects.

11. What other actions could the Scottish Government take to ensure Scotland will have the necessary infrastructure in place to enable resilient, local energy systems?

Key Figures

• 30 responses (65.2%) were received for this question 
• 100% response rate from community groups and Local Authorities

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	2	4
Academic Institutions (3)	2	1
Trade bodies and interest groups  (11)	7	4
Renewables industry (11)	5	6
Individuals (2)	1	1
Total (46)	30	16

Summary 

• Across most groups, a number of respondents highlighted their desire for the Scottish Government to pursue more meaningful engagement with organisations such as DNOs, National Grid, Ofgem, and others.
• While there was no consistent responses within the defined groups, across all respondent groups there was a belief that the Scottish Government should ensure that there were adequate funds, skills and knowledge are in place locally.
• One comment received suggested that the Scottish Government should take the lead by introducing national infrastructure plans for net zero, which should also include a full assessment of the current available infrastructure across Scotland.
• Some respondents stated that the Scottish Government should introduce and strengthen existing legislation and regulations – whereas some respondents (even those within the same group) expressed the opposite view.

Scottish Government Local Energy Policy Statement: Theme 4 – Pathway to Commercialisation

12. What significant barriers are there to the replication of existing local energy projects and systems in Scotland that this policy statement should take account of?

Key Figures

• 31 responses (67.4%) were received for this question 
• 100% response rate from community groups and Local Authorities

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	5	1
Academic Institutions (3)	2	1
Trade bodies and interest groups  (11)	6	5
Renewables industry (11)	5	6
Individuals (2)	-	2
Total (46)	31	15

Summary 

• A common theme across all groups was the difficulty those involved in the development of local renewable energy projects have in accessing finance. This was a particular problem when it came to financing projects to replicate at scale.
• As the above table shows, all Local Authorities submitted a response to this question – and there was some commonality between each council regarding the barriers faced in replicating local energy projects:
  • The high infrastructure costs associated with local energy projects, in general
  • A lack of funding security and continuity across lenders
  • Ensure there is a “right” balance of risk 
• Almost half (37.5%) of Local Authorities stated that there were barriers related to knowledge sharing and finding more information on the lessons learnt from previous projects. However, it was noted that this was, partially, due to commercial sensitivity. 
• Across communities, the renewables industry and trade body groups, there was a shared concern about the lack of a viable route to market for local energy projects. Many respondents commented that the closure of UK Government renewable subsidy schemes were a key driver behind this issue.

13. What actions can we take to accelerate the focus on economically and commercially viable low carbon local energy solutions in an inclusive way?

Key Figures

• 33 responses (71.7%) were received for this question 
• 100% response rate from community groups and Local Authorities

	Response Received	Not Answered
Community groups (5)	5	-
Local Authorities (8)	8	-
Public sector (6)	3	3
Academic Institutions (3)	2	1
Trade bodies and interest groups  (11)	7	4
Renewables industry (11)	7	4
Individuals (2)	1	1
Total (46)	33	13

Summary 

• For this question, there was a 100% response rate from Local Authorities. A quarter (25%) of these respondents wish to see Scottish Government financial support for local renewable energy projects continue and expand, while slightly more (37.5%) Local Authorities wanted more investment in future skills development.
• However, one comment received from a Local Authority raised concerns about this Policy Statement being too much of a “wish list”.

• 40% of community group responses stated their desire for the Scottish Government to work more closely and improve engagement with the DNOs and Ofgem.

• A number of trade bodies and interest groups suggested that the Scottish National Investment Bank will have a key role to play in facilitating the roll-out of low carbon, local energy projects moving forward.
• Across representatives from industry, community groups, and academia, there was a desire to see a greater emphasis placed on both locally-owned and shared-ownership opportunities – as these could, potentially, play a role to increase the deployment of local energy renewables projects.
• Those representing the renewables industry believe there is a role for the Scottish Government to promote awareness of inclusive business models, and ensure that funding for replicable projects is finalised (building on the replies made to Question 12).  

Scottish Government Local Energy Policy Statement: Theme 5 – Opportunity 

14. How can we ensure that Scotland capitalises on the economic opportunities from the development of local energy systems?

Key Figures

• 26 responses (56.5%) were received for this question 

	Response Received	Not Answered
Community groups (5)	3	2
Local Authorities (8)	7	1
Public sector (6)	1	5
Academic Institutions (3)	2	1
Trade bodies and interest groups  (11)	6	5
Renewables industry (11)	6	5
Individuals (2)	1	1
Total (46)	26	20

Summary 

• Across Local Authorities and community groups, in particular, there was agreement in the belief that the Scottish Government should provide investment in both the upskilling and re-skilling of Scotland’s workforce.
• Similar to previous questions within this consultation, a number of comments received across various respondent groups stated the need to ensure that key learnings and success stories are shared between parties which, in turn, would help develop more “outcome-based” knowledge across Scotland.
• One respondent stated that any future legislation surrounding local energy systems development should not support “generation for generations sake”.
• The comments received from trade bodies and interest groups (54.5%) were varied, and a brief summary of these are as follows:
  • Investment towards facilitating a greater level of energy exports.
  • Capitalising on each local area’s natural resources and enhancing the “unique energy characteristics” of each area.
  • Scottish Government funding being directed to create a pipeline of projects across Scotland, which would also help support local supply chains.
  • Enhance links with academic institutions to help facilitate the transfer of knowledge.
• Finally, those representing academia argued that the Scottish Government should provide patient, long-term funding to encourage developers to undertake more local renewable energy projects, and also there is a role for the Scottish Government to provide further support for Local Authorities through the creation of an expert hub for local energy procurement.

15. Do you have any opinions on the initial focal typologies chosen?

Key Figures

• 16 responses (34.8%) were received for this question 

	Response Received	Not Answered
Community groups (5)	2	3
Local Authorities (8)	6	2
Public sector (6)	2	4
Academic Institutions (3)	1	2
Trade bodies and interest groups  (11)	3	8
Renewables industry (11)	2	9
Individuals (2)	-	2
Total (46)	16	30

Summary 

• As highlighted above, the majority of respondents (>65%) did not provide any comments against this question. 
• However, for those who did:
  • There was concern that this approach could “limit, as opposed to increase, ambition”.
  • A number of respondents felt the typologies were useful, but more clarity was required with regards to how this approach would work in practise and also to what end the typologies would be used.
  • A comment was also received that the use of these typologies may lead to restrictions of other opportunities.

16. How can local energy considerations become business as usual for industry?

Key Figures

• 21 responses (45.7%) were received for this question 

	Response Received	Not Answered
Community groups (5)	3	2
Local Authorities (8)	5	3
Public sector (6)	-	6
Academic Institutions (3)	2	1
Trade bodies and interest groups  (11)	6	5
Renewables industry (11)	5	6
Individuals (2)	-	2
Total (46)	21	25

Summary 

• Over half of respondents (54.3%) chose not to reply to this question.
• For those who did respond, 60% of Local Authorities believed that the Scottish Government should provide funding and support for the testing and deployment of innovation technologies. 
• Feedback from those representing the renewables industry included the need to ensure alignment between both Scottish Government and UK Government energy policy.  
• There was a desire amongst both the renewables industry (40%) and trade bodies/ interest groups (33.3%) for the Scottish Government to provide more regulatory incentives to ensure local energy considerations become the “norm”. 
• Finally, a comment was made that, once the Policy Statement is published, the Scottish Government’s next steps should involve the establishment of a clear timeline that sets out the future actions that need to be undertaken to ensure that the transition to local energy is realised.