Low Income Winter Heating Assistance: consultation analysis

2. Overview of proposals for LIWHA

This chapter provides an analysis of the first eight consultation questions. Respondents were presented with an overview of the Low Income Winter Heating Assistance and asked for their view on the proposal, its effectiveness and its name.

Q1. Do you agree or disagree with the proposal to replace Cold Weather Payment with a new benefit whose eligibility is based solely on receipt of a low income benefit and not on reaching a specific temperature for a period of time?

Q2. If you disagreed, please could you explain why?

Among all respondents (119)	Agree	Disagree	Unsure	No answer	No. of comments
Number	83	26	9	1	41
%	70%	22%	8%	1%

There was broad support for the introduction of LIWHA. Overall, seven in ten (70%) agreed with the proposal to replace the Cold Weather Payment (CWP) with a new benefit. One fifth (22%) disagreed and one in ten were either unsure or did not answer. While both groups supported the proposal, agreement was higher among organisations (83% compared to 64% of individuals). Follow-up comments to Q2 were given by 41 respondents. Although Q2 and Q4 asked respondents why they disagreed with the proposal, several respondents who supported the introduction of LIWHA gave reasons for their support; these expressions of support are included under the analysis of Q4.

Disadvantages households in typically colder locations

The most prevalent issue with LIWHA among the minority who disagreed with aspects of the proposal was that removing the cold spell criteria could make some households worse off under the new benefit than under the Cold Weather Payment. This recurring theme of concern, noted by some individuals as well as organisations such as Energy Action Scotland, Age Scotland and Scottish Federation of Housing Associations, was evident across responses to several questions and is addressed in detail in the analysis of Q8. To summarise, respondents highlighted that households in areas where there are typically more than two cold spells per winter, or prolonged cold spells, would receive less money than under the current system. For example, a household in an area which experienced three cold spells in a winter would receive £75 (3 payments of £25) under the Cold Weather Payment, but £50 under LIWHA.

"This will significantly disadvantage those living in the colder parts of Scotland." - Individual

Other reasons for disagreement

The second most common theme in response to Q2 was a concern that LIWHA could disadvantage some low income households. Many respondents noted that households could have a low income, but not be eligible for or claim the benefits which make them eligible to receive a LIWHA payment. Another common theme was that LIWHA does not help to address fuel poverty. Both of these themes were recurring across responses to several consultation questions and are addressed in detail in the analysis of Q4 below.

Another reason for disagreement, mentioned by a few respondents across later consultation questions (Q24, Q29 and Q31), was concern about the administrative costs of the scheme. A few respondents highlighted the time required to identify recipients, make payments and process requests for redeterminations and appeals; one doubted that the resources are available to administer LIWHA. An individual suggested "a guaranteed fixed payment, irrespective of means", while Citizens Advice Scotland called for more consideration of the cost-effectiveness of the proposed approach.

"An assessment of the likely administrative cost incurred in writing to all recipients of a qualifying benefit with a registered address in Scotland each year would also help to inform wider considerations as to the cost-effectiveness of the overall LIWHA policy." – Citizens Advice Scotland

"Why create a cumbersome bureaucratic process [for redetermination and appeals], no doubt costing more to deal with than the £50 in question?" - Individual

Small numbers of respondents gave other reasons for disagreement. Three felt the payments were an unnecessary use of public funds and one suggested the scheme makes too many assumptions and lacks flexibility. Two respondents who were unsure of the proposal, including Child Poverty Action Group in Scotland, called for more information about who will benefit from LIWHA and by how much.

Q3. Do you agree or disagree that this approach is an effective way for the Scottish Government to tackle winter heating costs for people on low incomes?

Q4. If you disagreed, please could you explain why?

Among all respondents (119)	Agree	Disagree	Unsure	No answer	No. of comments
Number	73	31	14	1	49
%	61%	26%	12%	1%

Overall, respondents offered their support for LIWHA as an effective way to tackle winter heating costs. Three fifths (61%) agreed, while one quarter (26%) disagreed and one in ten were unsure. Again, organisations were more likely to support the approach than individuals (75% and 55% respectively). Just over half of respondents (49) gave an open-ended comment at Q4. The three most common themes mentioned by similar numbers of respondents were that: the approach does not adequately address fuel poverty; it potentially disadvantages some low income households; and households in colder locations could be worse off (also described at the analysis of responses to Q2 and Q8).

Disadvantages some low income households

Perceptions that LIWHA would only support some low income households was another prevalent reason for disagreement among the minority who disagreed with aspects of the proposal, and a recurring theme throughout responses.

Respondents – mostly individuals - argued that while the eligibility criteria meant LIWHA is targeted at people on low income benefits, many households not in receipt of benefits could still be on a low income and need assistance. Several felt it was unfair that such households – particularly pensioners and those experiencing in-work poverty - could miss out on LIWHA because their income was only slightly over the threshold to receive the qualifying benefits. Chapter 3 includes a more detailed analysis of respondents' views on LIWHA's eligibility criteria.

"It is also recognised that many CAP clients are on very low incomes but not necessarily in receipt of the stated benefits. Those in low-paid part-time work or in receipt of inconsistent incomes will potentially miss out on a much needed method of support." – Christians Against Poverty

"The cold weather does not only effect those on low income and by limiting any payments to that section of the population you are especially penalising those who do not qualify for any help because they are just over the threshold by even a few pounds and so miss out on all the benefits that pension credits bring" – Individual

"Just because you don't receive benefits, doesn't mean that the costs of dealing with cold weather will not have an economic impact on your household, in fact many households who are just above the breadline end up being penalised because they are not "poor enough" (or marginalised health wise or employment wise) to qualify to receive aid." - Individual

Does not adequately address fuel poverty

Another prevalent theme at Q4, which was also common at Q2, was that LIWHA does not sufficiently address fuel poverty. The minority of respondents who disagreed with aspects of the proposal viewed the approach as ineffective, arguing that the payments offer short-term relief to 'take the edge off' a bad situation but are not a sustainable solution. Others felt the proposal could worsen fuel poverty in colder areas, where households potentially receive less money each year; this is detailed more under analysis of Q8. Specifically, Citizens Advice Scotland and Age Scotland noted that one policy intervention cannot be viewed in isolation, with the former calling on the Scottish Government to produce a plan to address the multiple drivers of fuel poverty.

Related to this, some respondents suggested approaches which they felt would be more effective. These included: investing in energy efficiency schemes; improving the energy efficiency of housing stock e.g. better insulation and investing in alternative heating systems which can be retrofitted to properties; and ensuring low income households have access to the cheapest tariffs. Age Scotland suggested that LIWHA should also ensure that eligible households are targeted directly with practical advice on energy efficiency.

"We agree that the Low Income Winter Heating Assistance can provide useful means to help older people struggling to pay for the increasing costs of energy provision to the home. However we would like to highlight that this will only go as far as offering an immediate short term relief on the impacts of fuel poverty amongst older people." – Age Scotland

"Whilst we agree that providing additional cash support to low income households is an effective approach this payment is not sufficient in scope, nor level, to tackle winter heating costs or fuel poverty" – Child Poverty Action Group in Scotland

"It is clearly a stop gap temporary fix - firefighting in some respects. Better targeted investment (with insulation) is needed to reduce energy demand and thus cost." - Individual

Payment too small / increasing energy costs

Another reason for disagreement at Q4 was a suggestion that the proposed £50 payment is too small to address winter heating costs. While some welcomed the £20 million budget, they believed the low value of individual payments would not have a significant impact. Some respondents highlighted that the payment will not be enough to mitigate the recent rise in energy prices. A detailed analysis of comments on this theme is provided at Q18.

Other reasons for disagreement

A few respondents shared other reasons for disagreement. These included concerns that the payments may not be used for heating costs (see Q20 for detail). Organisations including Poverty Alliance, Citizens Advice Scotland, Child Poverty Action Group in Scotland and Stirling Council argued that more needed to be done to address low incomes in general, such as increasing household incomes and having adequate social security.

Reasons for agreement

Although Q2 and Q4 asked respondents who disagreed with the proposal to explain why, several – mostly organisations - outlined reasons for their support of LIWHA. These views typically aligned within three themes. Most commonly, some felt the one-off payment, regardless of temperature, provided households with certainty about what payment would be received. This was seen as beneficial in budgeting and planning ahead. A more detailed analysis of the move to a one-off payment is provided in Chapter 5. A small number agreed because they felt heating assistance should be based on income and not temperature. A few also felt LIWHA was fairer than CWP and would help more people.

"Having the benefit as a guaranteed payment rather than a payment contingent on outdoor temperature will mean that people know how much they will receive and when, providing reassurance and certainty to people and enabling them to better plan their heating use and budget for bill payments." – Energy Saving Trust

"We agree that it is a more predictable way for individuals and families to receive assistance with heating costs during cold weather. It would remove eligibility based on the vagaries of weather, reach more people in need and provide a degree of security." – National Carer Organisations

"Agree. Save the Children supports cash payments being made directly to households who are living on low incomes to offer support to tackle the high cost of winter heating. It is vital that this payment goes direct to families so that they can manage their budgets and have control over their household finances." – Save the Children

"Age Scotland agrees with the principle of the new benefit eligibility being centred around income rather than experiencing significant drops in temperature below freezing for a sustained period of seven consecutive days." – Age Scotland

Other suggestions

A small number of respondents used Q2 and Q4 to suggest other approaches they felt would be more effective. These singular suggestions included:

• Reforming the Warm Homes Discount in Scotland.
• Making payments to those who spend a greater percentage of their income on fuel.
• Taking into account the level of home insulation.
• Using the budget on a smaller number of people who are more in need.
• Improving education on keeping homes warm.
• Involving charities to distribute the money to people who need it.
• For the Scottish Government to urge the UK Government to provide more support to those in need. Conversely, one individual disagreed with the proposal for LIWHA because they felt changes to CWP should be made at a UK level

"We think it is essential that any communications to householders about the replacement of Cold Weather Payment with Low Income Winter Heating Assistance signposts to Home Energy Scotland to ensure that householders are aware of where they can go for further advice and support about keeping warm at home, including improving their home's energy efficiency which is the best long term solution to reducing fuel poverty. Using this channel of communication will help the Home Energy Scotland service to reach the most vulnerable and challenging to reach householders who do not engage with most government services." – Energy Saving Trust

Q5. Do you agree or disagree with the proposal to name the replacement for Cold Weather Payment (CWP) in Scotland "Low Income Winter Heating Assistance" (LIWHA)?

Q6. If you disagreed, please could you explain why?

Among all respondents (119)	Agree	Disagree	Unsure	No answer	No. of comments
Number	57	47	14	1	55
%	48%	39%	12%	1%

Just under half of respondents (48%) agreed with the proposed name of Low Income Winter Heating Assistance. Four fifths (39%) disagreed and one in ten (12%) were unsure. While individuals supported the name (51% agreed and 36% disagreed), organisations were more likely to disagree (47% compared to 42% agree). Open-text responses to Q6 were given by 55 respondents.

Creates stigma

The most common reason for disagreement with the proposed name, especially among organisations, was that the term 'low income' could stigmatise recipients. 'Low income' was described as degrading, negative, insulting, embarrassing, unfair and as having connotations with poverty. Specifically, a few organisations felt 'low income' was inappropriate for the ethos of social security in Scotland.

"If you receive this benefit under this new name you are putting these people into a bracket that distinguishes them as of a lower category than others the same way that free school meals did in the past." – Individual

"This seems to go against one of the core principles of social security that have been adopted by the Scottish Government in that it appears to pay insufficient respect to the dignity of claimants and potential claimants of winter heating benefits." – Citizens Advice Scotland.

"Describing a benefit as being a 'low income' assistance is [inconsistent] with the wider social security Scotland messaging. We are not aware of any other benefits being described as 'low income' and doing so could be a barrier to take up. It also may cause confusion, as it is not available to many groups of people on a low income." – Child Poverty Action Group in Scotland

Alternative names

Suggestions for alternative names was the second most prevalent theme at Q6. Given the dislike of 'low income', the most commonly suggested alternative was Winter Heating Assistance (WHA). Other suggestions included Winter Heating Grant, Winter Heating Support, Winter Heating Payment, Winter Heating Assistance Payment, Winter Heating Costs Assistance, Supplementary Winter Heating Assistance, Equal Heat Assistance, Cold Weather Assistance Payment, Scottish Cold Weather Payment and Scottish Winter Heating Payment.

"I'm unconvinced of the need to label it 'low income'. I understand that this is a criteria, but I'm concerned that it adds to stigma. "Winter Heating Assistance" would be sufficient, the criteria could be spelled out for applicants" – The Moray Council

Keep Cold Weather Payment and avoid confusion

Several respondents felt the existing Cold Weather Payment name should be kept. They argued this was shorter, more memorable and recognisable. A few argued that some people within the LIWHA target audience could find the change unnecessarily confusing. Again, it was suggested that keeping the existing Cold Weather Payment name would avoid the stigma of including 'low income' in the name.

"People are used to Cold Weather Payments and changing benefit names is confusing for claimants." - CHAI Community Help and Advice Initiative

Length

Some respondents believed the name 'Low Income Winter Heating Assistance' is too long, or that its acronym LIWHA has too many letters. It was suggested that neither term 'trips off the tongue', and the long name might be difficult to understand.

Aspects of the name are misleading

Different aspects of Low Income Winter Heating Assistance were seen by some respondents as misleading. Most commonly, 'low income' could be misleading as not all those with a low income would receive the payment, only those who meet the eligibility criteria. A few argued this could lead to hesitancy and confusion around eligibility. A small number also questioned how low income was defined.

"The use of the term 'low income' in the title would be misleading as people who are in work and on low income are not included." – OPFS (One Parent Families Scotland)

Stirling Council noted that the term assistance could be misleading, as it suggests regular ongoing assistance with heating. They suggested 'Payment' as an alternative.

Other comments

Christians Against Poverty expressed their support for the name, highlighting its clarity and effective message; conversely, two individuals described the name as patronising and stupid. Another individual suggested the name of the benefit is irrelevant, as long as it reaches those who need it.

"CAP is in agreement with this change. It effectively ensures that recipients are clear that this is an entirely different support scheme, and maintains the updated narrative outlined in the Scottish Government's consultation." – Christians Against Poverty

Q7. Do you agree or disagree with the proposal to remove the requirement for a 'cold spell' to be identified in order for a client to receive a payment?

Q8. If you disagreed, please could you explain why?

Among all respondents (119)	Agree	Disagree	Unsure	No answer	No. of comments
Number	90	19	9	1	38
%	76%	16%	8%	1%

The existing CWP pays £25 when recipients experience a cold spell between 1 November and 31 March. A cold spell occurs when the average temperature is recorded or forecast to be at or below zero degrees Celsius for seven consecutive days. LIWHA proposes to remove the cold spell requirement for payment. Q7 asked whether respondents agreed with the removal of this requirement. Over three quarters (76%) of respondents agreed with the proposal. One sixth (16%) disagreed and a small proportion (8%) felt unsure. Almost all organisations who responded to the question agreed (86%), compared to 71% of individuals. Open comments were provided by 38 respondents at Q8.

Disadvantaging households in colder locations

The most prevalent issue identified by the minority of respondents who disagreed with this aspect of the proposal was that removing the cold spell criteria could make some households worse off under LIWHA than under the Cold Weather Payment. A few went on to say that this would exacerbate higher existing levels of fuel poverty in colder areas which result from higher energy costs and poorer quality housing. This issue was also discussed in detail at the stakeholder event.

Several respondents highlighted that households in areas where there are typically more than two cold spells per winter, or prolonged cold spells, could receive less money than under the current programme. For example, a household in an area with three cold spells in a winter would receive £75 (3 payments of £25) under the Cold Weather Payment, but £50 under LIWHA. Some referred to this being a particular concern in the rural north of Scotland and the Islands. Energy Action Scotland, Scottish Federation of Housing Associations and Poverty Alliance cited Braemar as an example – in the relatively mild winter of 2021/22, three cold spells were triggered (totalling £75 across three CWPs), compared to seven in 2020/21 (totalling £175) and 10 in 2012/13 (totalling £250).

Specifically, Family Fund, Inclusion Scotland and Age Scotland noted their concern for those living in six (of 27) weather station areas identified in the consultation paper as being more likely to lose money under LIWHA. Age Scotland approximated 17,000 people would receive less under LIWHA compared to the existing CWP.

Some respondents pointed out that, due to unpredictable weather, a fixed rate of £50 could mean that all households receive less than under CWP in a particularly cold winter.

"Most years in my area of Lochaber we get more than 2 cold weather payments, so the proposed £50 help would actually make us worse off. My wife and I are disabled and live in a home prone to mould and damp, so we have high energy costs due to mains gas not being available in Lochaber." – Individual

"The consequence is a benefit which fulfils a completely different function to the Cold Weather Payment and no longer helps those who are disadvantaged by the fact they live in an area which can be exposed to extreme weather conditions. If this benefit is to be replaced, there should be alternative mechanisms as part of the Fuel Poverty Strategy which offer adequate levels of assistance to these households during the winter months." – Scottish Federation of Housing Associations

"Among households who live in parts of Scotland more regularly exposed to periods of temperature-driven enhanced building heat loss, the Scottish Government's proposals will increase the fuel poverty gap and are likely, in a cold winter, to result in many experiencing adverse outcomes to their health and wellbeing." – Citizens Advice Scotland

Additional support for colder areas

Given the concerns over some areas being comparatively worse off under LIWHA, several respondents suggested alternative ways to support those in colder locations, including:

• A payment supplement or additional targeted payments to parts of Scotland with more frequent adverse winter weather. OPFS (One Parent Families Scotland) called for a feasibility study to determine the amount needed to assist colder areas. Cystic Fibrosis Trust proposed that LIWHA is implemented alongside CWP to ensure those who live in the coldest parts of Scotland do not lose out.
• A few suggested an approach whereby LIWHA payments are weighted based on geography and heating type availability.
• Glasgow City Council recommended that discretionary power be granted in the case of extreme cold weather. Similarly, Poverty & Inequality Commission for Scotland called for extra funding to some local authorities.

"We therefore believe that the Scottish Government should look at the viability of creating 'Cold Weather Premiums' for areas that we already know experience the most significant drops in temperature over the winter period and provide eligible households within these postcode areas with an additional top up of at least £25 in their LIWHA." – Age Scotland

"We suggest that, in addition to Winter Heating Assistance, extra funding is given to Local Authorities covering areas with particularly cold weather, such as Highlands & Aberdeenshire, via the Winter Support Fund. That would give those Local Authorities the capacity to provide additional financial help to those living in the areas covered by the weather stations that regularly record lengthier cold spells." - Poverty & Inequality Commission for Scotland

Retain a link to temperature

Another common theme was a call to keep the payment related to temperature. Respondents argued that it costs more to heat homes in cold weather and that should be the basis of the payment. Linked to the themes above, a few noted that those living in colder parts of Scotland would be disadvantaged; retaining the link to temperature would mean those with the greatest need were targeted. For example, while the Scottish Federation of Housing Associates agreed with some of the reasons to remove the cold spell requirement, they worried that without any connection to temperature LIWHA fails to account for the large variation in costs of heating across Scotland.

The Scottish Government's proposals for LIWHA would therefore remove the only form of financial support that currently comes close to accounting for the divergent consumer outcomes caused by regional differences in weather and deny the wider package of measures within its control the ability to be sufficiently locally responsive to factors which influence local fuel poverty rates. We do not therefore consider that removing a link with the weather is consistent with a credible plan to eradicating fuel poverty in every local authority area in Scotland by 2040. – Citizens Advice Scotland

Among those who disagreed, a few recommended broadening the definition of cold spell. Citizens Advice Scotland suggested considering multiple factors like those used to calculate the 'feels like' temperature, i.e. the dry bulb temperature, humidity, and airflow. Energy Action Scotland highlighted multiple ways to improve and extend triggering events. These included raising the triggering temperature to above 0 degrees Celsius, reducing the length of the cold spell from 7 days, and measuring beyond absolute air temperature.

Unnecessary Payment

A few respondents expressed concern that payments would be made in mild weather when heating was unnecessary, if the cold spell requirement was removed. They suggested payments should only be made in cold weather, otherwise the support could be seen as 'just another benefit'.

"There is a reason for the current system, and the proposal removes this reason, takes away this safety net, and dishes out money regardless. This proposal is wasteful, badly conceived and pointless." - Individual

Keep or modify the CWP

Two respondents approved of using the current CWP approach without amendments; another individual felt CWP works well but would benefit from a higher payment rate.

In their detailed response, Citizens Advice Scotland argued for an alternative approach - the Adverse Weather Payment (AWP) - which maintains a link to temperature and provides low income households with short-term financial relief from heating costs. Recognising this may not be feasible within legislative timeframes, they advocated for a temporary devolved version of the CWP, using existing triggers and eligibility criteria. This could be replaced with an alternative to LIWHA after further discussion. Their response explains how such an alternative could operate. At the stakeholder event, Citizens Advice Scotland also noted issues around budgeting for the CWP, but felt that any underspend from a mild winter could be reinvested in other Scottish Government fuel poverty schemes.

While not linked directly to the cold spell criteria, Energy Action Scotland also felt "it would be better to adopt the current Cold Weather Payment system with a view to developing and improving it. Once it has been deployed the Scottish Government should consult on the best options for amending it based on direct operational experience."

"It is important that the introduction of LIWHA is done well as it is a precursor to the Winter Fuel Payment which is perhaps the single largest intervention to support people to access heat and power. As it stands LIWHA has no targeting, no clear policy alignment to reducing fuel poverty and appears to be a low cost administrative option. As such it equates to little more than £1 per week to those that receive it. It would be far better deployed recognising the role it can plan in helping people at time of climatic stress and indeed is scaled in relation to extreme events as they occur." – Energy Action Scotland

Other discussion on the CWP included calls from a small number for changes to the weather monitoring and data collection systems which trigger cold spells under CWP. They shared examples of places which do not receive payments for cold spells because their linked weather station is in a milder area. Suggested solutions included more weather stations, in a wider range of locations, to make readings more accurate and targeted.

"The location of the 27 weather stations in Scotland has also raised questions over accuracy and fairness. As noted in the consultation document, there could be opportunities to look at increasing the number of weather mapping points or better capturing the effects of wind chill. We would like to see the Scottish Government explore these options further before removing the requirement for a cold weather event completely." – Scottish Federation of Housing Associations

Reasons for agreeing with LIWHA proposal

In describing their agreement with the LIWHA, some observed that removing the link to cold weather would increase certainty about fuel assistance. A few felt it give households confidence that money would be available to allow them to put on or turn up their heating.

"Removing the requirement for a week-long period of freezing temperatures would give more confidence to recipients that they have some financial assistance available to help pay for increased energy use when it is cold, and not waiting until after it has been very cold for a week exactly to turn up their heating for fear that money wouldn't be available." – Age Scotland

A few respondents believed removing the cold spell trigger creates a simpler and fairer benefit, as the criteria created too much variance in payments around Scotland. One noted that winters, whether colder or milder, required more heating.

"We agree. It avoids those periods of cold weather but don't quite fit the criteria for 7 days or the temp is slightly too high and prevents people from receiving help under the current system. This new way will ensure everyone who is entitled, will receive the payment regardless of weather or where they live. It is a much fairer system and will help avoid the frustration of people still having higher bills due to cold weather but missing out due to the criteria." – Castle Rock Edinvar