Low Income Winter Heating Assistance: consultation analysis

7. Other impacts and Impact Assessments

Consultation questions Q33 to Q37 asked respondents for any further information they wished to share about the impact of LIWHA. Analysis of responses to these questions is presented in this chapter, along with analysis of responses to Q32 and Q38 which asked respondents for any information on unintended consequences or the implementation of LIWHA.

A small number of respondents, such as Child Poverty Action Group in Scotland and Scottish Women's Convention, called for impact assessments such as Fairer Scotland Duty or Equality Impact Assessments (EQIA) to be carried out before impact is evaluated.

Q33. Please set out any information you wish to share on the impact of LIWHA on groups who share protected characteristics?

There were 41 open-text responses to Q33, though four of these comments were statements to the effect that they had nothing to add.

Disability and mental health

Among comments about groups with protected characteristics, the most commonly mentioned were people with disabilities and or mental health conditions which fall under disability as a protected characteristic. A few respondents believed that LIWHA would positively impact recipients with disabilities, noting this group may spend more time at home and often spend more on heating to maintain consistent household temperatures. One respondent noted that people with mental health conditions or learning difficulties may have difficulties managing and budgeting a one-off payment.

"We believe that LIWHA will provide a level of certainty to families on a low income raising a disabled child, in particular, those who are not eligible for Child Winter Heating Assistance. In a recent survey by Family Fund, 51% of respondents from Scotland indicated that they have to pay more for energy as a direct result of their disabled children's conditions or illnesses. Households which include a family member with a long term health condition often have to use more energy in order to maintain a certain temperature, or due to a reliance on certain equipment." – Family Fund

Age

A few respondents commented on LIWHA in relation to different age groups. A small number mentioned the burden of low wages and gig employment on young people who then struggle to pay fuel bills. However, unless they claim relevant benefits, they may not be eligible for LIWHA. Two respondents noted the impact on young children, which is addressed in more detail in Q34. One respondent mentioned pensioners who may be ineligible for LIWHA but in need of extra support to afford to keep their homes warm.

Other protected characteristics

While a few respondents highlighted the positive impact LIWHA could have on lone parents, two respondents suggested that the qualifying week could be problematic for single-parented households and women. They suggest that lone parents are more likely to be in work with varying weekly hours, e.g. part time, shift or temporary workers. This means their circumstances and benefit claims may be different just before or after the qualifying week.

"This is unfair in particular to women (+90% of lone parents are women) who as a gender are more likely to be in part time employment. Thus, the use of a qualifying week may amount to indirect discrimination against female claimants as it would tend to disproportionately impact on them. Indirect age discrimination may also occur if a week, rather than a longer qualifying period, is used as younger workers are more likely to be dis-entitled because their hours of work are more likely to vary." - Poverty & Inequality Commission for Scotland

Citizens Advice Scotland highlighted that Gypsy/Traveller communities often live in homes with lower levels of energy efficiency, and so those communities in colder areas of Scotland may be adversely affected by LIWHA.

Accessibility considerations

Several respondents addressed the need to ensure those with protected characteristics are both aware of LIWHA and have access to information. This includes considering:

• Digital exclusion and illiteracy, particularly among the elderly.
• Adjustments for people with disadvantages and impairments that make accessing information difficult.
• Implementing LIWHA with a diverse team who can provide information in multiple languages.

Respondents shared suggestions to ensure information about LIWHA and the associated benefits reaches all eligible households. These included national awareness campaigns, targeted publicity material, and delivery of information through a variety of channels.

"Consideration also needs to be given on encouraging take-up of qualifying benefits, e.g. pension credit, as even in circumstances where the monetary entitlement is relatively small, it will act as a passport benefit to the LIWHA payment." - National Carer Organisations

Q34. Please set out any information you wish to share on the impact of LIWHA on children's' rights and wellbeing?

Around one quarter of respondents (27) provided open-text responses to Q34. Two stated that impact assessments and further details were needed before answering this question.

Positive impact

A common theme, mentioned by some respondents, was that LIWHA would have a positive impact on children. Respondents acknowledged the new scheme could provide an increase in income for eligible families, improving the health, wellbeing and development of more children in Scotland. OPFS noted that the payment needs to be large enough to make a difference, but did not suggest what this level would be.

"My hope is a levelling up of life opportunities for the children of "low income" families who are being left behind & falling through the safety net." - Eagle's Wings Trust Dundee

'We believe that LIWHA will enable more children to enjoy their right to an adequate standard of living that is good enough to meet their physical and social needs and support their development. We also believe that it will support children to enjoy their right to the best possible health.' – Family Fund

A few commented on the positive impact of LIWHA on children with disabilities. Two respondents acknowledged the potential to help meet the state's responsibility under Article 23 of the UN Convention on the Rights of the Child^[3]. However, the Poverty & Inequality Commission for Scotland also felt the amount of assistance was not high enough to fully ensure disabled children's right to 'enjoy a full and decent life'.

"Disabled children, can often lose out as well, because they need a lot of heating, but their guardians just can't afford to put the heating on, or even the washing machine, because of issues with their energy suppliers, and then homes are filled with wet washing which causes even more cold issues in the home, which then in turn can and does effect children's health." - Individual

Negative impact

Another common theme was that some families with children could lose out under LIWHA. Respondents cited a few ways in which this could happen. A small number noted that some families with low income who are struggling to heat their homes will not be eligible as they do not receive the qualifying benefits. Related to the more general theme of some households being comparatively worse off under LIWHA (see Chapter 3), Citizens Advice Scotland noted that families in colder areas could potentially receive less money than under the CWP. They believe the negative impact on these children outweighs the benefit to others in urban areas who may receive more under LIWHA than they did previously under CWP.

Two respondents highlighted timing issues, providing examples of children born after the qualifying week who may miss out even if their household was otherwise eligible.

"There may be some children who are born after the third week in September and if this is taken as the qualifying week then we will have a situation where (unless there is another route to entitlement) that family will not qualify for the LIWHA. Also there will be some situations where a young or disabled child is living away from the parents, perhaps in foster care, and if they were to return home after the specified week then there would be no entitlement to the LIWHA" – Glasgow City Council

A few respondents thought LIWHA would not positively impact children. Their reasons included: the payment amount is too small; that it does not include children over the age of 5; the CWP is fairer, and that children may be adversely affected if the payment is spent on other things rather than paid directly to the energy supplier.

Other suggestions for how to have a positive impact on children were mentioned by small numbers. These included:

• In relation to LIWHA, extending eligibility to all homes with children and considering how many children live in a household. One called for a new, targeted approach for low income families with older children.
• Two respondents called for improved home energy efficiency.
• Two highlighted the need for any new assistance to align with existing benefits and social security. The Highland Council called for a 'thematic approach based upon multidisciplinary expertise and experience from a range of stakeholders'.

Q35. Please set out any information you wish to share on the impact of LIWHA on businesses?

Open-text responses to Q35 were given by 11 respondents, of which four stated they had nothing to add or contribute specifically in relation to the impact on businesses.

A small number gave comments about energy companies, but there were no consistent themes identified in these comments. One stated that if the payment was made directly to energy suppliers it would help their cash flow. Another stated that energy companies would be chasing less long-term debt. One felt that energy companies are profiteering and should be taxed appropriately; another suggested LIWHA should be paid for by taxing energy company's profits.

An individual and Citizens Advice Scotland highlighted that LIWHA could have an adverse impact on businesses and charities who support low income and vulnerable households during cold weather. They argued this would be particularly felt by organisations including community-based organisations and advice services who help people access assistance. Citizens Advice Scotland also pointed out that any increase in fuel poverty as a result of introducing LIWHA could create an additional cost to the NHS through associate ill-health, and that this should be considered when assessing the cost-effectiveness of LIWHA.

Other singular comments included: the impact of rising energy costs on businesses; businesses wanting to avoid higher costs; and that the payment could generate spend in a local area.

Q36. Please set out any information you wish to share on the impact of LIWHA on Island communities?

Responses to Q36 were provided by 22 respondents, with the most common theme being the higher rate of fuel poverty in island communities. Respondents cited several reasons islanders face increased fuel poverty rates. These include the comparatively higher cost of fuel and energy supplies, a lack of mains gas, the lack of an energy cap on coal and oil, the high cost of sustainable energy, and the poor energy efficiency of homes.

Some respondents called for LIWHA to have a greater recognition and consideration of these challenges. Two respondents disagreed with the timing of LIWHA payments as many residents buy fuel (oil or solid fuel) before the proposed February payment date.

"As stated previously, island communities may through necessity use fuel sources such as heating oil and wood suitable for burning as a heat source. As such, payment earlier in the winter might better support such households to be able to purchase adequate supply ahead of the coldest months when delivery can take some weeks to organise." – Family Fund

Others suggested an additional or higher LIWHA payments for islands and rural areas.

"Rural areas can have higher distribution cost therefore an additional payment could be made to isolated areas. It may be rural areas which had 3/4 cold spells would have got £100 but will now only get £50. Also fuel costs are higher in rural areas." – OPFS

"Island communities experience more extreme weather conditions and more costly tariffs than other parts of Scotland. Applying an uplift for Island communities would provide a proportionate rate of LIWHA when compared to the rest of Scotland." – The Highland Council

"A rural uplift is proposed as part of the Fuel Poverty Act 2019 yet there is no meaningful attempt to align the LIWHA to the goals of the Fuel Poverty Strategy 2021 nor the Heat in Building Strategy." – Energy Action Scotland

A small number felt island communities could lose out under LIWHA if they had received multiple CWPs in previous years (as described more generally in Chapter 2). Glasgow City Council suggested more information was needed to determine how many of those who received more than two CWP in any given year are living in island communities.

Conversely, some respondents, including Shetland Islands Council, Inclusion Scotland and Citizens Advice Scotland, noted how LIWHA could benefit island households. They noted that island temperatures infrequently fall below zero degrees Celsius because of the Gulf Stream, meaning that they rarely qualified for CWPs under the cold spell trigger. However, wind chill can still create low temperatures, resulting in greater energy use and spend in areas where costs are already higher. While some therefore argued that LIWHA could provide island households with some certainty, Citizen Advice Scotland felt LIWHA would make little material impact given the higher rates of fuel poverty in the islands.

"The Gulf Stream/North Atlantic Drift and the sea both tend to moderate temperatures in the islands (and indeed West Highland coastal communities). Despite this the impact of "wind chill" can result in the need for greater energy use. This is because wind speed tends to be higher in the islands making temperatures, which, according to the thermometer, are a little above freezing, feel more like minus four or five. Thus, the proposal to do away with the need for seven consecutive days of cold weather should benefit families in island communities as they will be certain of entitlement to £50 of assistance each winter." – Poverty & Inequality Commission for Scotland

A small number of respondents expressed their support in broad terms, stating that any additional assistance to island residents and areas with high fuel poverty is welcome.

Q37. Please set out any information you wish to share on the impact of LIWHA on reducing inequality of outcome caused by socio-economic disadvantage?

Open-text responses to Q37 were provided by 25 respondents.

Some respondents stated LIWHA would reduce the inequality of outcome caused by socio-economic disadvantage but observed that the impact may be small.

"This new benefit should have a positive impact on reducing inequality of outcome caused by socio-economic disadvantage as it provides an additional benefit which is paid directly into the recipients bank account." - Dumfries and Galloway Poverty and Inequalities Partnership

"Winter Heating Assistance will make a small contribution towards reducing the socio-economic disadvantage experienced by households containing disabled adults and/or children and that of families with younger children. However, it will come nowhere near actually meeting the additional energy costs that are experienced by households containing disabled people/children." – Inclusion Scotland

A few respondents expressed concern that LIWHA will not positively impact the inequality outcomes caused by socio-economic disadvantage; for example ineligible households would still struggle to pay heating costs because of their low income. Citizens Advice Scotland noted that those in cold areas could lose out. A small number of respondents mentioned location of households on the impact of the payment. The varying weather patterns and heating costs across Scotland were highlighted and some respondents stated that LIWHA did not provide enough to account for the variation.

"Costs are variable but at this current time we are experiencing the biggest increases in living memory. A 54% increase for GB average dual fuel bills on 1 April. Yet the average dual fuel bill in Scotland is estimated to be 50% more than the GB average. Indeed in some of our island communities and off-gas areas bills can be 100% more. A failure to recognise this and adjust payments to provide some equity to achieve comparable comfort levels consigns these communities to continuing disadvantage and inequality." – Energy Action Scotland

"Whilst the proposals do identify that some households will actually experience a reduction in the level of support with winter fuel costs as a result of the changes, they fail to fully acknowledge the potential impact on affected individuals' health and wellbeing and to set out how such impacts will be ameliorated." – Family Fund

Ensuring LIWHA works in tandem with other programs was suggested by a few respondents. These included programs to ensure energy efficiency of housing and educational programs to assist in household financial management.

"Heating is more expensive for people who pay as you go or have prepaid meters or those who don't know how to shop around and perhaps have been left with a [higher tariff] after their energy provider ceased trading. This practise needs to be subsidised or stopped as its burdening those already burdened with money worries." - Individual

Q32.Can you identify any potential unintended consequences which we have not considered in these proposals?

Q38. If there is anything else you would like to tell us about the described policy intention, impact assessments or LIWHA in general, please do so here.

Over half of respondents (56) responded to Q32 and just over one quarter of respondents (26) responded to Q38. However, almost all made or repeated points which they or others had already made in relation to other questions; these comments have been included in the analysis of the relevant questions. The summary below presents other points raised.

Singular comments on unintended impacts which did not align with existing themes included one individual who felt that LIWHA created a situation where benefits differed across the UK and another who asked for the needs of those undergoing cancer treatment who need to heat their home to be considered. Save the Children and Child Poverty Action Group in Scotland noted that the introduction of LIWHA could be an opportunity for greater sharing of social security to data to maximise incomes in Scotland:

"There is an opportunity to ensure data sharing across social security, and across the public sector in Scotland to maximise incomes. For example, data sharing agreements with the DWP must be such that they allow SSS to use the data on eligibility to LIWHA to increase take up of the Scottish low income benefits such as the Scottish child payment. At the very least, this data should be used in such a way as to ensure that families who are not claiming Scottish child payment are made aware of their entitled. Ideally it should be shared in such a way that it allows automation of payments. This will help Scotland meet its child poverty targets. Another example would be to have clear referral pathways between SSS and Warmer Homes Scotland – everyone eligible for a LIWHA also meets the current benefit criteria for a warmer homes discount. Data should be used in such a way as to refer recipients to Warmer Homes Scotland, or the equivalent scheme, to check eligibility for other energy saving measures. This will help Scotland meet its net-zero targets." – Child Poverty Action Group in Scotland

Other singular comments included:

• The Scottish Federation of Housing Associations called on the Scottish Government to lobby the UK Government for wider social security reforms, to maximise the support available through devolved benefits, and to press for a clear timetable for reforms to the energy market. Their response also calls on the Scottish Government to take forward the recommendations of the Zero Emissions Social Housing Taskforce (ZEST) on approaches to improve energy efficiency in existing housing stock, including increased investment in social housing retrofit programmes, with a fabric first approach to help reduce energy demand, and a review of the EESSH2 targets to ensure alignment with fuel poverty and climate change objectives.
• A suggestion to include an information sheet with the payment to direct households to Home Energy Scotland and other agencies who could provide energy advice.
• Providing those on low incomes with small, newbuild accommodation which is easier to heat, and providing warm community spaces for teenagers or single parents.
• At the stakeholder event, one participant questioned how the policy would be evaluated. They suggested a logic model and a more detailed monitoring and evaluation plan should be in place before the policy is implemented.

A few respondents commented on the consultation itself. Citizens Advice Scotland and Inclusion Scotland urged the Scottish Government to ensure that draft Impact Assessments are available during a consultation so that stakeholders can scrutinise them and provide constructive feedback on policy proposals. Two organisations felt the consultation had the potential to exclude certain groups; Inclusion Scotland noted the lack of an easy read version of the consultation and Dumfries and Galloway Poverty and Inequalities Partnership felt the format of the consultation may exclude those who are interested in responding but do not have the 'social capital' to do so. One individual considered the consultation to be a box-ticking exercise.