Scotland's Sustainable Housing Strategy: Analysis of Responses to 'Homes that Don't Cost the Earth' Consultation

2 Analysis of responses: A National Retrofit Programme

2.1 Questions 2 to 10 address issues of the National Retrofit Programme (NRP); all were open questions. There was a high average response rate for this section (77%).

2.2 The WWF campaign response welcomed the National Retrofit Programme, but did not directly answer the consultation questions. It noted the need for milestones to meet a 42% reduction in emissions from the housing sector by 2020 and eradicate fuel poverty by 2016.

2.3 Questions 2 to 4 address how to facilitate the installation of energy efficiency measures in the private sector, including in rural, remote and island areas.

Q2 What do you think are the main barriers that prevent home owners and landlords from installing energy efficiency measures?

2.4 Most respondents answered question 2 (85%). A quarter provided extensive responses. Some suggested solutions as well as barriers; these are included in the analysis of question 3. A few of the non-standard campaign responses also identified barriers. The main barriers identified are set out below.

2.5 Costs and financing Respondents pointed out that capital for up-front costs is a particular barrier in lower value first time buyer homes, while investment in energy efficiency may not enhance the value of the property, and measures to improve hard-to-treat properties have long payback periods. There was confusion about how the Green Deal and ECO would apply, and concerns about whether ECO would be effective for hard-to-treat properties, including uncertainty about the funding of solid wall insulation.

2.6 Consumer perceptions and behaviour, inadequate information Consumers were often not aware of the measures or practices they could adopt and the benefits that would result from investment. Residents were often unable to see a direct impact from passive measures such as loft and cavity insulation and installation was unlikely to encourage neighbours to do the same.

2.7 Perceived 'hassle' and disruption. Several respondents commented on issues such as residents being unwilling to clear loft space or move furniture to allow skirtings to be taped before installing cavity wall insulation. They noted that some measures cause high levels of disruption and that internal wall insulation reduces room sizes. RSLs could also face 'hassle' with Combined Heat and Power (CHP) or district heating schemes where they become the energy supplier, responsible for collecting payments from tenants.

2.8 Questionable benefits of measures, fears of technical problems Some relayed consumers' lack of confidence in claimed energy savings, and fear of poor quality of work and damage to their homes. There was generally little understanding of wall insulation, while building professionals appeared to disagree over the technical aspects of solid wall insulation.

2.9 Physical nature of the stock Many respondents identified difficulties associated with the physical nature of the stock, building condition, energy supply, or location. These were illustrated by some of the non-standard campaign responses: these called for research to help those living in granite buildings to insulate their homes and reduce energy burdens; reported problems with the replacement of degraded cavity wall insulation; described the difficulty and cost of heating common urban house types such as ground floor tenement flats; and called for replacements for inefficient white meter electric storage heaters.

2.10 Confusing range of offers and uncertainties about advisors and contractors Several local authorities felt that households don't know who to trust, with letters from utility companies and door step selling which create suspicions of genuine free offers and fears about bogus callers. Funding mechanisms were difficult to understand and there was a complex landscape of grant provision, with frequent changes in programmes.

"we have had to report several companies to trading standards for telling people that they are working for the Council when they are not and for stating that the householder will be fined if they do not get loft insulation installed" – Local authority

2.11 Difficulties of improving mixed tenure blocks and common parts Respondents noted that improvements were often delayed where the consent of owners must be obtained and was withheld. This is a particular challenge in non-traditional properties where the cost of retrofit is higher.

2.12 Other issues were the lack of incentives for private landlords, and limitations imposed in conservation areas and listed buildings, a concern also raised in some non-standard campaign responses:

"My house costs £155 per month for electricity and £30 per week, averaged out over the year, for firewood. I am not permitted to double-glaze, even with appropriately designed timber frames, as the house is B Listed - as a pensioner, this is a quite unaffordable burden" – Individual campaign respondent

Q3 Please explain any practical solutions and/or incentives to overcome any barriers you have identified.

2.13 Most respondents answered question 3 (85%) and offered possible solutions to some of the barriers they had identified. A quarter provided extensive responses. The following analysis links responses to the key issues identified in question 2 to suggestions in question 3 - often similar solutions were raised to address different issues; some may not be directly relevant to the NRP.

2.14 Funding the work Respondents recommended a variety of incentives including continuity of funding schemes and assistance for owners, while some questioned the viability of the Green Deal and ECO. All types of respondents called for incentives related to energy efficiency improvements or energy generation. Council tax rebates were most often mentioned. Several called for additional reductions in Value Added Tax (VAT), such as a zero rate on insulation, windows, and retro-fitting works, or more commonly a 5% rate on the labour element of home repair, maintenance and improvement works.

2.15 Others called for a rebate on Land and Buildings Transaction Tax (LBTT)^[2] for those purchasing the most energy efficient homes or for retrofitting within 6 months of purchase. One respondent suggested a sliding scale rebate for LBTT, up to 100% for achieving an 80% reduction in predicted CO₂ emissions. Others called for a Scottish Feed-in Tariff (FiT) at the previous higher level, and to make the Renewable Heat Incentive (RHI) available to larger landlords such as RSLs. Non-standard campaign responses included calls for making part of the extra expense of zero carbon energy tax-deductible, and to divert subsidy from wind turbines to a retrofit programme.

2.16 The stability of funding programmes for improvements was a common theme across sectors: a single national universal grant over 5 years would allow better opportunity to engage partners to spread the message and improve uptake; schemes should be funded over the longer term to achieve a reasonable level of stability in the volume of measures. Some commented on the scope of programmes, with calls for the continuation of existing programme services including benefit and tax credit checks, referral of households to utilities for energy cost reductions, and energy efficiency advice. There were also calls for a national fuel poverty scheme to complement the proposed area based schemes, and for grant assistance from the energy companies and other sources for low-income owners to install energy efficiency measures.

2.17 Some respondents queried whether Green Deal and ECO would allow a whole house approach, with sufficient funding for solid wall insulation. Others questioned the viability of the Green Deal and ECO, with suggestions that the Energy Saving Scotland Home Loan scheme should be reintroduced, and for a simpler finance model for Scottish retrofit, based on bulk discounts.

2.18 There were several calls for additional funding. An RSL called for direct funding for top up loft insulation and solid wall insulation, and also to fund wall insulation for adjoining owner-occupiers so that the RSL would not carry the debt risk. A private sector organisation called for grants or loans to cover both reinstating the property, including redecoration, and ancillary costs such as scaffolding. A non-standard campaign response called for grants or soft loans to be sufficient to enable deep whole-house retrofit (to zero-carbon or passive house standards), rather than repeated small-scale interventions. One RSL suggested a way to limit costs, whereby social housing organisations would share the benefit of competitively procured services with nearby private householders, though with the householder directly contracting the installer. Another warned that requirements might impact on RSL and local authority budgets and work plans based on component lifecycles if equipment were required to be replaced ahead of its due date.

2.19 Many respondents suggested measures to counter consumer perceptions and behaviour, and inadequate information. These again included calls for incentives, such as inheritance tax reductions as well as lower rates of council tax, VAT, and LBTT. Others identified desirable features of improvement programmes: information on preventative maintenance in conjunction with an area based scheme with the Local Authority as 'trusted brand'; area-based programmes with face to face advice, plus intensive support for those in greatest need, regardless of location, similar to the Energy Assistance Package (EAP);impartial advice through the ESSac network; and free insulation measures.

2.20 Many called for local and national awareness campaigns about energy efficiency and the available grant and incentive schemes – one noted a report in August 2012, which stated that there had been a very low take up (0.04%) of council tax discounts since 2009. Others wanted a practical householders' guide to retrofit measures for the main Scottish property types, and for sign-posting towards trusted contractors. A common call was for the clear statement of the costs of improvements, and the scale of benefits in improved comfort levels and estimated fuel savings. DVDs and television programmes could show installations of energy saving equipment. Both home owners and private landlords could be helped to understand the potential benefits and issues of improvements with demonstration homes that are typical local house types such as a tenement flat or ex-council house, with energy efficiency measures installed. Other measures to change consumer perceptions were suggested: better use of the Energy Performance Certificate (EPC) at sale or rental; a minimum energy efficiency standard for private rented housing; every home to have a current EPC; a building 'MOT' that addresses the basic wind and watertight condition of a home; and requirements for consequential improvements when building work was done.

2.21 There were some suggestions for ways to reduce 'hassle:' a support network providing services such as loft clearance for those unable to carry out the work themselves; staff time and resources to provide advice and practical help to landlords and owners; financial incentives to tenants to decantwhile improvement works were carried out; and provision of suitable decant accommodation, which was currently very limited across all sectors. RSLs could be provided with dedicated funding for staff to administer district heating schemes.

2.22 Of those commenting on measures to counter questionable benefits of improvement measures, there were a few detailed responses that identified the need for: good practice in specification, installation, monitoring and awareness raising about specific technologies; assessor and installer training specific to technologies and Scottish house types; guidance and guarantees for work on hard-to-treat house-types; design to consider performance over time; case studies to verify cost models for improvements across all house types, and a national register of building types. Many of these suggestions also apply to issues of the physical nature of housing stock. There were several calls to draw together lessons from solid wall projects funded through various Scottish and UK programmes and initiatives; and for better modelling software than RdSAP/SAP for hard-to-treat properties. There were also calls for enhanced funding for rural homes, leniency on targets for hard-to-treat homes, and improvement to energy supplies. A private sector call to empower informed decisions by property owners through an independent survey scheme was illustrated by one of the non-standard campaign responses:

"if there was someone that could inspect homes like mine (built in 1880s) to find out where all the heat was escaping and check where draughts were getting in so that they could be prevented, that would be an enormous benefit." - Individual campaign respondent

2.23 Other measures to improve the quality of installations included: design informed by research that takes account of how mechanical ventilation with heat recovery (MVHR) works in practice and degradation in performance over time; and third party scrutiny of installers, equipment, and techniques to be acceptable to the warranty and insurance sectors. An example of this was the forthcoming Solid Wall Insulation Guarantee Agency (SWIGA).There were also many suggestions for high levels of funding to support energy supply solutions in rural areas and insulation for hard-to-treat homes.

2.24 There were many suggestions for measures to reduce confusion about the range of offers. Several called for a one-stop approach through local energy advice teams, with referrals from partner helplines, and consistent promotional campaigns. Some called for a whole property approach co-ordinated by local authorities and simplified funding streams run by a single agency.

"A whole property approach is needed and not just offering single measures... projects have brought together UHIS, CESP and Private Sector Housing Grant to maximise the measures and funding available .. this included external wall insulation, new roofs and chimneys, loft insulation, draft proofing and where appropriate, new boilers and heating systems." – Local authority

2.25 An assisted-approach Care and Repair model would help older and more vulnerable householders. Reliable advice was a common theme, including:

"There must be more engagement with installers. EST research has shown that the majority of householders rely on the advice of their plumber, electrician when installing replacement heating systems." –Scottish & Northern Ireland Plumbing Employers' Federation (SNIPEF)

2.26 Difficulties of improving mixed tenure blocks and common parts Measures suggested to facilitate co-operation included: financial assistance, possibly with graduated subsidy that would increase in line with the number of units dealt with in one project; learning from UHIS innovative projects; a loft clearance service; and early information and advice to owners to encourage investment in repairs and maintenance.

2.27 With regard to the issue of lack of incentives for private landlords, views were very diverse, with groups calling for regulation through Private Landlord Registration, albeit with some handholding, and the private sector's advocacy of increased levels of Landlords Energy Saving Allowance (LESA), a phased improvement of stock for large landlords over the period to 2050, and access to ECO funding while a property was empty.

2.28 Uncertainties about advisors and contractors Respondents recommended investment in the ESSac network to support householders through the NRP. Organisations in the 'other' group saw local authorities as trusted agents, who would reduce concern about employing disreputable builders, and since they have a strategic role in improving housing, were well placed to identify local needs, to build on existing relationships and services already provided, and to operate a system where householders should have to opt out rather than opt into upgrading.

2.29 Private sector organisations and local authorities highlighted the need to use properly qualified and accredited tradespeople: industry accreditation schemes included the green energy installation certification schemes administered by the Construction Licensing Executive. There were also local authority Trusted Trader schemes, with local businesses committing to trading fairly and a Code of Practice. Others pointed to independent energy surveys and to products and installations covered by a recognised warranty provider.

2.30 Conservation areas There were a few calls, including some non-standard campaign responses, for clarity on priorities for Scottish Government conservation objectives, relaxed planning constraints, and for planners to agree standardised solutions for listed buildings and conservation areas that would not need planning permission.

Q4 Given Scotland's diverse range of housing, what support is needed to enable people to get energy efficiency measures installed?

2.31 Most respondents answered question 4 (87%). The key issues, supported by over a third of the respondents to Q4, were: local delivery organisations providing advice and support, with strong support for ESSacs; financial incentives and grants; and extensive communication, information resources, and demonstration projects. Recommendations often repeated responses to question 3. The only new comments concerned measures for traditional constructions, and guidance to ensure that improvements achieve their desired objectives, such as adequate insulation before installing heat pumps.

2.32 'Other' group respondents called for support to be extended to measures for traditional housing, particularly in conservation areas: shutters, slim line double glazing, high quality draught-proofing to traditional windows and doors; insulation to rooms-in-the-roof, partial lofts, and floors; and biomass in off-gas areas. One called for RdSAP to be improved to model extensions, rooms in the roof, and multiple heating systems which were increasingly common in off-gas properties. Another respondent cited an example where an air source heat pump had been installed without adequate building insulation, highlighting the need for competent analysis and advice to ensure that programmes have the desired outcome, including reduced fuel bills.

Q5 a) What specific issues need to be addressed in respect of improving energy efficiency in rural areas, particularly more remote or island areas? b) How should these be addressed?

2.33 Most respondents answered questions 5a (70%) and 5b (70%). Some stated that they did not feel it appropriate to give opinions on rural issues. Also, some non-standard campaign responses addressed the particular problems of rural areas.

2.34 The key issues identified were: the rural premium, energy supply and high energy costs, the nature of the building stock and building condition, difficulties in accessing programmes of support, and low incomes.

2.35 Nearly half of respondents identified the issues of the rural premium – higher costs due to access and low density and the concomitant unwillingness of companies to work in rural areas, plus relatively poor value for money in terms of the emissions reductions that could be achieved. Distance from supply chains meant additional transportation costs, difficulties in achieving economies of scale, and more time to complete works. A private sector respondent noted that the cost of servicing rural and hard-to-treat areas may be disproportionate to the carbon and consumer energy saving realised. Another noted that many homes were easy to improve, but their location was a barrier to cost effectiveness.

2.36 Over a third identified energy supply and high energy costs for areas off the gas grid, and dependent on electricity, oil, or LPG^[3] including non-standard campaign respondents. An RSL highlighted the difficulty of improving homes with wet electric heating systems and called for additional funding to improve properties off the gas grid. Also, it did not consider practicable any improvement that would cause significant disruption to tenants. The cost of domestic fuel in island areas was crucial to addressing the problem and one respondent advised that if prices kept rising, the benefit of any works done would be negated and families would remain in fuel poverty. Comments about woody biomass included both concerns about a lack of affordable biomass, and the observation that many households used firewood to avoid fuel poverty. One queried the treatment of firewood in SAP calculations and pointed out that installing central heating for rural, fuel poor households who under-heat their homes, could increase their energy bills.

"I live in an area that depends on oil for heating and apart from not helping the emissions problem I'm sure you are well aware how volatile the price of that can be - please don't ignore us because we live outside of towns." – Individual campaign respondent

2.37 Over a third identified the nature of some of the building stock and building condition, with a high proportion of hard-to-treat (as well as hard-to-heat) properties. Respondents identified several issues of housing in rural areas: the expense of treating detached houses, the poor condition of properties due to climate, the high average age of many houses, and construction types including solid wall construction or cavity walls in exposed locations, and coomb ceilings that require intrusive or costly measures.

2.38 Nearly a quarter identified low income and difficulties in accessing programmes of support, even in areas of high fuel poverty, due to eligibility criteria that do not take account of rural densities. Homes below tolerable standard (BTS) were likely to be occupied by older people, single persons, those on low incomes and insecure or seasonal employment, or people relying on more than one source of part time employment. The use of multiple deprivation indices as a means of targeting grant support was seen to work against many rural areas and islands and there was concern that this was being repeated in the targeting of the Green Deal and ECO.

In the Highlands "a combination of low average incomes, a long heating season, limited access to mains gas and a high proportion of traditional stone-build houses give particularly intractable problems of fuel poverty" – Individual campaign response

2.39 Many addressed the design and delivery of schemes of support, calling for additional funding for rural areas, with obligations on utilities to support these areas, and learning from the experience of earlier and current schemes. Respondents recommended funding options: for specific grant incentives targeting areas off the gas grid; for subsidy to be a percentage of installation costs rather than a flat rate; and for access to the range of local, national and European resources. Utilities should be required to help improve remote and island areas, even though such locations may not provide the optimum economic return; one queried whether the Warm Homes Fund would target fuel poor rural households.

2.40 The submission from Highland Council had an appendix with detailed recommendations for delivery of improvements, including administrative processes, communications skills, processes to determine the appropriate solutions for traditionally built homes, non-standard properties and awkward cases, funding for pre-requisite improvements such as removal of asbestos, branding, use of locally based contractors, and understanding of the customer's experience and outcomes. Other respondents called for subsidy to upskill local contractors in installation and maintenance, particularly to minimise delay in servicing new technologies, and for appropriate training for surveyors and installers, both in technical skills and customer service. There were also calls for improvement programmes to maximise the involvement of local construction and supply businesses, including business development to access contracts, and procurement systems to effect economies of scale.

2.41 Some respondents called for the use of renewable energy, particularly community systems. Respondents gave the example of remote communities, such as Eigg, with their own energy mini grids, and residents educated about energy budgeting to smooth out demand. Community based grants were needed for rural heating systems in villages. Other suggestions were the use of alternatives to LPG such as biofuel by-products from waste, small scale biomass, or micro hydro – but combined with a fabric first approach. One respondent proposed reduced energy costs for communities near large wind turbine sites. However, a few respondents pointed to difficulties with some domestic technologies and running costs, particularly the poor performance of heat pumps resulting in under heated homes and increased fuel bills, and the fact that most renewable technologies require regular maintenance and would degrade over time.

2.42 Respondents again called for technical guidance on solutions for hard-to-treat properties, and for a fabric first approach, including case studies, as in preceding questions. Some RSLs commented on the need to share information between housing providers about the success or failure of specific products for various house types, and the practicality of solutions with regard to tenant disruption and the need to decant into alternative accommodation.

Q6 Taking into account the models and funding sources outlined in section 1.20-1.37, what role might local authorities and other agencies play in bringing about a step change in retrofitting Scotland's housing?

2.43 Most respondents answered question 6 (87%).

2.44 All but one^[4] of the local authority group responded. They advocated a central role for local authorities in managing energy efficiency improvements across tenures, with only two exceptions who mentioned less central roles. A few of the local authorities advocated a regional partnership, or partnership with other organisations, and a facilitating rather than delivery role. Many wished to build on the success of the UHIS, although some noted that delivering solid wall insulation under the NRP would be more resource intensive.

2.45 Few offered opinions on the funding options set out in the consultation, but there was concern about the challenge funding model and more support for the Scottish facilitated funding model than the formula-based model. However these findings were based on very few responses.

2.46 Only eight respondents commented on the Homes for Scotland proposal whereby builders of new homes would contribute to a fund for the improvement of existing homes in lieu of even higher building standards. Reaction was mixed and polarised – it ranged from the view of one 'other' group organisation that action on the existing housing stock should not be at the expense of progress towards zero carbon new build to another which saw the proposal as "a cost-effective way to achieve the vision of the Sustainable Housing Strategy, without driving up the costs of new homes at a time of financial pressure on house-builders and buyers."

Q7 What role should the Scottish Government play in a National Retrofit Programme?

2.47 Most respondents answered question 7 (86%) and identified various roles for Scottish Government.

2.48 Almost two thirds identified the key role as maximising resource and providing funding for the programme, including negotiation of Scotland's share of UK funding; identification of a budget to support the programme, with funding to support local authorities and Energy Saving Scotland advice centres, research and development into technical solutions and training.

2.49 Nearly as many identified the role of setting standards and designing the programme, reviewing lessons from delivery of UHIS and EAP to provide both area based schemes and support to vulnerable households in fuel poverty; consulting with industry; removing red tape; maximising community benefits, and procurement efficiencies.

2.50 Over a third suggested facilitation and oversight, co-ordinating the work of local authorities and other agencies, and monitoring progress of delivery. Over a third called on Scottish Government to manage information, including promoting awareness of the scheme, disseminating information on technical options, and supporting systems to identify need and track progress.

Q8 Whatrole could the devolution of additional powers play in achieving more retrofit?

2.51 The consultation does not suggest what the potential impacts for the devolution of additional powers or discussion of reserved matters might be. Perhaps as a consequence, less than half the respondents answered question 8 (47%), with particularly low response rates in the professional and 'other' groups. A few commented that without knowing what the devolved powers might be they could not respond.

2.52 Less than half of those answering question 8 identified tax powers and control of budgets as having most impact on achieving more retrofit. Some proposed a reduced rate of Value Added Tax to encourage repairs and maintenance work, but there was uncertainty about this following a European Commission ruling on the VAT directive. A few suggested the use of rebates under the forthcoming Land and Buildings Transaction Tax, in common with responses to several questions in the next section, on the role of standards.

2.53 A few pointed to fund-raising powers, the devolution of 'financial incentives,' and greater control of budget spending. Some suggested that new capital borrowing powers under the Scotland Bill could allow increased investment in the NRP, more flexibility and longer term planning. Opting out from the Green Deal might allow Scotland to deliver a more joined up programme, with better response to local circumstances. Others queried whether the replacement for the Social Fund in Scotland might include measures to tackle fuel poverty, and whether devolution might allow Scottish Government to set welfare benefit levels.

2.54 However, the SFHA suggested that there was scope within the existing Scottish Budget, and through the Scottish Government's allocation of European Structural Funds, to move sufficient funds to energy efficiency in order to meet the targets on fuel poverty and climate change.

2.55 Three respondents identified opportunities concerning energy company obligations. Two argued that Scotland could demand a minimum percentage spend of ECO funding, and a third that FIT and RHI could be altered to promote greater uptake of micro generation in a Scottish context. However, two other respondents thought there could be no significant impact of devolution on regulation in the gas and electricity markets, or the price of energy, although one suggested that the Scottish Government might introduce powers to regulate the domestic oil, LPG and solid fuel distribution markets in Scotland.

Q9 What further action is needed to achieve the scale of change required to existing homes?

2.56 Most respondents answered question 9 (76%), with particularly high rates of response in the local authority and RSL groups. Many responses reiterated issues raised earlier and only a brief selection is included.

2.57 Nearly half of those who answered question 9 identified the need for improved information. This included: case studies, both for urban hard-to-treat flats with demonstration of before and after performance, and for rural homes, linking with small biomass, biofuels from waste and community district CHP; mainstreaming energy efficiency as part of home improvements, so that it was part and parcel of 'doing up the house;' a single brand to support householders and landlords for energy advice.

2.58 Nearly half called for incentives and grants for retrofit, for increased investment in new build, and for long term budget commitments. Funding should improve and up-skill labour capacity in Scotland.

"Scottish Government will not achieve the scale of change required without offering incentives to householders and there is a need to be flexible and transparent about what offers are made. Cost is important and householders will not consider measures that are too costly or where there is a fear that additional unknown costs will be added. Fixed price offers have proved successful..." – Local authority

2.59 Less than a third of respondents considered compulsion and targets. This issue is discussed more fully in the following section on standards. Others identified the need for local programmes, issues of training, accreditation, and procurement, removal of planning barriers; improving building condition; and establishment of a central register of building data.

Q10 How can we make sure a National Retrofit Programme maximises benefits to all consumers (for example, older people, those from ethnic minorities, those with long term illness or disability)?

2.60 Most respondents answered Q10 (78%), with many emphasising the need for partnerships with trusted intermediaries to promote the programme, ways to prioritise work for people in need, helping people in the private rented sector, reassurance, and for effective communications including one-stop shops.

2.61 Over two thirds of the respondents commented on the need for trusted engagement and delivery agents, working with partners to prioritise work for people in need, seeking to work with private sector landlords, and measures to provide reassurance. The NRP would need to draw on the skills, expertise and knowledge of trusted intermediaries and local champions to promote it within communities. Partners should be supported by funding of face to face advice, case studies of best practice, training, peer support networks, and ESSac Community Liaison Officers. Respondents suggested partnerships with health visitors, community nurses, care services, MacMillan nurses, social workers, Community Planning Partnerships, community interest groups, WRVS, cultural groups, groups engaging with ethnic minorities, private landlord forums, Neighbourhood Partnerships, schools, Age Scotland, housing associations, and energy suppliers. Local authorities should identify and prioritise need, working with occupational therapy services, NHS Boards, and representative groups for vulnerable people.

2.62 Local authorities should also check records of maintenance and repair programmes to identify property condition. Consumer assurance could be provided by a scheme of independent surveyors allied to approved contractors with appropriate skills to allay fears of shoddy workmanship and exploitation. One respondent also called for provision of independent financial advice. Several called for advice to single property private sector landlords:

"Many of these disadvantaged groups live in private rented accommodation where it can be very difficult to gain landlord permission for improvements. New initiatives should be taken to encourage landlords to improve their properties and the quality of life of tenants." – Local authority

2.63 Over a third called for communications and engagement campaigns, including presenting a long-term unified brand to consumers and advice agencies, with consistent messages. There needed to be an engagement campaign at community level, with local events supported by professional and voluntary bodies, including 'meet the installers' events, and information distributed by mobile libraries and ferry services as well as national media, local radio, local newspapers, community newsletters, and charity shops. The campaign should provide accessible information and advice in many languages and formats, including non-written. Some advised against over-reliance on online or telephone services alone because this disadvantages certain groups. Some respondents called for a one-stop shop approach with face to face energy advice plus benefits and utility tariff checks to boost income and reduce energy costs; and for funding for outreach work with home visits. Some called for practical measures to improve delivery for vulnerable households, including training for installers to provide extra levels of care and support. There were also broader amenity and life safety recommendations on related matters, perhaps beyond the immediate scope of the consultation – e.g. to require social housing to install showers to save water and energy; and for fire and safety measures for vulnerable people.

2.64 Over a third called for targeted financial support that would prioritise vulnerable people within area based schemes. There should also be free or low cost measures for fuel poor regardless of location or tenure. Funding should target over-75s, and people with illness or disability. One respondent highlighted the need to extend help to incapacitated people not on Disability Living Allowance (DLA) or over 50 who were ineligible for Care and Repair. A few advocated free work for people where health was affected, irrespective of income. Some again called for enhanced ECO support for rural homes where improvements cost more, and for an incentive such as a council tax rebate. One respondent called for measures to be under-written so if they prove problematic people were assured they would be fixed. A private sector organisation called for prioritisation of work on a cost-benefit basis of energy or carbon savings.

General Comments on the National Retrofit Programme

2.65 Some organisations expressed strong support for the NRP outwith the questionnaire itself: The Scottish Building Federation highlighted the opportunities the NRP would offer to Scotland's construction industry, while noting that a huge increase in resources would be needed to achieve the Strategy's vision and objectives. Consumer Focus Scotland observed that minimum energy efficiency standards would be needed to encourage take-up of measures under the NRP, and welcomed the support that it would provide for consumers to help them meet new standards. SFHA welcomed area-based programmes under the NRP as the most cost effective way to improve the energy efficiency of existing homes, while at the same time calling for a safety net for tenants or owners in fuel poverty who live outwith designated NRP areas. The Chartered Institute of Housing welcomed the plans for an NRP, while highlighting the critical need for financial support for low income households and the need for links between minimum standards and financial market transformation to make energy efficiency something which was valued by buyers and sellers.