Winter Heating Payment (Low Income) (Scotland): island communities impact assessment

Consultation

37. The purpose of the Consultation on LIWHA (now WHP) and associated stakeholder engagement at the end of 2021 and the beginning of 2022 was to gather views on the key eligibility criteria and the proposed payment format, and to identify any unintended consequences of introducing the new payment including the impact of the new benefit on eligible clients living within island communities. The consultation analysis and responses have now been published.

38. The public consultation^[21] took place between 1 December 2021 and 25 February 2022. It provided an overview of the new payment's aim, its key eligibility criteria and its format. It set out how we intend to deliver this new benefit through Social Security Scotland to provide help towards meeting heating costs in winter. The consultation asked specific questions on whether the policy intention will best meet the needs of those it aims to help including whether the requirement for a period of cold weather to trigger a payment should be removed, whether different qualifying benefits should confer eligibility and whether those receiving such benefits should be identified during an annual qualifying week. We also asked about the value, format and timing of the payment itself. A report^[22] summarising the independent analysis of the 119 consultation responses has been published on the Scottish Government website.

39. As part of this engagement process the Scottish Government also ran an extended workshop with a wide range of organisations representing various sectors.

40. The responses to the consultation provided us with a range of proposed changes. In general respondents agreed with the removal of weather dependence but want the value of the payment to be higher. They also wanted to retain some of the current responsiveness of CWP to additional need in some circumstances, or at least to provide flexibility throughout the winter period either through multiple assessments of eligibility and/or multiple or additional payments.

41. At the same time we asked members of our Social Security Experience Panels for their views on the key policy options for this new benefit. In total, 288 members chose to complete our survey exploring this topic^[23]. Of those Panel members that responded;

• 82% agreed with the plan to replace Cold Weather Payment with a new benefit in Scotland;
• 87% agreed that a new benefit replacing Cold Weather Payment is a good way to help towards winter heating costs for people on low incomes;
• 90% agreed with the plan to remove the need for a 'cold spell', a component of the eligibility for Cold Weather Payment, in order for people to receive the new benefit.

42. In consulting on the proposed introduction of WHP the following question was specifically posed to respondents: "Please set out any information you wish to share on the impact of LIWHA on Island communities."

43. A total of 22 respondents provided an answer to this question key themes in these responses in regards to island-specific impacts were:

• Fuel Poverty
• Higher cost of fuel and energy supplies
• Lack of mains gas and the need to buy fuel in advance making the proposed timing for payment potentially problematic to island communities
• Poor energy efficiency

44. The main theme of stakeholder feedback focused on the widespread higher rates of fuel poverty within and across island communities. These include the comparatively higher cost of fuel and energy supplies and the poor energy efficiency of homes. Some respondents called for WHP to have a greater recognition and consideration of these challenges.

45. A small number of respondents felt island communities could lose out under WHP if they had received multiple CWPs in previous years. However, a greater number (including numerous notable stakeholders) acknowledged how WHP 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.

46. A majority of the consultation respondents (52%) disagreed with the proposal to make the new payments in February each year. echoing the responses to our Experience Panel survey, Many who disagreed felt a payment date in February is too late, and that recipients need help earlier in the winter to cover heating costs when cold weather first arrives. Key stakeholders raised issues with regards to island recipients in particular who were more likely to require unregulated fuels (oil or off-grid gas) who pay for fuel in advance, and were likely to be disadvantaged by a February payment.

47. Commencing payments in February 2023 will provide Social Security Scotland with a small window of time in which to manage any issues arising from the extension of Scottish Child Payment (SCP) and to prepare staff and systems required for a smooth transition to WHP. We are therefore unable to bring forward the payment date for WHP for winter 2022/23. However, we have committed to explore the feasibility of bringing forward the payment date in future years.