Summary of key points from consultation response:
- We welcome the commitment to eradicate fuel poverty, but regret there is no target date.
- The sub-targets are hugely unambitious – they propose to reduce fuel poverty levels from 27% today to 10% by 2040. This averages out at a reduction of less than 1% a year – we can and must do far better.
- We welcome the commitment to remove poor energy performance as a driver of fuel poverty, but the targets are vague and lack ambition. We suggest as a starting point that a target of EPC band C is set (unless technically not feasible) with provision to rise to EPC band B.
- The strategy is lacking in new policies, programmes and resources that will provide the step-change required to eradicate fuel poverty.
- The suggested scope of the Warm Homes Bill is too narrow. The Warm Homes Bill is a rare opportunity to propose legislative measures that will ensure the fuel poverty target is addressed and support the achievement of warm, affordable and low carbon homes for everyone in Scotland so no one is at risk of being in fuel poverty.
- We broadly support the new definition of fuel poverty, however we believe income thresholds should be adjusted upwards for households living in remote and rural areas due to the higher costs of heating properties.
- The new fuel poverty strategy demands cross-portfolio support and therefore should be led by a cross-ministerial committee. The Fuel Poverty Advisory Panel should be established in statute, to provide an advisory and scrutiny role, with a requirement to report to ministers and Parliament.