Shelter Scotland campaigns for decent housing for all in Scotland. An energy efficient housing stock is vital not only to reduce greenhouse gas emissions in line with the Climate Change (Scotland) Act 2009, but also to help tackle fuel poverty and to ensure that Scottish housing is warm and comfortable for all households.

Shelter considers that there are 4 key principles that should inform policy in relation to promoting energy efficiency in the housing stock:

• As far as practical, Scottish housing should make a proportionate contribution to the national greenhouse gas reduction targets.
• Financial support should be targeted at vulnerable and disadvantaged households in fuel poverty who, in the absence of substantial changes in energy efficiency, may need to increase their fuel consumption to achieve satisfactory levels of comfort and warmth.
• Resources for new building in the social rented sector should not be diverted to help private owners and landlords who are well able to fund the necessary improvements from their own resources.
• The use of regulation to achieve energy efficiency targets needs to be implemented with considerable care to ensure public support and taking into account the wide variety of types of housing found in Scotland.

As our specific interest is in energy efficiency in the residential sector, we have focussed on the questions in chapters 6 and 7 of the consultation paper taking into account the partial regulatory impact assessments set out in Annex A. We have used the question numbering set out in Annexe B.