Energy Efficient Scotland consultation: Shelter Scotland response

At Shelter Scotland we believe everyone is entitled to a safe, secure and affordable home – a home with poor energy efficiency presents a barrier to making this a reality.

Scotland is currently in a housing crisis and we need to invest in our existing housing stock to ensure it is sustainable and fit for purpose. This includes making sure that existing homes are affordable to heat. Improving the energy efficiency of Scotland’s homes not only has benefits for the economy and the climate, but it can reduce fuel bills helping to tackle poverty as well as having real impacts on the health and wellbeing of the householder. Everyone, regardless of their tenure, deserves a home which is affordable to heat and power.

We welcome the commitment to introduce minimum energy efficiency standards in the private sector as a means to tackle fuel poverty. There is strong evidence that private tenants in particular do not feel empowered to tackle high energy bills in their homes. Regulation, when accompanied with sufficient scrutiny, enforcement and support, is both necessary and effective to improve energy efficiency in the private rented sector. Proactive monitoring and enforcement is key – the onus must not be placed solely on tenants as the conduit for change. Local authorities are likely to be best placed to take on the role of monitoring compliance, but they must be resourced to do this successfully.

We believe that simply ‘encouraging’ owner occupiers to improve the energy efficiency of their homes will be ineffective, and thereby regulation is necessary. However, this must be rolled out in a way which does not adversely affect poor owner occupiers who are already struggling. Energy efficiency improvements must not be pursued at the cost of making housing unaffordable for people. The focus must be on providing tailored support, including financial, and advice to households.

We welcome the proposal for higher targets for those who are living in fuel poverty to effectively remove energy efficiency as a driver for fuel poverty to focus resources on those most in need.

The provision of a sufficient communication and awareness raising plan and support (including financial) and handholding services for those who require it is essential to enable and ensure compliance with the proposed standards.