As stated in the consultation guidance notes, the Enhanced Heating Regimes (EHR) will be a key part of the methodology by which the Scottish Government defines fuel poverty. What is less clear, however, is how the EHR will be used to determine who is eligible for support under the new Fuel Poverty Strategy and accompanying delivery programmes, and how the EHR will interact with other proxies for identifying the fuel poor. Determining the eligibility criteria for the new EHR is important to ensure that the Strategy better targets resources and strengthens support for those in fuel poverty and extreme fuel poverty.
We support the inclusion of the three EHR scenarios to capture all the possible variants between temperature and duration of heating, as laid down in the Fuel Poverty Bill. While other assessments such as an EPC rating can determine to what extent energy efficiency contributes to fuel poverty, the EHR considers the importance of heat for comfort, health and wellbeing for those in vulnerable situations. There may be some householders who live in well-insulated, energy efficient properties yet still suffer fuel poverty because of their higher-than-average heating demand. It is these households that we need to ensure are supported.
We understand that there is a balance to be struck in determining the eligibility criteria for an EHR; if the criteria are too broad it risks spreading precious budgetary resources too thinly across the populace and potentially mis-directing support, yet too narrow and it risks missing out vulnerable people who need it most to avoid cold related ill-health and financial detriment.