Publications

Citizens Advice Scotland responded to the Ofgem consultation on prepayment meters. 

CAS is enthusiastic about the potential for the devolution of winter heating benefits to drive a meaningful improvement in the rates and lived experience of fuel poverty in Scotland. Done well, devolution of Cold Weather Payments (CWPs) and the Winter Fuel Payment (WFP), taken alongside the assistance provided by the Warm Home Discount (WHD) scheme, the Scottish Government’s fuel poverty and energy efficiency programmes, and additional support for vulnerable households such as the Child Winter Heating Assistance, could create a coherent package of measures which work together more effectively to reduce inequality and improve the health and wellbeing of citizens most vulnerable to the effects of living in a cold home.

We agree that reforms to the existing CWP scheme could deliver greater consumer benefits than the scheme that currently exists. However, we do not agree that the Scottish Government’s proposals for Low Income Winter Heating Assistance (LIWHA) achieve this. Indeed, we are concerned that for many consumers, LIWHA will often make fuel poverty, and in particular extreme fuel poverty, worse. Evidence also strongly suggests that in a cold winter, LIWHA is likely to prove prejudicial to the health of many vulnerable low income households. We are extremely concerned about the negative consumer outcomes this will deliver, including the impact on winter mortality. CAS cannot support a policy that holds significant potential to increase inequality and endanger the health and wellbeing of consumers in Scotland, and as a result we cannot support the Scottish Government’s proposals for LIWHA in their current form. We are however mindful of the tight deadlines to which the Scottish Government is working to deliver the devolution of CWPs before the end of 2022. We therefore propose a practical series of evidence-led actions that we believe would safely deliver a Minimum Viable Product to the required timeframes which significantly improves on the current CWP scheme and to which future improvements can be made as time and resources allow

In May 2019, The Scottish Government committed to establishing an independent Energy Consumers Commission (ECC) to enhance the voice of consumers who reside in Scotland within the energy market. The Commission was formed in July 2020 consisting of representatives with a wealth of experience in national consumer advocacy and advice bodies, academia and local groups serving energy consumers in their communities.

The Priority Services Register (PSR) is a record held by energy suppliers and network operators which enables them to provide additional support services to consumers in vulnerable situations.

Ofgem practices principles-based regulation in relation to vulnerability, and although suppliers and network operators broadly determine who can benefit from their PSRs, a level of consistency is ensured across the industry by a common framework of needs codes and vulnerability flags.

Previous research has found that the strength and depth of priority services, and those they seek to support, varies both between different PSR holders, and across different parts of Great Britain.

This briefing, based on research commissioned from Changeworks, examines how experiences of the PSR vary in Scotland in the context of the COVID-19 pandemic and the early stages of the transition to low carbon heating and electric vehicles. It also summarises the Commission’s recommendations on how the services offered and/or the range of vulnerabilities provided for under PSRs and other energy industry vulnerability initiatives can be improved.

The Warm Home Discount scheme provides important funding for the short-term relief of fuel poverty. However, a combination of research and evidence from the Citizens Advice network in Scotland has previously found that while the Warm Home Discount is seen as vital by those who receive it, it is not adequately reaching those who need it most. This consultation proposes a number of potentially positive changes to the operation of the Warm Home Discount scheme, alongside a 4-year extension to March 2026.

Scotland’s Citizens Advice network empowers people in every corner of Scotland through our local bureaux and national services by providing free, confidential, and independent advice. We use peoples’ real-life experiences to influence policy and drive positive change. We are on the side of people in Scotland who need help, and we change lives for the better.

Our 2021/22 Impact work plan outlines the areas where we will be working to secure changes on behalf of our network’s clients. It has been drawn together following extensive analysis of advice data and consultative workshops with representatives from the network to identify significant trends and areas of concern.

Citizens Advice Scotland welcomes this consultation, which reflects the pace and scope of Scotland’s climate ambitions. We are pleased that the Scottish Government has proposed a principle-based, people-centred approach. 

It is essential that the outcomes of this standard reflect the complex heating, cooling, and ventilation needs of Scotland’s housing stock, and widens accessibility to truly affordable, highly efficient housing for low income and fuel poor households. Developers should be encouraged to follow the best practices of community engagement and ethical business practice so that the full potential of the buildings covered by this standard is realised. To aid developers in making future proof decisions, clear, thorough, and accessible guidance should be issued alongside this standard.