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Publications

  1. Publication date:
    February 2020

    CAS is publishing its Market Pulse report which has tracked the attitudes of consumers in Scotland over three years on a range of issues, finding 

    • 12 per cent of consumers rating their bills as unaffordable 
    • A fall in consumers using the traditional Big Six suppliers with consumers moving to smaller suppliers, often because of lower prices
    • A decrease in people using electricity to heat their homes and an increase in people using gas, laying out the challenges in the energy market as policy makers move to decarbonise heat and meet climate emissions targets
    • Almost half of consumers could qualify for extra support through the Priority Service Register – but only a quarter of consumers are actually enrolled. 

    The report is available for download below. The data is also available on request. 

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  2. CAS
    Publication date:
    February 2020
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  3. Aoife Deery
    Publication date:
    January 2020

    This is CAS' response to the Economy, Energy and Fair Work Committee's call for view on local energy and electric vehicles, as part of their Energy Inquiry. CAS acknowledges the central role that locally-owned energy and electric vehicles have to play in the transition to low carbon, in line with climate change targets but we emphasise the need to protect consumers in the transition from unaffordably high fuel bills, scams and lack of redress, especially those who are vulnerable to these changes.

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  4. Publication date:
    December 2019

    This briefing paper outlines the scale of the challenge to improve the energy performance of Scotland’s housing stock. It presents CAS’ estimate of how much it will cost to raise the energy performance of all homes in Scotland to at least an EPC C by 2040 (EPC B for social sector homes) in line with the Scottish Government’s target under Energy Efficient Scotland (EES).

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  5. Emma Ash
    Publication date:
    December 2019

    CAS welcomes the proposals for ECO3. The ECO scheme has helped deliver energy efficiency measures to vulnerable consumers in two other phases and we were pleased to see that BEIS and Ofgem are expanding consumer protections in this third iteration. In particular, we are pleased to see the incorporation of Trustmark into ECO3 to certify suppliers.  

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  6. Aoife Deery
    Publication date:
    December 2019

    Citizens Advice Scotland welcomes the opportunity to respond to this consultation. It is important that we recognise the role that all bodies and sectors have to play in achieving the new and ambitious climate change targets that were passed in the Climate Change Bill in September 2019. 


    It is, however, imperative that the Scottish Government properly supports public bodies to meet any new duties or roles. It is important that public bodies are able to continue to provide the same (or higher) standard of service to citizens without inadvertently or intentionally passing on the cost of achieving emissions reductions to the very citizens they are trying to support.

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  7. Aoife Deery
    Publication date:
    December 2019

    In this response, Citizens Advice Scotland lays out our support of the broad aims of the principles within the policy statement, but urge that much more must be done to strengthen consumer protection and ensure that communities are involved in the process in an inclusive, sustainable way that meets their needs. 

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  8. Alastair Wilcox
    Publication date:
    November 2019

    The energy regulator, Ofgem, publishes data on the consumption of gas and electricity by typical domestic consumers in GB. These Typical Domestic Consumption Values become industry standards and are used in a variety of different ways by energy suppliers, Price Comparison Websites, and the media. They have also become the benchmark annual consumption value used by Ofgem when it sets the prepayment and default tariff price caps.

    The Typical Domestic Consumption Values are based on the total domestic consumption of gas and electricity in GB over a 2-year period and are subject to biennial review.

    Having last been reviewed in 2017, Ofgem published its latest review of the Typical Domestic Consumption Values in an open letter to the energy industry and its stakeholders on 18 October 2019. In our response to this consultation, CAS observes that:

    • The value of the Typical Domestic Consumption Values to both consumers and suppliers is eroded by the use of GB averages. These hide very significant variations in typical annual domestic gas and electricity consumption between the different regions of GB. The Typical Domestic Consumption Values could therefore be made more relevant were they to be reported as a series of averages by electricity distribution network operator region. This would be consistent with how gas and electricity tariffs are priced in GB.
    • For properties with wet electric heating systems and/or supplied via multiple electricity meter points, the aggregation of all multi-rate electricity meter types results in a series of Typical Domestic Consumption Values that significantly misrepresents consumers’ total annual consumption and their peak:off-peak consumption split. With the possibility that the revised Typical Domestic Consumption Values will be integrated into the prepayment and default tariff price caps at a later date, there is a need for a discreet set of Typical Domestic Consumption Values and peak:off-peak consumption splits to be produced for a small number of related multi-rate electricity meter sub-profiles.
    • In addition to providing a more balanced and more locally representative price cap, these changes would also allow suppliers to provide consumers with better quality information on how their energy use compares with similar consumers, and better quality, more relevant advice on energy efficiency.
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  9. Alastair Wilcox
    Publication date:
    November 2019

    In June 2018 the energy regulator, Ofgem, consulted on proposals to introduce a series of new Guaranteed Standards of Performance on all domestic gas and electricity suppliers in GB. These were to place a service level requirement on suppliers to provide consumers with an automatic and pre-defined level of compensation when problems with switching supplier occur. Following feedback from the energy industry and its stakeholders, the first 3 of these new Guaranteed Standards of Performance for Switching were introduced on 1 May 2019.

    Following further work in this area, in September 2019 Ofgem consulted on the introduction of a second phase of the Guaranteed Standards of Performance for Switching. These would provide an automatic and pre-defined level of compensation to consumers where a change of supplier takes longer than 21 calendar days to complete; where a Final Bill is not issued by the losing supplier within 6 weeks of a switch; and where a consumer is erroneously transferred to a new supplier.

    CAS supports Ofgem’s objectives in its proposals to introduce additional Guaranteed Standards of Performance for Switching. However, in our response to this consultation we detail concerns with some of the proposals as they currently stand.

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  10. Alastair Wilcox
    Publication date:
    September 2019

    The Capacity Market arose from the UK Government’s Electricity Market Reform in 2014 and is designed to provide assurance that electricity supply can continue to meet demand where, for example, demand peaks coincide with periods of reduced renewable electricity generation.

    After being selected on price through a reverse auction process, Capacity Market participants undertake to reduce stress on the electricity system, either by bringing additional generating plant online or by deploying technologies that reduce electricity demand.

    To date, the Capacity Market auctions have favoured the provision of additional generating capacity, but this has often been reliant on relatively carbon-intensive forms of electricity generation which run counter to the Government’s ambitions on climate change. In July 2019, BEIS therefore consulted the energy industry and its stakeholders on how it might create new markets for energy efficiency in the electricity system such that it could become a viable alternative to the provision of additional generating capacity or electricity network reinforcement as a means of meeting peak demand.

    In our response to this consultation, CAS observes that:

    • The Capacity Market may yet prove not be an appropriate route by which to encourage investment in energy efficiency in the electricity market. However, the results of the Electricity Demand Reduction pilot do not definitively show that that energy efficiency is unable to compete in a Capacity Market, and more evidence is therefore needed before firm conclusions can be made.
    • The design of Capacity Market should be revised to allow the whole system costs and benefits of a given intervention to be considered when assessing the value of competing bids. This would help to address the competitive disadvantage that electricity demand reduction technologies such as demand side response, flexibility services and energy efficiency face in the Capacity Market, where the carbon intensity of a given intervention is currently not considered.
    • Reform of the Capacity Market should seek to take a whole system view of the whole life costs of a given intervention, where competing technologies such as energy efficiency and storage or flexibility services are also seen as complementary to one another.
    • The Energy Efficient Scotland program and the development of Local Heat and Energy Efficiency Strategies presents a sizeable opportunity to leverage Capacity Market funding for energy efficiency as a form of electricity demand reduction.
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  11. Aoife Deery
    Publication date:
    September 2019

    This is CAS’s response to the Call for Evidence on the Annual Energy Statement. We believe that while Scotland is likely to miss its target of achieving 11% of heat demand coming from renewables by 2020, there are actions the Scottish Government can take to ensure that it remains on course for achieving net zero by 2045, including;

    ›     Boosting public buy-in by stepping up practical and financial support for consumers

    ›     Driving technological innovation

    ›     Reducing the cost of renewables 

    These measures will help to address what CAS believes are the key risks and threats to achieving the 2045 target:

    ›     the initial cost of moving to renewable heat sources

    ›     the lack of public awareness and buy-in to the scale of the change needed

    ›     the quality of installations and access to redress when things go wrong

    ›     the lack of advice and guidance on how to properly use low carbon heating systems to best effect

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  12. Michael O'Brien
    Publication date:
    September 2019

    CAS welcomes Ofgem’s proposals to improve outcomes for consumers who experience self-disconnection and self-rationing. We have identified a number of priorities:

    • The standardisation of friendly credit dates and hours, where technically feasible
    • Improvements to emergency credit provision, which maintains flexibility, but allows for the maintenance of supply in a reasonable worst case scenario
    • The removal of barriers to discretionary credit, which maintains protection from excessive debt, but enhances consumer choice
    • Improvements in how suppliers communicate with their prepayment customers, for e.g. as regards the seasonal accrual of standing charges
    • The formalisation of Ofgem’s Ability to Pay principles in the licence code
    • Utilisation of the full suite of smart functionality, for e.g. suppliers switching meters to credit mode to maintain supply
    • Viable alternatives to prepayment, for e.g. clarification on the future of Third Party Deductions for energy (Fuel Direct)
    • The extension of fuel voucher schemes (fuel credits)
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  13. Emily Rice
    Publication date:
    September 2019

    This is CAS’s response to the Energy Efficiency (Private Rented Property) Regulations 2019. We welcome mandatory standards of energy efficiency in the private rented sector, provided that:

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  14. Alastair Wilcox
    Publication date:
    September 2019

    CAS has responded to BEIS’ Hydro Benefit Replacement Scheme (HBRS) and Common Tariff Obligation (CTO) consultation. Both are subject to a statutory 3-year review and are designed, respectively, to subsidise the cost of electricity distribution in the North of Scotland to avoid disproportionately higher distribution network costs for consumers vs. those charged in the rest of GB; and to prevent domestic suppliers from offering less favourable terms to remote rural and island communities in the North of Scotland than they do to comparable consumers located elsewhere within the North of Scotland electricity distribution network operator region.

    The HBRS imposes a levy on every electricity consumer in GB. For a typical dual fuel domestic consumer, this equates to about £1 per annum. To date, however, the additional costs of electricity distribution in the Shetland islands has been fully met by consumers in the North of Scotland. It is proposed that this will change and will instead be distributed throughout GB.

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  15. Jamie Stewart
    Publication date:
    August 2019

    CAS welcomes the opportunity to respond to the ENAs consultation. We think that the consultation raises issues that need to be quickly addressed as the electricity flexibility market develops.

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  16. Publication date:
    August 2019
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  17. Publication date:
    August 2019
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  18. Publication date:
    August 2019
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  19. June 2019
    Emma Grant McColm
    Publication date:
    June 2019

    This is CAS's response to the Scottish Government's consultation on the Energy Efficient Scotland programme.

    Energy Efficient Scotland (EES) is an ambitious Scottish Government programme which aims to improve the energy efficiency of Scotland’s housing stock over the next 20 years in a bid to reduce carbon emissions and fuel poverty. One of the proposed strands of the programme is the regulation of minimum standards of energy efficiency in both rented and owner occupied domestic properties. This would take the form of mandatory Energy Performance Certificate (EPC) standards to be achieved by respective sectors by a target date. This consultation seeks views on whether the Scottish Government should bring forward the date for all owner occupied homes to be EPC Band C or above by 2030, where technically feasible and cost effective. It also seeks views on the implementation of regulations for the private rented sector.

    The accompanying research report summarises the results of an omnibus survey that we commissioned in March 2019. The aim was to: better understand levels of awareness about EPCs; what homeowners are currently doing, if anything, to upgrade the energy efficiency of their homes; what would motivate homeowners to install more energy efficiency measures; and how Scottish homeowners and renters feel about potential regulation of energy efficiency.

  20. June 2019
    Jamie Stewart
    Publication date:
    June 2019

    This is CAS's response to the Scottish Government's consultation on the future of low carbon heat for off-gas buildings.

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