You are here

Publications

  1. Creating a framework for robust consumer protection in the energy efficiency and renewable retrofit sector
    Publication date:
    September 2020
    Spotlight:
  2. Michael O'Brien
    Publication date:
    August 2020

    Scotland has redefined fuel poverty and set targets towards its eradication by 2040. The Warm Home Discount scheme exists, by definition, to support fuel poor households and fuel poverty risk groups. This report examines the effectiveness of Warm Home Discount in the context of the new fuel poverty definition in Scotland. 

     'Mind the Fuel Poverty Gap' sets the policy context around the key issues, provides insight into research conducted by Changeworks for CAS, and makes a series of recommendations. 

    Spotlight:
  3. Emily Rice
    Publication date:
    July 2020

    Scotland has set some of the most determined climate goals in the world, and home energy efficiency has a large role to play in Scotland’s transition to a low or no carbon society.

    Spotlight:
  4. Scottish Commission on Social Security consultation
    Rob Gowans and Alastair Wilcox
    Publication date:
    June 2020

    Citizens Advice Scotland welcomes the moves to extend Winter Heating Assistance in the challenging context of COVID19 which has resulted in delays to wider measures on disability assistance.  We recommend the draft regulations are amended to better meet the policy intention and add clarity in a number of areas.

  5. Aoife Deery
    Publication date:
    June 2020

    Citizens Advice Scotland welcomes the opportunity to respond to this consultation. Above all, we want to ensure that a market framework improves outcomes for heat network consumers. We have been calling for heat network consumers to have access to the same rights and services afforded to customers of the regulated energy market for several years.

    Spotlight:
  6. Aoife Deery
    Publication date:
    May 2020

    CAS welcomes the opportunity to respond to this consultation.

    We want to ensure that the Heat Networks (Scotland) Bill delivers the best possible outcomes for heat network consumers, and gives parity with the rights and services afforded to consumers of the regulated energy market. Unfortunately we are aware of instances where heat network consumers have been disadvantaged due to the current unregulated nature of heat networks and are keen that this Bill works towards improving this as much as possible.

    Spotlight:
  7. Markets Team
    Publication date:
    April 2020

    CAS welcomes the ambition of the Scottish Government to bring every owner-occupied home in Scotland to Energy Performance Certificate (EPC) band C. This will not only increase the energy efficiency of Scotland’s housing stock, but also reduce carbon emissions and alleviate fuel poverty. We believe a warm, dry, energy efficient home that is affordable to heat should be the standard in Scotland, not a privilege.

    Spotlight:
  8. Publication date:
    February 2020

    Fairer pricing, clear and accurate billing and better support for people in vulnerable situations are at the heart of Citizen Advice Scotland’s (CAS) priorities for the energy market in Scotland which are summarised in this report. 

    With the retail market facing potential changes in the coming years, with OVO energy’s recent takeover of SSE retail energy business, as well as the Scottish Government’s proposal for a Public Energy Company, the charity has published a report on priorities for customers.

    This report draws upon evidence and insights from our frontline advisers in Citizens Advice Bureaux (CABs) across Scotland and the Extra Help Unit (EHU). It highlights cases from our CABs in six thematic areas which are crucial to consumers.

    CAS six key consumer priorities are: 

    • Fair pricing and debt support; so customers aren't shocked by sudden increases in costs and the ability to pay is central to any debt repayment scheme.
    • Ease of contact; so customers aren’t left in the dark or hanging on the phone about their service or bills
    • Clear and accurate billing; to allow customers to understand how charges have been calculated, and to stop people accruing debt through no fault of their own
    • Easy access to the Warm Home Discount; to help more people with the cost of energy
    • Better support for vulnerable consumers; particularly accurate meter reads to prevent bill shocks
    • Offering choice for consumers on restricted electricity meters; to challenge fuel poverty for consumers off the gas grid

    The report also summarises a review undertaken for CAS around consumer engagement in the energy market in Scotland and makes a number of recommendations on how fuel poor households may be supported. This review is available on request. 

    Spotlight:
  9. 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. 

    Spotlight:
  10. CAS
    Publication date:
    February 2020
    Spotlight:
  11. 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.

    Spotlight:
  12. 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).

    Spotlight:
  13. 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.  

    Spotlight:
  14. 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.

    Spotlight:
  15. 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. 

    Spotlight:
  16. 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.
    Spotlight:
  17. Alastair Wilcox
    Publication date:
    November 2019

    Citizens Advice Scotland (CAS) believes it is more important to get the smart meter rollout right than it is for it to be rushed through to arbitrary deadlines, and we have long been concerned that the 2020 smart meter deadline was so unrealistic that it risked having a negative effect on consumers. In June 2016 we therefore published a report that called for the smart meter rollout to adopt an interim target of 80% smart meter coverage by the end of 2020, with 100% coverage achieved no later than the end of 2025. We reiterated this call in August 2018, and so we welcomed the UK Government’s September 2019 announcement that the smart meter rollout is to be extended to the end of 2024.

    This new-found pragmatism provides an opportunity for a review of the targets, incentives and penalties to which energy suppliers will be exposed as the smart meter rollout progresses over the next 5 years. However, it must also be acknowledged that there remain multiple technical barriers to the universal rollout of smart meters, particularly in remote rural areas and for many Scottish households that use traditional electric storage heaters as the primary form of space heating.

    These constraints lead CAS to be concerned that consumers reliant on electric heating in Scotland will be among the very last in GB to benefit from the smart meter rollout. Indeed, under current proposals we believe that it would be possible for electricity suppliers to comfortably exceed the proposed post-2020 smart meter targets without a single Scottish consumer with traditional electric heating having benefited from the rollout. This risks placing the costs of maintaining the traditional meter network onto a relatively small customer base, increasing prices for a group of consumers where a majority (52%) already struggle to afford to heat their homes to an acceptable standard.

    CAS does not underestimate the significant challenges required to overcome these issues, but we are equally clear that the smart meter policy framework and the regulation of the retail energy market post-2020 must not unfairly burden consumers with additional costs they have no opportunity to avoid. We therefore believe that there may be a need to provide short-term protection for consumers whose ability to access the benefits of smart meters is restricted by the industry's readiness to provide them with suitable metering equipment. We also consider that suppliers could be better encouraged to deliver a market-wide smart meter rollout in all areas of GB if the proposed minimum coverage level were to apply separately in each electricity distribution network area.

    While CAS supports proposals to move away from the “all reasonable steps” obligation that currently governs suppliers’ smart meter engagement programs, we are also cautious about the impact of holding suppliers to binding, linear annual targets given the technical barriers referred to above. The Citizens Advice network in Scotland already hears the concerns of consumers who have felt pressured into accepting a smart meter by their energy supplier, and even of instances where attempts to install smart meters have been made by domestic energy supply licence holders that are not the registered supplier at the property concerned. This suggests that while the imposition of installation targets backed by financial penalties for non-compliance may be driving the pace of the smart meter rollout, such targets may adversely impact consumers’ experience of smart meter installation and could jeopardise levels of engagement with the planned transition to a smarter energy future. We believe that suppliers may already be suitably incentivised to encourage their customers to embrace smart meters, and we therefore urge Ofgem to place its post-2020 focus on the enforcement of a high quality customer journey throughout the energy transition.

  18. 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.

    Spotlight:
  19. 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.
    Spotlight:
  20. 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

    Spotlight:

Pages