Publications

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.

196,000 people in Scotland are not connected to the public water supply, and rely on a private supply for drinking water. Water quality in private supplies can be poor. Those responsible for the supply must cover the full burden and cost of ensuring that they are treated, monitored, and maintained correctly. The majority of private supplies are rural or remote rural.

Citizens Advice Scotland is today publishing a new guide for how organisations can take the public with them when planning new building developments or other activities. Based on joint research carried out with Scottish Water and the Customer Forum, the CAS report captures the components of best practice community engagement, which we believe should be at the centre of organisations’ community engagement policy and practice.

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.

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. 

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.

The Markets and Systems policy team at Citizens Advice Scotland puts consumers at the heart of policy and regulation in the energy, post and water sectors in Scotland. We work with governments, regulators and business to put consumers first, designing policy and practice around their needs.

Our advocacy work is evidence led and we use a combination of independent research and evidence from the Citizens Advice Network in Scotland to speak up for consumers.  

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.