Stakeholder Priorities
Thank you for your invitation to submit views on priorities within the Committee’s remit.
Undoubtedly, one of the biggest challenges the Scottish Parliament will face over this session will be how we make progress towards becoming a net zero nation by 2045. Decisions made in this session will determine whether or not we meet the 2030 target of reducing carbon emissions by 75%, the extent to which we tackle fuel poverty and how well we focus our recovery on building a green economy.
Cross-Committee Responsibility for Climate Change and Fuel Poverty
Although responsibility for climate change sits predominantly with the Committee for Net Zero, Energy and Transport, we believe that the size of the remit of that committee, alongside the cross-cutting nature of the strategies to meet climate change and fuel poverty targets, requires that the Local Government, Housing and Planning (LGHP) Committee must be able to consider the housing related issues that will be at the heart of the Scottish Government’s net zero plans. Effective housing policy is central to meeting climate change and fuel poverty targets, as well as offering huge potential to support a green recovery and help build more resilient communities. We believe that the LGHP Committee must have oversight of the significant housing related policy, regulatory and financial approaches that will be developed over the coming session.
Fuel Poverty
The Scottish Government’s Draft Heat in Buildings Strategy includes a firm commitment that the transition to zero carbon heating must not exacerbate fuel poverty. According to the latest published data, 24.6% (613,000) of households in Scotland are living in fuel poverty. 12.4% (311,000) of households are living in
extreme fuel poverty.
1 Source: Scottish House Condition Survey: Key Findings 2019
It is widely believed that there are four drivers of fuel poverty:
• Poor energy efficiency of the home;
• Low disposable income;
• High price of domestic fuel; and
• How energy is used within the home.
2
A new fuel poverty strategy is due to be published in 2021 which must encompass all four drivers of fuel poverty. Whilst the Heat in Buildings Strategy, including fuel poverty, falls within the remit of the Cabinet Secretary for Net Zero, Energy and Climate Change, and accordingly, the NETZET Committee, we believe that the LGHP committee is well placed to take a holistic view on this issue, and therefore should have a role in scrutinising the implementation of the Fuel Poverty (Targets, Definitions and Strategy) (Scotland) Act 2019 and the forthcoming Fuel Poverty Strategy.
Housing to 2040 – Affordable Warmth and Housing Quality
A core part of the remit of this Committee is housing and housing strategy and the Committee has a critical role to play in considering the policy framework that is being developed to deliver the Scottish Government’s recently published Housing to 2040 strategy.
Part 3 of Housing to 2040 focuses on “Affordable warmth and zero emissions homes” and Part 4 focuses on “Improving the quality of all homes”.
Many of the approaches to deliver the affordable warmth aims are contained within the Draft Heat in Buildings Strategy, which again is predominantly within the remit of the NETZET Committee. However, there is a high level of overlap with the Housing to 2040 commitment to introduce a new cross tenure Housing Standard, alongside targeted support packages for owners who need help improving their homes and an enforcement framework.
The Scottish Government intends to publish the final Heat in Buildings Strategy later in 2021 and, given the need for the new Housing Standard to be aligned to the proposed regulatory standards for energy efficiency and heating, we believe that it is essential that the LGHP Committee considers housing quality/standards issues in the round and scrutinises the Heat in Buildings Strategy as it impacts on local government, registered social landlords, homeowners (including private landlords) and tenants.
Tenements
Both Housing to 2040 and the Draft Heat in Buildings Strategy recognise the challenges of improving quality and energy efficiency in tenements. Housing to 2040 includes a commitment to “act on the recommendations of the Parliamentary Working Group on Tenement Maintenance” and we believe the that the LGHP Committee should consider whether the Scottish Government is making satisfactory progress to ensure that people who live in tenements are not left behind in the transition to net zero.
The role of Planning in improving homes
Planning policy has a significant role to play in facilitating the transition to net zero and improving Scotland’s existing housing stock. The National Planning Framework (NPF4) has been delayed due to the pandemic, however the NPF4 Position Statement published in November 2020 indicated that Permitted Development Rights should be extended to enable low and zero carbon refurbishments, and restrictions on energy efficiency and zero emissions heat technologies in listed buildings and conservation areas should be lifted, while still respecting the special characteristics of historic buildings.
We believe that the Committee should consider the extent to which NPF4 facilitates energy efficiency and heat transition. 3
The role of local and national government in delivery
The Existing Homes Alliance believes that, to meet our climate change and fuel poverty targets, we need strong leadership, at a national and a local level. The role of local authorities is critical in our transition to net zero, in terms of providing strategic direction, delivery of area-based schemes, developing proposals for heat networks and enforcing new regulations.
Local Heat and Energy Efficiency Strategies (LHEES) will have a central role to play in shaping our transition to net zero and we recommend that the LGHP Committee considers local authorities’ capacity to develop and implement LHEES and the extent to which current budget allocations enable them to fulfil these obligations, alongside delivery of area-based schemes, developing proposals for heat networks and new enforcement requirements.
The SNP manifesto included a commitment to “re-focus our efforts on a new dedicated national public energy agency” to co-ordinate and accelerate delivery of heat and energy efficiency work, inform and educate the public…, provide expert advice to national and local government, and work with public, private and third sector partners to deliver this transformative national project.”
This is welcome and we believe that the LGHP Committee should consider the role and remit of the new agency, its relationship with local government, and how it can best support a just transition to net zero.
Housing and the green economy
Investing in energy efficiency and zero carbon heating for Scotland’s homes not only cuts emissions and tackles fuel poverty, but it also provides a huge opportunity to create and sustain thousands of green jobs across Scotland.
We believe that the current national fuel poverty programmes – Warmer Homes Scotland and the Area-Based Schemes provide a solid base which could quickly be scaled up. These are models that work well but could do so much more to transform Scotland’s homes and tackle fuel poverty.
We believe that the LGHP Committee should consider whether the Scottish Budget is taking advantage of the opportunities presented by these programmes and to what extent they could be scaled up to cut emissions, reduce fuel poverty and contribute to a green economy.
We believe that this parliamentary session will require a great deal of cross committee working to ensure that the Scottish Government’s approaches are appropriate, both to meet the scale of the challenges, but also to take advantage of the opportunities.
Thank you again for the opportunity to feed into your considerations and we would be more than happy to provide additional evidence as required throughout the parliamentary session.