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3. MAIN FINDINGS AND ISSUES RAISED BY RESPONDENTS
3.1 The findings from the consultation are discussed under the eight chapter headings of the consultation document: Setting the Scene; Energy Use in Scotland; Changing Our Behaviour; Knowing What We Use; Changing Our Buildings; Improving Our Homes; Public Sector Leading By Example and Next Steps. As a significant volume of comments were received on matters specific to microgeneration, these are discussed under a separate heading.
Chapter 1: Setting the Scene
Decentralised energy
3.2 The topic that attracted the most interest in this chapter was decentralised or community energy, with 13 respondents offering comments. All of the respondents agreed on the benefits of decentralised energy, but felt that these were under-represented in this consultation. Five respondents highlighted the need for assessment to identify strategic direction, investment required and any barriers. A further four suggested incentives to encourage uptake, including thermal Renewables Obligation Certificates ( ROCs), permitted development rights, local taxation relief and a low interest loan scheme.
Setting targets
3.3 Of the 13 respondents, ten agreed that setting targets for energy efficiency and reductions in demand for energy could be effective provided they were based on a sound statistical base. They also felt that the targets should be achievable, supported both financially and in policies, flexible to allow for progress year on year, expressed in the form of carbon savings and reported on and debated in Parliament annually. However, one respondent commented that such targets should not be mandatory as this may lead to token actions and untrue figures being reported at the expense of actual improvements.
Renewable heat and transport
3.4 11 respondents felt that a Renewable Heat Strategy should have been aligned with this consultation document. A further three felt that transport should have been incorporated.
Chapter 2: Energy Use in Scotland
3.5 The three respondents who commented on this chapter all agreed that more and regular monitoring of energy use is crucial and that a sound statistical baseline should be established as soon as possible.
Chapter 3: Changing Our Behaviour
"One Stop Shop" advice
3.6 The issue that attracted the most interest across the consultation was the establishment of a series of 'one-stop-shop' advice centres for consumers. In total, 27 respondents commented with 25 in support of this approach and two who were concerned that it would diminish the resources available to the current network of Energy Efficiency Advice Centres ( EEACs).
3.7 Those who were supportive of a 'one-stop-shop' felt that it would reduce confusion amongst consumers and would provide easily accessible, consistent, clear and up to date advice.
3.8 These respondents felt that the new approach should build on the existing EEAC network and retain their local knowledge and contacts but that it should have clear indication that the initiative is being led by the Scottish Government. They also felt that the staff of the current EEACs would require further training if they are to deal with all sustainable energy issues.
3.9 The respondents also suggested specific services the advice centres should offer and these included: a clearing house for grants; advice and support on loans for householders and SME's and personal advisers who are fully trained to deal with all sustainable energy issues.
Raising awareness
3.10 A third of all respondents commented on the importance of awareness raising. They felt that sustained educational initiatives would strengthen understanding of the role of energy efficiency and microgeneration in reducing emissions and would help individuals and organisations understand and measure their impact on climate change. One respondent commented that the proposals for influencing consumer behaviour by awareness raising described in the consultation were insufficient.
Incentives
3.11 Five respondents agreed that measures such as tradable carbon allowances, council tax rebates, comparisons with other developed countries and community level carbon reduction targets would encourage consumers to reduce their energy demand.
Financial support for SMEs
3.12 The issue of financial support for SMEs i.e. Loan Action Scotland attracted comments from nine respondents all of whom agreed that this should not only continue, but should be expanded, retain a five year payback, include microgeneration and be more effectively marketed with face to face visits for smaller SMEs.
Review of energy efficiency and microgeneration support
3.13 Five respondents commented that they agreed on the need for a review of energy efficiency and microgeneration support in Scotland in order to identify any gaps or overlaps.
Prioritising energy efficiency
3.14 The majority of respondents agreed that energy efficiency and reducing demand for energy should be given priority over the installation of microgeneration technologies.
Chapter 4: Knowing What We Use
Metering and billing
3.15 All of the 18 respondents who commented on this chapter agreed that information provided to energy users should be transparent and unambiguous. One suggested that fuel bills should be clearer whilst the others felt this could be achieved through smart meters.
3.16 They suggested that a UK-wide roll out of smart meters should involve the utility suppliers at all stages and should be accompanied by a high profile awareness and education campaign with linked advice on savings and follow up support for action.
3.17 It was also suggested that meters should have meaningful displays for consumers and should be capable of being read and recalibrated remotely.
3.18 One respondent did not agree with the UK Government's white paper proposal that suppliers should provide customers with stand alone monitors that display information on electricity use prior to a roll out of two way smart meters which would allow both the consumer and supplier to monitor energy use. They felt that this would undermine the case for the long-term wide-scale and rapid roll out of full smart meters.
Chapter 5: Changing Our Buildings
Building standards
3.19 12 respondents commented on building standards with most welcoming the new standards introduced in May 2007. However four felt that Scotland was still behind other European countries and should be brought into line with, for example, those in Scandinavia.
3.20 Three respondents raised concerns about current standards not being met and non-compliance not being adequately policed. To address this, it was suggested that the new standards should be accompanied by an inspection and enforcement regime alongside ring-fenced funds for Local Authority building control officers. It was suggested by two other respondents that random air tightness testing or thermal imaging could assess compliance and by another, that builders as well as owners should be prosecuted if buildings don't comply.
3.21 It was suggested by two respondents that making the building industry aware in advance of higher building standards was necessary in order to give the market certainty and allow industry time to prepare.
Energy performance certificates
3.22 12 respondents were in favour of the Energy Performance Certificates ( EPCs) being introduced by the European Performance of Buildings Directive ( EPBD). They felt that the EPCs were a good starting point for future improvements and would increase the efficiency of buildings. However, it was felt that they should be clear, meaningful, include information on energy use and should be complimented by mandatory audits.
3.23 These respondents also felt that an awareness campaign was required to give value to a favourable rating, help users interpret the information on the EPC and signpost them to further help and advice.
3.24 Five respondents however, were not in favour of the introduction of EPCs, commenting that as they do not contain information on energy use, they will neither encourage improvement of building performance nor result in significant improvements in energy efficiency.
New buildings
3.25 On the issue of new buildings, six respondents felt that this was an opportunity for building regulations to incorporate energy efficiency and microgeneration in the design phase with one highlighting the need to tighten building controls to ensure these regulations are met. Another commented that microgeneration is far more effective when installed on a building which has effective energy efficiency technologies installed.
Existing building stock
3.26 Of greater concern though was the condition of existing building stock in Scotland and 11 respondents suggested this should be given higher priority and significantly more support than is currently received. It was suggested that financial measures such as a ring-fenced carbon reduction programme through the provision of grants, regulatory responsibility on energy suppliers and integration of existing funding schemes could draw in the additional resources required for the most expensive to treat buildings.
3.27 It was also suggested that new building regulations should tackle the existing building stock and that increased standards could be enforced when a property is refurbished.
Carbon neutral buildings
3.28 Seven respondents were supportive of targets for carbon neutral buildings, although the suggestions ranged from zero carbon heating in new homes by 2015 to overall carbon neutral housing by 2030. In order to meet targets though, it was highlighted that they would need to be supported by: robust and clear policies; research; software; new building regulations; investment and training in low carbon technologies for building design professionals.
Renewables Obligation Certificates
3.29 Renewables Obligation Certificates ( ROCs) attracted comments from 12 respondents who all agreed that reducing the qualification to include individual households could stimulate the application of microgeneration technologies. Two respondents highlighted that if this was to be the case, the process for obtaining and trading ROCs should be streamlined and simple to administer. Another two suggested financial support such as loans repayable through ROCs and improved export prices would encourage uptake.
Support for changing buildings
3.30 11 respondents commented that making buildings more energy efficient and encouraging greater uptake of microgeneration would require advice and financial support. In terms of advice, they suggested that a 'support toolkit' for setting goals and reporting on progress as well as guidance on best practice would be helpful.
3.31 In relation to financial support, two comments were that the present situation was confusing as funding comes from a number of bodies and the application process for grants is lengthy and has no guarantee of success. Other suggestions for financial support are as follows:
- Fiscal measures such as council tax rebates should be offered to those who have installed energy efficiency or microgeneration technologies
- Funding and maximum grant for the Scottish Community and Householders Renewables Initiative ( SCHRI) should be increased. The extra £2 million promised is unlikely to be enough
- Long term, substantial grant funding should replace SCHRI
- SCHRI should be compatible with new Carbon Emissions Reduction Target ( CERT) mechanisms
- Additional funding should be put into the Biomass Support Scheme
- Low interest loans should be introduced for district energy schemes
- Businesses require further incentives as they may be operating on the margins of economic viability and do not have resources to invest in new technologies
- The nature of a householder's tenure should be irrelevant when applying for grant support
Chapter 6: Improving Our Homes
Fuel poverty
3.32 Of the nine respondents who commented, all welcomed the Scottish Government's commitment to end fuel poverty by 2016. Several suggestions were made on how this could be achieved including: energy efficiency measures should be widely installed before considering microgeneration; microgeneration technologies could be used in off-gas and hard to treat properties; there should be coordination between the Scottish Government's fuel poverty schemes and the suppliers Energy Efficiency Commitment ( EEC); merging private sector housing grants with fuel poverty measures would help poorer householders improve the energy efficiency of their homes and eligibility of fuel poverty schemes should be widened to include other fuel poor groups currently missing out.
Energy Efficiency Commitment and Warm Deal
3.33 Further to this, eight other comments were received specifically about EEC and the Warm Deal programme. One respondent felt that the Warm Deal would be better targeted at private landlords whose tenants are in fuel poverty to avoid any overlaps with EEC, whilst another felt that EEC monies would be better directed at Warm Deal. Two other respondents suggested that the product set covered by EEC should be extended to include renewable heating technologies and a third urged the Scottish Government to ensure it is receiving its fair share of EEC funding.
Energy efficient homes
3.34 Improving homes with energy efficiency measures attracted comments from 15 respondents. All 15 agreed that this could make a major contribution to a low carbon economy. It was suggested that targets be set for energy efficiency in homes both for new developments and existing properties and that the private rented sector be included.
3.35 It was felt though, that to ensure targets are met, support mechanisms and incentives would have to be put in place. Amongst the suggestions were council tax rebates, a combined grant and low interest loan scheme and a good practice forum consisting of developers, architects and housing providers being developed across the UK. One respondent highlighted the need for further research into housing previously thought to be unsuitable for conventional insulation.
National Home Energy Ratings
3.36 Two respondents commented on the National Home Energy Rating, both agreeing it should be amended and one suggesting the minimum should be seven for all Scottish homes.
Chapter 7: Public Sector Leading By Example
Central Energy Efficiency Fund
3.37 Commenting on the Public Sector Central Energy Efficiency Fund ( CEEF), 13 respondents agreed that the scheme had been beneficial. However, they would like to see several improvements including a more streamlined application process, the inclusion of renewables and smart meters, greater awareness raising and additional funding.
Public sector procurement
3.38 Eleven respondents commented on the contribution public sector procurement can make to energy efficiency. Of the 11, two felt that there should be targets for the procurement of renewable supplies and microgeneration and another that procurement processes could be used to eliminate energy inefficient products.
3.39 The most important issue for those who commented though, was on procurement of energy. It was felt by five of the respondents that this needs technical input from the local authority energy officers. They also highlighted that if energy is to be procured for all 32 local authorities as a consortium then accurate consumption data would be required to secure the best possible price.
Eco Schools
3.40 Nine respondents agreed that the Eco Schools programme was worthwhile and could help to deliver long term behavioural change. Some also felt that it should be embedded in the curriculum and others that it should focus more on energy use and include the idea of a 'carbon footprint'. Four respondents felt that school buildings could be used to teach students about energy efficiency and microgeneration if they were involved in energy saving measures relating to building design, heating and lighting.
Public Private Partnerships
3.41 All six respondents who commented on Public Private Partnership ( PPP) projects thought that they did not encourage delivery of sustainable public buildings. They felt this was due to contractors being unwilling to take on liability for energy efficiency and microgeneration technologies. It was suggested this could be resolved with the setting of funding conditions for PPP projects which include sustainability elements.
Leading by example
3.42 A quarter of all respondents welcomed the commitment that the public sector would lead by example for a transition to a lower carbon footprint. They felt that, as well as the Scottish Government's own estate, this should include agencies, NDPBs, schools and NHS Trusts and that staff should be encouraged to play their role in reducing their carbon emissions.
3.43 They highlighted though, that the climate change declaration hasn't yet had an impact on the majority of public sector decision making or on the attitudes and behaviours of public sector employees and, as there is currently no mandate for action, it has been difficult to justify resources to deliver objectives.
Environmental targets
3.44 In terms of setting environmental targets for the public sector, most of the eight respondents who commented on this topic agreed that any such targets should be applied to all public bodies and should be regularly monitored and reported against benchmarks. One respondent felt that this consultation failed to adequately explain what the targets would be and how they could be achieved. Others suggested that the Scottish Government should consult with other public bodies before any targets were set and should offer incentives to help prioritise spending.
Carbon Management
3.45 On the topic of Local Authority Carbon Management, three respondents felt that it was a very positive initiative and that all local authorities should participate. One respondent commented though, that it cannot guarantee implementation of its action plans as competition for resources often undermines commitment.
Chapter 8: Next Steps
3.46 Ten respondents welcomed the idea of an energy efficiency and microgeneration action plan.
3.47 However, most of the respondents felt that the measures described were not ambitious enough and needed to be strengthened given the scale of the problem, particularly for the business sector.
Microgeneration
3.48 Although briefly discussed within previous chapters, particularly chapter 5 paragraphs 3.29 - 3.31, the volume of comments received on matters specific to microgeneration was such that a separate section in the report is necessary to fully examine the issues raised. The comments have been collated under four topics: Targets; Barriers to uptake; Support and incentives; and Impacts.
Targets
3.49 Targets for microgeneration were welcomed by nine of the ten respondents who commented on them. It was suggested that any current targets should be assessed in the first instance and if more needs to be done then projecting future energy demand could help determine new targets. It was also felt that targets for renewable heat and zero carbon buildings should be included and that a benchmarking exercise was required to measure energy use reduction against microgeneration installation. Two respondents highlighted that any targets should be supported by complete, holistic and robust policies to welcome investors to the Scottish market.
3.50 The respondent, who did not agree with target setting for microgeneration, felt that the Scottish Government should only set and enforce carbon emissions reductions and give consumers flexibility in how to achieve them.
Barriers to uptake
3.51 One of the main barriers to uptake of microgeneration identified by the respondents was planning restrictions. Of the 17 respondents who commented on barriers, seven wanted to see changes to the planning system to make it easier to install microgeneration. Other potential barriers included: the cost of the technologies and the fact that their benefits are unproven; a weak power distribution system in Scotland and a potential skills shortage in installers and manufacturers.
Support and incentives
3.52 To overcome these barriers, various mechanisms of support were suggested by 21 respondents. Firstly, to assist with the cost of the technologies and their installation, nine respondents agreed that Government support in the form of increased grants of up to 40% of the cost and council tax rebates for those installing microgeneration should be offered. Another respondent felt that compulsion on new build and public procurement would help to bring down costs.
3.53 One respondent would like to see Government encouraging support for the development and commercialisation of indigenous renewable technologies to grow the supply chains.
3.54 To address the issue of unproven benefits, it was suggested that there should be sustained support for research and development into microgeneration and other technologies such as community scale of micro combined heat and power ( CHP).
3.55 In terms of a weak power distribution system, one respondent highlighted that there is currently an opportunity to replace the present supply network with a more microgeneration-friendly system.
3.56 Eight respondents felt that a potential skills shortage could be addressed by the establishment of a competent and trained installer and technician base in Scotland. It was suggested that this base be supported by an information resource for installers and manufacturers to engage with each other and promote best practice.
Impacts
3.57 Five respondents highlighted potential negative impacts of microgeneration. Larger scale microgeneration projects could have an impact on natural heritage especially for bats, freshwater ecology and areas near to sensitive bird populations. Safeguards should be put in place and suggested nationwide base information of what areas are suitable for microgeneration would be welcomed. Three of the respondents felt that the impact on human health and local air quality from biomass schemes have been overlooked as wood burning is a major source of toxic poly aromatic hydrocarbons.
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