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Energy Efficiency and Microgeneration: Achieving a Low Carbon Future: A Strategy for Scotland: Consultation Analysis Report

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ANNEX 1 - CONSULTATION SUMMARY REPORT

4. Setting The Scene

4.1 Target setting
No.	Comments	Names
11	progress reports robust methodology based on a sound statistical base demand reduction flexible to allow for progress made year on year achievable and accompanied by incentives where they will have a financial impact on businesses. policies must be put in place to ensure targets are met expressed in the form of carbon savings complement national or long term targets additional sectoral targets annual debate in parliament on progress set around Key Performance Indicators ( KPIs) backed up by financial and staff resources remain targets without becoming mandatory may lead to tokenism & statistic fiddling at the expense of actual improvements needs significant support in understanding how to calculate carbon equivalents and to support planned approaches to implement reduction medium & long term targets to ensure progress is made quickly and to establish a clear signal that investment in energy efficiency & microgen will be rewarded	Highlands & Islands Enterprise Scottish Natural Heritage ( SNH) South Ayrshire Energy Agency Scottish Renewables The Scottish Rural Property & Business Sector Energy Saving Trust Friends of Earth / Association for the Conservation of Energy Scottish Water Edinburgh Council Changeworks Scottish Environment Protection Agency ( SEPA)
4.2 Renewable heat strategy
11	incorporated into this one and included in the action plan	Scottish Energy Officer's Network ( SEON) North Lanarkshire Council Scottish National Heritage West Lothian Council Scottish HECA Officers Network ( SHON) Forward Scotland Sustainable Development Education ( SDE) Changeworks Scottish Renewables Kilmartin Property Group South Ayrshire Energy Agency
4.3 Decentralised / community energy
13	poor understanding of the extent of actions and measures required barriers have never been adequately addressed should be developed wherever suitable clear links between this strategy & the Decentralised Energy Strategy need permitted development rights or local taxation relief's to give incentive economic benefits to the whole community supported with additional funding supported i.e. through a thermal Renewable Obligation Certificate greater efficiencies of scale advice on establishment, management & operation of energy services companies for promoting decentralised energy requires assessment to identify possible strategic direction & investment needs. credit guarantee /low interest loan scheme that allows larger district heating & Combined Heat and Power projects to raise finance decentralisation would in most situations find a 'best value' level. It allows the integration of several technologies to work together, greater economies of scale, higher likelihood of proper maintenance, less cycling of equipment energy supply regulation has to be reviewed to allow for confident investment in community schemes where these are determined to be the best value approach disappointed that small & large scale community schemes were not properly represented	South Ayrshire Council Forward Scotland Changeworks The Scottish Rural Property & Business Sector Chartered Institute of Housing Scottish Water Kilmartin Property City of Edinburgh Council West Lothian Council South Ayrshire Energy Agency Business Environment Partnership Scottish Renewables SHON
4.4 Transport
3	carbon savings made will mean very little if the issue of sustainable transport is not addressed welcome proposals to link microgen & transport	Aberdeen Campaign Against Climate Change SEPA Scottish National Heritage
4.5 Strategy, carbon & climate change
6	60% carbon dioxide reduction needs to be the driving force of the Strategy and Action Plan set out the step by step achievements that will have to be made to reduce carbon dioxide or on the phasing of targets that will be required on 5 year cycles to meet them welcomes assessment of carbon savings on the Scottish Executive's actions initiatives should be measured in carbon so progress on climate change can be reported on	West Lothian Council South Ayrshire Energy Agency Scottish Renewables EDF Energy Royal Environmental Health Institute City of Edinburgh Council

5. Energy Use in Scotland

5.1 Measuring energy use
No.	Comments	Names
3	more & regular monitoring is required current measurements of energy improvements & carbon reductions bear no relation to the actual situation systematic statistical research should begin as soon as practicably possible set baseline and measure progress	South Ayrshire Council South Ayrshire Energy Agency Scottish Renewables

6. Changing Our Behaviour

6.1 One stop shop
Support
No.	Comments	Names
25	not be limited to householders marketed with clear indication that initiative is lead by Scottish Executive reduce confusion increase awareness of the benefits of energy efficiency and microgen weighting system needs to be applied which recognises the needs of each area staff training in the Sustainable Energy Networks is crucial help to match progress made in industry retain high quality local provision must offer a clearing house for grants loans for SMEs and commitment of a further £2 million loan fund local knowledge & delivery is essential include microgen priority should be given to energy efficiency as a first step, followed by microgen community based approach done alongside an awareness raising campaign easily accessible, consistent, clear and up to date energy efficiency advice build on the existing network of Energy Efficiency Advice Centres ( EEACs) allocate each client a personal adviser who is fully trained to deal with all sustainable energy issues and how to motivate & inspire people to change their behaviour incorporate services from both Energy Saving Trust & Carbon Trust inclusion of Scottish Community and Householder Renewables Initiative advice for SME's & domestic consumers	Alan Kennedy SEON Energy Action Scotland Wise Group SHON West Lothian Council South Ayrshire Energy Agency Forward Scotland SDE Highlands & Islands Community Energy Company Aberdeen City Council Scottish Renewables Business Environment Partnership ( BEP) Scottish Gas Energy Saving Trust Fife Council Friends of Earth / Association for the Conservation of Energy Scottish Water Edinburgh Council SEPA Highlands & Islands Enterprise Dormont Estate Changeworks EDF Energy Kilmartin Property Group
Does not support
2	will not be achievable unless all concerned parties across Scotland are coordinated to follow the same lines of action not necessarily the answer more local advice is more effective as funding differs in each of the 32 Local Authority areas cannot support proposal if it reduces front line service provision not threaten or duplicate community based approach that already exists may divert resource allocation from more distant or rural areas pockets of extreme need will be sacrificed for a structure based solely on advice and without directly maximising measures or directing grant funding.	South Ayrshire Council SHON
6.2 Support for SMEs
9	Loan Action Scotland to be expanded more marketing for Loan Action Scotland needed face to face visits to smaller SMEs more support for the uptake of microgen by businesses practical support and financial assistance is required for SMEs to implement energy saving recommendations money for Loan Action Scotland should be considerably expanded single, well marketed point of contact with local delivery for advice & support need for further explanation on the assumptions & calculations for targets & benefits of future Loan Action Scotland funding welcome additional funding & doubling of max loan in Loan Action Scotland payback should remain at 5 years scheme should be expanded with marketing targeted at SMEs	Royal Institution of Chartered Surveyors Highlands & Islands Enterprise Wise Group West Lothian Council Scottish Renewables BEP Fife Council Scottish Water Friends of Earth / Association for the Conservation of Energy
6.3 Awareness raising
13	sustained educational initiatives promoting individual and community responsibility for energy conservation promotion of best practice not enough proposals for changing consumer behaviour in the Strategy good practice that consumers apply needs to be translated into actual cost saving benefits if growing enthusiasm for microgen meets prohibitive installation costs, there will be widespread dissatisfaction awareness of energy efficiency of products and ecological footprint of goods & services schools provide a useful community focus strengthen the understanding of energy efficiency and microgen's role in tackling climate change help individuals & organisations understand and measure their affect on climate change more focussed education & awareness programmes aligned with Eco Schools Installing microrenewables on school buildings is encouraged	The Institution of Engineering & Technology Scottish National Heritage SHON West Lothian Council South Ayrshire Energy Agency. Forward Scotland SDE Changeworks Scottish Renewables Energy Saving Trust Chartered Institute of Housing Kilmartin Property Group SEPA
6.4 Review of energy efficiency & microgeneration support in Scotland
5	should include microgen need for a standard to govern the provision of advice and endorsement of products & services inform how the SEN is taken forward as different models will work in different regions	Highlands & Islands Enterprise Scottish Renewables Scottish Gas Energy Saving Trust City of Edinburgh Council
6.5 Incentives
5	domestic, tradable carbon allowances should be introduced Scotland should be compared to other developed countries to encourage them to achieve more legislate to an ambition to at least match the reductions achieved by other countries council tax rebates for home owners greening their homes carbon reduction in the community a target for Local Authorities so that privately owned houses are included personal carbon allowances	Royal Institute of Chartered Surveyors Energy Saving Trust National Insulation Association Fife Council South Ayrshire Council
6.6 Market transformation
9	need a workforce skilled in the use, installation and maintenance of low carbon technologies expand energy from renewables but only where this minimises impact on natural heritage expansion of The Low Carbon Building Programme would boost the sector until market forces allow them to become self-sustaining and competitive welcomes development & implementation of green jobs, especially in renewables sector Need new, rigorous measures current subsidies & grants cannot be provided at a scale sufficient to effect necessary changes encourage greater efficiency in consumer products Add to microgen section	Institute of Engineering & Technology Scottish Natural Heritage West Lothian Council BEP Fife Council Highlands & Islands Enterprise South Ayrshire Council Changeworks Kilmartin Property Group

7. Knowing what we use

7.1 Metering & billing
No.	Comments	Names
18	domestic fuel bills should be clearer need clear & unambiguous information about energy use accompanied by a high profile customer awareness and education campaign smart meters should be able to be read & recalibrated remotely have meaningful display for the householder welcome free usage meters being distributed under Energy Efficiency Commitment ( EEC), should be a similar device for gas linked advice on savings to be made rolled out to homes, businesses & public sector as soon as possible do not agree with UK Government's white paper proposal that prior to roll out of smart meters, suppliers should provide customers with stand alone monitors that display information on electricity use develop 2-way communication smart meters must also be follow up support for action mandatory UK-wide roll out of smart meters utility suppliers should be involved at all stages	Royal Institute of Chartered Surveyors Energy Action Scotland Institute of Engineering & Technology Highlands & Islands Enterprise SHON South Ayrshire Council West Lothian Council Forward Scotland SDE Aberdeen City Council EDF Energy Scottish Gas Energy Saving Trust Fife Council Friends of Earth / Association for the Conservation of Energy Scottish Water Kilmartin Property Group Edinburgh Council

8. Changing Our Buildings

8.1 Building standards
No.	Comments	Names
12	brought into line with the best European standards accompanied by an inspection and enforcement regime more needs to be done to tackle existing stock improvement in energy efficiency higher standards should be expected in the future and the industry should be made aware of this standards are not always being met and this needs to be adequately policed. lesser standard should be applied to existing stock regular reviews will be required as the technologies improve welcome plans to use thermal imaging to assess compliance local building control officers require additional resources in order to help them ensure maximum compliance more will need to be done more in line with other countries such as in Scandinavia targets for energy efficiency & microgen are welcomed if it cascades down to building standards forward plan on how building standards will be improved will give market certainty and the industry time to prepare Scotland is still 30 years behind the best in Europe give Local Authorities access to ring-fenced funds to ensure better compliance random air tightness testing builders should be prosecuted alongside owners if buildings do not comply	Institute of Engineering & Technology Royal Institute of Chartered Surveyors Wise Group South Ayrshire Council West Lothian Council Aberdeen Campaign Against Climate Change South Ayrshire Energy Agency. Changeworks Aberdeen City Council Scottish Renewables Fife Council Friends of Earth / Association for the Conservation of Energy
8.2 The EU Energy Performance of Buildings Directive ( EPBD) & Energy Performance Certificate ( EPC)
Support
12	campaign is required to ensure public are fully aware of their duties and how to interpret the information on the Energy Performance Certificate make a contribution in providing information on carbon & fuel costs Energy Performance Certificates must be understandable and meaningful to intended users and contain information on energy use will increase efficiency of buildings should be applied to all buildings to allow the Energy Performance Certificate to act as a benchmark good starting point for future improvements asset & operational ratings should be displayed and the latter updated annually indicate energy costs during purchase or rental of properties? welcome extension of Energy Performance Certificates to business premises value must be placed on having a favourable certification mandatory audits to complement Energy Performance Certificates on all buildings by spring 2008 Energy Performance Certificates should be as user friendly as possible should sign post consumers to sources of further help & advice i.e. EEACs.	Royal Institute of Chartered Surveyors Energy Action Scotland Highlands & Islands Enterprise Wise Group South Ayrshire Energy Agency Changeworks Scottish Renewables BEP The Scottish Rural Property & Business Sector Friends of Earth / Association for the Conservation of Energy Kilmartin Property Group Energy Saving Trust
Does not support
5	does not encourage improvement of building performance no obligation on householders to act on this so further measures are required will not result in significant improvements in energy efficiency will not encourage setting of ambitious goals will not drive performance improvements unless there are mechanisms of compliance checking & sanctions for non display	SEON North Lanarkshire Council South Ayrshire Council West Lothian Council Fife Council
8.3 New buildings
6	new development should be energy efficient & high in density around transport development areas decisive measures need to be put in place to promote the use of cost effective materials and technologies in both new & existing buildings. support new building standards for new builds provide financial and other incentives to improve energy efficiency and encourage uptake of microgen in both new builds & existing stock new homes to include a minimum of energy produced on site Permitted development rights for all forms of renewables & microgen in both new housing & existing stock strengthen building controls to ensure new homes are actually built to design & specification on plans welcome support of building regulations for increased energy standards of new build new buildings should incorporate energy efficiency as standard.	Royal Institute of Chartered Surveyors Institute of Engineering & Technology Aberdeen City Council EDF Energy BEP Scottish Gas
8.4 Existing stock
11	concerned about condition of existing housing stock particularly in the private owner & rented sectors solid wall properties in areas off gas should be given the highest priority integration of existing funding schemes could be used to draw in the additional funding required for the most expensive to treat houses The Scottish Housing Quality Standard will help, but more can and should be done significantly more work is required to increase energy efficiency & energy supply options for existing housing. support should be significant & realistic encourage increased standards when properties are refurbished biggest challenge is tackling energy waste in the existing housing stock insulation is the most cost-effective ring-fenced carbon reduction programme through the provision of grants or regulatory responsibility on energy suppliers new building registrations do not address stock of existing buildings provide guidance on targets for refurbishment of existing buildings, for developments of less than 500 sq.m and set out future increases in targets energy performance of existing stock should be raised.	Energy Action Scotland The Institute of Engineering & Technology Wise Group Changeworks Aberdeen City Council Scottish Renewables National Insulation Association Fife Council Friends of Earth / Association for the Conservation of Energy The Scottish Rural Property & Business Sector Aberdeen Campaign Against Climate Change
8.5 Carbon neutral buildings
7	favour introduction of carbon neutral building standards 'passive house' found in Germany & Austria should be replicated in Scotland building design professionals need in-depth training deliver zero carbon energy use in all buildings by 2016 new homes to be zero carbon by 2017 new build housing: zero carbon heating by 2015/16 & overall zero carbon housing by 2030 needs robust & clear policy, research & a support framework software & building registrations to be developed to accommodate technology & methods training & investment in low carbon techs targets in line with English Zero Carbon emissions from buildings to be reduced by min 3% per annum	Royal Institute of Chartered Surveyors Wise Group South Ayrshire Council Scottish Renewables Energy Saving Trust Friends of Earth / Association for the Conservation of Energy Chartered Institute of Housing
8.6 Renewable Obligation Certificates
12	reduce the qualification level of Renewable Obligation Certificates so individual households could be eligible lobby for improved export prices from renewables could stimulate the application of these technologies target should be increased to 15-20%. continual readjustment of the Renewables Obligation scheme does not improve confidence process for obtaining & trading Renewable Obligation Certificates for small scale producers should be streamlined change criteria for Renewable Obligation Certificates to include microgen, but programme should remain simple to administer Loan scheme should be established alongside this, with installation costs being repaid through Renewable Obligation Certificates either easier access to Renewable Obligation Certificates or feed-in tariffs as in Germany & Spain	SEON North Lanarkshire Council West Lothian Council South Ayrshire Energy Agency Changeworks Aberdeen City Council Scottish Renewables Scottish Water Kilmartin Wise Group Fife Council Friends of Earth / Association for the Conservation of Energy
8.7 Support for changing buildings
11	'support toolkit' to set more ambitious goals and what progress has been made to reach them. fiscal measures such as council tax rebates should be introduced to encourage uptake of energy efficient measures guidance on best practice for the provision of grants to install microgen and repayment times and projected savings should be readily available extra £2m for Scottish Community and Householder Renewables Initiative is unlikely to be enough nature of the householders tenure should be irrelevant when applying for grant support welcomes additional funding for Scottish Community and Householder Renewables Initiative longer term substantial investment is required to maintain enthusiasm and assist with market transformation longer term & more substantial grant programme would be preferable for Scottish Community and Householder Renewables Initiative Scottish Community and Householder Renewables Initiative should be compatible with new Carbon Emissions Reduction Targets ( CERT) mechanism should incentivise renewable heating technologies single point of contact for climate change advice to share best practice & innovation the Low Carbon Building Programme application could be easier with better instruction on how much has been awarded and how to access this welcome additional funding to Biomass Support Scheme further financial incentives should be made available: Loans ( LAS); grants ( SBSS & LCBP); low interest loans for district energy products; tax allowances on low carbon buildings need incentives to encourage businesses to invest in energy efficient as many will be operating on margins of economic viability and do not have resources to invest fiscal incentives to encourage development & purchase of low carbon homes increase in Scottish Community and Householder Renewables Initiative funding to £14.8m per year double maximum grant new major funds for upgrading existing buildings should be created Scottish Community and Householder Renewables Initiative application forms are time consuming with no guarantee of success confusing that funding comes from a number of bodies	SEON North Lanarkshire Council Royal Institution of Chartered Surveyors Dormont Estate Wise Group Forward Scotland Changeworks BEP The Scottish Rural & Property Business Association Energy Saving Trust Friends of Earth / Association for the Conservation of Energy

9. Improving Our Homes

9.1 Fuel poverty
No.	Comments	Names
9	to meet fuel poverty targets, more investment, awareness and infrastructure is needed microgen could make a contribution to the eradication of fuel poverty in off-gas and on hard to treat properties coordination between Scottish Executive's fuel poverty schemes and suppliers' EEC would help to meet fuel poverty targets by 2016 energy efficiency can help to end fuel poverty with microgen being considered at the planning stage supports commitment to end fuel poverty by 2016 supports microgen fuel poverty pilot continued work is needed to support those unable to make changes to the insulation or heating systems themselves EEC will be better targeted to work better with other fuel poverty & energy efficient programmes in Scotland attention should be paid to market transformation of microgen instead of the current pilot as this would help more people in fuel poverty living in hard to heat hard to insulate properties support use of microgen to combat fuel poverty successful technologies should be swiftly incorporated into a nationwide installation programme energy efficient in social rented sector is one area the Scottish Executive could have the biggest impact in tackling fuel poverty eligibility of all fuel poverty schemes should be widened to include other fuel poor groups currently missing out merging of private sector housing grant into the scheme of assistance would be a means of targeting help for poorer homeowners to improve the energy efficiency of their homes	Energy Action Scotland Wise Group South Ayrshire Energy Agency Changeworks Energy Saving Trust Fife Council Friends of Earth / Association for the Conservation of Energy Chartered Institute of Housing The Royal Environmental Health Institute of Scotland
9.2 Warm Deal & EEC/ CERT
8	eligibility should be extended to include other groups not currently eligible such as disabled persons, chronically sick, low income families and single people on very low incomes EEC funding gives homeowners attractive prices compared to average cost of installation existing Scottish Executive budgets & EEC funding should be brought together to work in a more coordinated manner in this way, all properties suitable for both cavity wall & loft insulation could be insulated warm deal would be better targeted at private landlords who's tenants are in fuel poverty as there is overlap with EEC future policy mechanisms should embrace CERT & encourage funding integration EEC monies would be better directed at Warm Deal EEC should apply to renewable heat in Scotland product set covered by EEC should be extended urge the Scottish Executive to ensure its receiving fair share of EEC funding i.e. more than 9% and suggest this is raised with Defra	Energy Action Scotland Wise Group South Ayrshire Council Aberdeen City Council Scottish Gas Fife Council Scottish Renewables Friends of Earth / Association for the Conservation of Energy
9.3 Energy efficiency measures & housing
15	housing sector can make a huge contribution to low carbon economy private sector housing has proved more difficult to educate on the benefits of energy efficiency revolving loan schemes for homeowners topped up with a bit of grant could help loan & grant scheme should be for energy efficiency such as boilers & insulation setting targets to improve energy efficiency in housing does not translate into corresponding carbon savings incentives need to be provided to those houses which are not cost effective to insulate using standard methods housing previously thought to be unsuitable for insulation should be re-examined further research into insulation methods for timber frame walls & other types of roofs is urgently required more financial assistance for homeowners to retrofit existing buildings strategy is an important first step in improving energy efficiency of housing stock householders need incentives such as discount on council tax barrier to take up is in 'able to pay' group need challenging targets for all housing and mechanisms enabling these targets to be met amended tolerable standard rating and Scottish Housing Quality Standard National Home Energy Rating for the next 15 years minimum National Home Energy Rating of 7 for Scottish housing stock legal reforms needed to meet these targets especially to enable improvements in tenements and private rented sector low interest loan scheme to householders developers & suppliers should be encouraged to aspire to higher standards of energy efficiency good practice forum with developers, architects & housing providers should be developed across the United Kingdom future energy policies to be more closely aligned with energy efficiency, rather than microgen energy efficiency standards should be introduced to private rented sector energy efficiency & microgen should be included on all new development sites Landlords Energy Saving Allowance is not well enough marketed to tenants welcome review of Home Energy Conservation Association targets new Home Energy Conservation Association targets should be set for all Local Authorities: 30% reduction of carbon emissions based on March 2007 levels by March 2017	Wise Group South Ayrshire Council West Lothian Council Aberdeen Campaign Against Climate Change South Ayrshire Energy Agency Aberdeen City Council Scottish Renewables National Insulation Association Fife Council The Scottish Rural & Property Business Association Friends of Earth/Association for the Conservation of Energy Chartered Institute of Housing City of Edinburgh Council Energy Saving Trust Energy Action Scotland

10. Public Sector

10.1 Central Energy Efficiency Fund
No.	Comments	Names
13	include targets and reporting mechanisms additional funds should be invested simplistic & beneficial projected savings of 20% over 5 years is unrealistic supports £4 million investment for the HE/ FE sector should be enhanced by resources and training on energy efficiency & microgen to raise awareness of these measures to staff & students 5 year payback should be increased if it's going to support microgen Central Energy Efficiency Fund has identified about £200k savings per annum streamline existing application process welcomes changes to Central Energy Efficiency Fund that include Advanced Meter Readers ( AMRs) should be extended to across entire public sector should include microgen, waste minimisation & renewable energy	SEON North Lanarkshire Council Energy Action Scotland Wise Group South Energy Agency SDE Changeworks Aberdeen City Council Scottish Renewables Fife Council Friends of Earth / Association for the Conservation of Energy Scottish Water SEPA
10.2 Procurement
11	greater care must be taken in how better energy procurement is achieved discussion is needed following the McLelland Report with Energy Managers for technical input require high levels of energy efficiency in building design & operation used to cascade carbon reduction to Scottish Executive suppliers insist on set % of microgen in all new public buildings welcome further guidance on how procurement can contribute to energy efficiency to procure energy through collaborations, there is a need for accurate consumption data council energy officers should be involved in the energy procurement process need targets for purchase of renewable supplies needs to consider whole of life costs to measure value for money must act to eliminate energy inefficient products	SEON North Lanarkshire Council Wise Group West Lothian Council SHON South Ayrshire Energy Agency Changeworks Scottish Renewables Fife Council Friends of Earth / Association for the Conservation of Energy Scottish Water
10.3 Eco Schools
9	student involvement in energy saving measures including building design and operation of heating & lighting in schools is welcomed schools should be 'buildings that teach' about energy efficiency & microgen should be embedded in curriculum every school should be encouraged to register with Eco Schools needs to focus more on energy use all new schools should be carbon zero in use by 2009 by 2011 at least half of schools should be retro-fitted to improve their energy efficiency all schools should be registered by 2011 introduction of the 'carbon footprint' into the programme would be a realistic application of an educational tool more focussed education & awareness programmes aligned with Eco Schools is a way of delivering long term behavioural change	Wise Group Forward Scotland SDE Scottish Renewables Fife Council Friends of Earth / Association for the Conservation of Energy SHON West Lothian Council Energy Saving Trust
10.4 Public Private Partnerships
6	do not encourage delivery of sustainable public buildings hope failure to ensure renewables in Public Private Partnerships programme for schools will not be repeated contractors often do not want to take on liability for energy efficiency & microgen technologies problem of installing microgen on Public Private Partnerships schools should be resolved worked against microgen due to cost and maintenance issues should stipulate minimum energy efficiency standards for Public Private Partnerships contractors before releasing funds should set funding conditions for Public Private Partnerships projects which include sustainability elements	South Ayrshire Council Forward Scotland Changeworks Friends of Earth / Association for the Conservation of Energy SEPA City of Edinburgh Council
10.5 Leading by example
10	setting an example for a transition to a lower carbon footprint Non Department Public Bodies and agencies should be seen as exemplars of sustainable building design, refurbishment & modernisation encourage staff to play their role in reducing carbon emissions supports an ambitious reduction in carbon emissions from the Scottish Executive's own activities and estate encouragement of greater uptake of energy efficiency & microgen across public sector estate especially schools & NHS trusts targeting key cities to become 'low carbon cities' would become a focal point for action climate change declaration has not yet had an impact on the majority of public sector decision making or on the attitudes & behaviours of public sector employees local government has no mandate for action on climate change not prioritised and it can be difficult to justify resources to deliver action emissions should be reduced by 5% per annum at least reduce transport based emissions grant funding is too time consuming & uncertain	Dormont Estate Wise Group South Ayrshire Energy Agency Forward Scotland Scottish Renewables Energy Saving Trust Fife Council Friends of Earth / Association for the Conservation of Energy SEPA Changeworks
10.6 Targets & benchmarking
8	welcome commitment to work with Local Authorities to develop other ways to monitor, report & benchmark emissions inadequately explains the intention to set targets for carbon dioxide emissions, what these are and how they could be delivered Scottish Executive needs to consult with Local Authorities to set implication of performance measures and how they should respond targets for all public bodies should be the same should be a reduction in carbon emissions instead of reduction in energy use monitor & report against benchmarks as this would help to re-prioritise spending need other targets i.e. emissions, generating renewable energy. stronger incentives are required if Local Authorities can support government targets target for carbon dioxide emissions reduction should be applied to Non Department Public Bodies & Local Authorities also setting environmental performance targets for Non Department Public Bodies and agencies and targets for Local Authorities	North Lanarkshire Council SEON West Lothian Council SHON Aberdeen City Council Fife Council Friends of Earth / Association for the Conservation of Energy Scottish Water
10.7 Carbon management
3	very positive initiative expected to greatly assist in delivering commitments under Scottish Climate Change Declaration all Local Authorities should participate in carbon management lacks surety of action plans being implemented as competition for resources undermines commitment	South Ayrshire Council Aberdeen City Council Fife Council

11. Microgeneration

11.1 Targets
No.	Comments	Names
10	should differentiate across range of technologies quantify anticipated carbon savings significant investment & commitment by the microgen industry is required if the technologies are to make a contribution to the 40% renewables by 2020 target cascade down to building standards & planning supported by complete, holistic & robust policies to welcome investors to the Scottish market assess current targets and whether or not more needs to be done required to ensure emissions reductions from microgen are realised welcome targets for microgen welcome targets for renewable heat targets could be for zero carbon buildings projecting energy demand would help set targets for renewables now do not agree with Scottish Executive target for microgen: should only set & enforce carbon emissions reductions and give consumers flexibility in how they achieve them	Scottish Natural Heritage South Ayrshire Energy Agency West Lothian Council Scottish Renewables SEPA Highlands & Islands Enterprise Aberdeen City Council Fife Council Friends of Earth / Association for the Conservation of Energy EDF Energy
11.2 Barriers to uptake
17	planning system should make it easier for householders to install microgen costs and benefits of specific technologies should be properly treated in the market place attractiveness to potential buyers will depend on: future gas prices; effectiveness of large scale public installations; payback times; environmental issues; simplification of regulatory arrangements and transparent regime of rewards for export of electricity application process for microgen should be simplified whether that be for planning permission, grid connection or grant planning requirements associated with microgen must be linked to the effectiveness of the technology technologies are too expensive and promised benefits are unproven GDPO should be a relaxed code for microgen need to consider onsite generation of renewable energy at the design stage planning reform could make it easier to install microgen planning restrictions & network access are barriers improve the grid infrastructure to allow suppliers access to the market power distribution system in some areas of Scotland is weak ensure that a potential skills shortage does not cause an additional barrier definition of microgen should not determine whether or not it needs planning permission Scotland-wide policy on what requires permission	Institute of Engineering & Technology Royal Institute of Chartered Surveyors Dormont Estate West Lothian Council SHON South Ayrshire Energy Agency Forward Scotland SDE Scottish Renewables Scottish Gas Scottish Water Kilmartin Property Group City of Edinburgh Council Scottish Natural Heritage Energy Saving Trust Fife Council Friends of Earth / Association for the Conservation of Energy
11.3 Support & incentives
21	give the certainty to the manufacturers, developers & financial institutions energy efficiency measures should be prioritised reduce emissions from non-renewables sources by carbon capture or nuclear compulsion on new build and public procurement to help bring down costs provide a resource of information to businesses supplying demand for microgen devices for installers & manufacturers to engage with each other and promote best practice planners should be provided with sufficient training need fiscal incentives increased financial support and information welcome extension of permitted development rights for microgen to households & commercial buildings 15% target in SPP6 will assist market growth should commission a wider study into other techs such as community scale or micro- CHP nationwide base information of what areas are suitable for what type of microgen is highly desirable ongoing provision of grant funding or tax breaks UK microgen certification process is welcomed there is an opportunity for current supply network to be replaced with a microgen friendly network greater emphasis for uptake of microgen should be focussed on encouraging new business opportunities that this developing industry could bring to Scotland financial incentives for domestic microgen need to be optimised grant should be raised to 40% further £2 million should be invested in support for grants council tax rebates for those installing microgen continued support for The Low Carbon Building Programme & The Scottish Community and Householder Renewables Initiative or the market may decline access to sound advice, design and installation of each system competent and trained installer / technician base is needed simple financial support to build up the market sustained support for research & development need more in-depth advice & support business rates exemptions should be extended to include microgen benchmarking to measure energy use reduction against microgen installation proposal to establish a high level work group for microgen policy current level of grant support for microgen is inadequate best practice from European countries on their use, programmes, incentives & promotion	Fife Council Wise Group Scottish Natural Heritage South Ayrshire Energy Agency Forward Scotland SDE Scottish Renewables Scottish Gas The Scottish Rural Property & Business Association Friends of Earth/Association for the Conservation of Energy The Royal Environmental Health Institute of Scotland EDF Energy Kilmartin Property Group City of Edinburgh Council Scottish Enterprise SEPA Dormont Estate Aberdeen City Council Institute of Engineering & Technology Scottish Retail Consortium Energy Saving Trust
11.4 Impacts
5	fossil fuel microgen technologies such as Combined Heat and Power will not always deliver lower carbon emissions when compared to electricity from conventional power stations and heat from condensing boilers impacts on human health and local air quality appear to have been overlooked concern about the promotion of biomass especially for areas where Local Air Quality Management Areas have been declared developments in schools & housing developments should take into account that children are a vulnerable group in health terms Poly Aromatic Hydrocarbons ( PAHs) are toxic, persistent in the environment and bioaccumulate in fatty tissues & biomagnify through the food chain. Wood burning is one of the major sources of PAHs need associated safeguards for the historic & natural environment larger scale of microgen could have an impact on natural heritage especially for bats, freshwater ecology and areas near to sensitive bird populations	The Royal Environmental Health Institute of Scotland EDF Energy City of Edinburgh Council SEPA Scottish Natural Heritage

12. Action Plan

No.	Comments	Names
10	should be placed in the context of action on climate change Scottish Government should lead on energy & climate change with this action plan should take a pro-active approach robust statistical breakdown so its impact and carbon reduction contribution can be better understood give government direction & confidence and avoid duplication in effort proposals need to be strengthened given the scale of the problem encourage innovation and drive next steps not ambitious enough supported by a systematic business plan approach welcome further measures for business sector focus on encouraging & supporting companies to get involved in the supply chains growing around microgen technologies support the development & commercialisation of indigenous technologies	Highlands & Islands Enterprise West Lothian Council SHON ACACC South Ayrshire Energy Agency Changeworks Scottish Renewables National Insulation Association The Scottish Rural Property & Business Sector Scottish Enterprise

13. General Comments

No.	Comments	Names
10	recommend that a higher spend per capita on energy efficiency in Scotland than in the rest of the UK due to anomaly in energy use suppliers should be able to claim credits for reductions in individual household consumption and for advice given i.e. energy audits householders should be encouraged to invest in energy efficiency measures first concern over achieving aims set out reducing demand for energy is given appropriate priority over the installation of micro-renewable technologies energy efficiency should always be the first step before considering installation of microgen focus of the Strategy should be more energy efficiency then looking at local energy supply, including microgen energy source is the principal issue. microgen is far more effective when installed on a building which has effective insulation should ensure any property fitted with microgen technology is suitably insulated. strategy does not cover new ground	Energy Action Scotland Scottish Gas Energy Saving Trust Alan Kennedy The Institute of Engineering & Technology Wise Group West Lothian Council Changeworks National Insulation Association Fife Council

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