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Report 13 January 2021

Our response to call for views on the Scottish Government’s updated Climate Change Plan

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Energy Saving Trust’s response to the Local Government and Communities Committee’s call for views on the Scottish Government’s updated Climate Change Plan. Submitted 12 January 2021.


Thank you for providing the opportunity for Energy Saving Trust to provide evidence to the Committee’s call for written views. Our submission focuses on the policies and proposals relating to homes and communities and relates to key aspects of the plan that the Committee is interested in, specifically, housing, fuel poverty and green recovery.

Energy Saving Trust is an independent organisation dedicated to promoting energy efficiency, low carbon transport and sustainable energy use to address the climate emergency.

Our work focuses on reaching net zero targets by taking action to reduce energy consumption, installing new infrastructure and accelerating a move to sustainable, low carbon lifestyles.

A trusted, independent voice, we have over 25 years’ sector experience. We provide leadership and expertise to deliver the benefits of achieving carbon reduction targets: warmer homes, cleaner air, healthier populations, a resilient economy and a stable climate.

We empower householders to make better choices, deliver transformative programmes for governments and support businesses and community groups with strategy, research and assurance – enabling everyone to play their part in building a sustainable future.

In Scotland Energy Saving Trust is a principal delivery partner of the Scottish Government for home energy efficiency. We run comprehensive local and national advice and support programmes for the Scottish Government. Public engagement on energy is at the heart of our work. In total each year the Home Energy Scotland advice service managed by Energy Saving Trust on behalf of the Scottish Government helps more than 90,000 customers.

Response to questions posed in the Committee’s call for written views

Our responses to each of the Committee’s questions are outlined below.

1. What is your assessment of the progress to date in cutting emissions within the sector/sectors of interest and the implementation of the proposals and policies set out in previous Climate Change Plans (RPP1-3)?

Emissions reductions

In terms of activities to improve home energy efficiency and reduce emissions from the residential sector it is worth emphasising here that Scotland, in many ways, already leads the way in the UK, and as an organisation delivering activity across the whole of the UK, we have first-hand experience of this. Indeed, Scotland was the first part of the UK to recognise energy efficiency as a National Infrastructure Priority and has provided over many years consistent (and increasing) funding and support for programmes to improve the energy performance of Scotland’s homes. Indeed, over recent years Scotland has spent considerably more in this area per head of population than other UK administrations. This means that many of the necessary building blocks to ensure that Scotland’s housing sector plays its full part in reducing emissions are in now in place.

So, Scotland has provided leadership in this area and there has been considerable progress made in developing and delivering programmes to improve the energy performance of Scotland’s homes. But there is still more that needs to be done. It is clear from emissions data that the scale and pace of this activity is not currently sufficient to ensure that the housing sector plays its full part in contributing to Scotland’s challenging emissions reduction targets. The Climate Change Committee’s (CCC) 2020 progress report to the Scottish Parliament[1] highlights that the vast majority of emissions reductions to date in Scotland have been limited to the power sector which has contributed to two-thirds of the total fall in emissions from 2008 to 2018 and that emissions from all other sectors outside of electricity generation have fallen by just 14% over the same period. The report goes on to note that “the key structural changes that will drive emissions in sectors outside of electricity generation have not yet been achieved”.

The CCC’s report provides a clear indication that the Scottish Government’s home energy programmes are delivering results in terms of emissions reductions. The report makes it clear that there have been emissions reductions in the buildings (residential and non-residential) sector over the last decade with a 16% reduction in emissions in all buildings seen between 2008 and 2018. They note that this progress has been “mainly seen in the residential buildings sector” and that “improvements to the energy efficiency ratings of homes…suggests that a proportion of the emissions reductions made in the last decade reflects genuine improvements”. Data detailed in the CCC’s report shows that emissions in the residential sector have shown little downward movement since 2014 and in fact rose by 0.2MtCO2e between 2017 and 2018. A number of countervailing factors contributed to this and it is important to emphasise here that without home energy programmes emissions in this sector would have been considerably higher. Emissions in the buildings sector as a whole rose by 4% over the same period. At a time when emissions need to be reducing significantly and rapidly this is concerning. It is clear from existing data and the expectations outlined in the CCPu that a step change in the rates of emissions reductions is required – as noted above the buildings sector has seen a 16% reduction in emissions over the last 10 years (2008-2018) while the CCPu suggests that the buildings sector (note: the CCPu does not break this sector down further) will need to deliver emissions reductions of 66% (ie from 7.6MtCO2e in 2020 to 2.6MtCO2e in 2029) in the nine years between 2020 and 2029.

Implementation of the proposals and policies set out in previous Climate Change plans (RPP1-3)

As noted above, significant progress has been made over the course of the last nine years (ie since the publication of RPP1 in 2011) in terms of the development and implementation of policies and proposals designed to reduce emissions from Scotland’s housing stock. The Scottish Government has provided consistent (and increasing) funding and support for programmes to improve the energy performance of Scotland homes. Indeed, over recent years Scotland has spent considerably more in this area per head of population than other UK administrations.

Notably, Scotland’s overarching energy efficiency programme Energy Efficient Scotland (EES) – previously called Scotland’s Energy Efficiency Programme (SEEP) – was announced in response to the designation of energy efficiency as a National Infrastructure Priority. EES was formally launched in May 2018 with the publication of the EES route map with two main objectives – to remove poor energy efficiency as a driver of fuel poverty and to reduce greenhouse gas emissions through more energy efficient buildings and through decarbonising Scotland’s heat supply. The Scottish Government have said that EES will be a 20-year programme and this long-term commitment together with the fact that the Scottish Government has proposed long term energy performance standards for all homes in Scotland helps to provide policy certainty (which is important as it provides a clear signal to investors). It also provides a clear signal to the supply chain to invest in the development of their staff, to recruit more staff and grow their businesses.

Delivery programmes have expanded considerably since the publication of the first RPP in response to the evolving policy landscape. As noted above, continued support for energy efficiency over many years means that much of the delivery infrastructure is in place to deliver against EES’ objectives. Further information about the parts of the programmes that the Energy Saving Trust delivers for the Scottish Government can be found in our recent report “Delivering a new energy future for Scotland’s homes – Home energy programmes delivered by Energy Saving Trust on behalf of Scottish Government”.

Support for domestic renewable heating in Scotland has grown since the publication of the last Climate Change Plan. A recent, although short term, development is the addition to the Home Energy Scotland loans and grants offering with the introduction of a new £4.5 million cashback incentive via the Home Energy Scotland loan scheme to help people install renewable and energy efficiency measures in their homes with a focus on renewable heating. This should play an important role in overcoming one of the key barriers to the take up of home renewables – the higher capital cost of a renewable heating system in comparison to a fossil-fuelled system.

It is worth emphasising here that Scotland’s extensive energy efficiency programmes have continued to have been designed where possible to work with and take advantage of other energy efficiency programmes, such as ECO and the RHI. This has helped to maximise the opportunities available to households and local authorities across Scotland and has made it possible to build larger funding pots to help deliver larger and/or more expensive projects. To achieve Scotland’s challenging targets the Scottish Government needs to continue to be bold in incentivising the uptake of home energy improvements even if this means that it displaces UK Government funding support (eg RHI) where that support does not provide a sufficient incentive as it has done with the new cashback available via the Home Energy Scotland loan scheme.

Of the policies and proposals outlined in the previous Climate Change Plans we believe there are a number of areas where we think more progress could have been made, including:

  • Regulation in the owner occupied sector. RPP3 committed that ‘SEEP will put in place regulation and standards providing long-term certainty and making it the norm to invest in energy efficiency’. While regulation and standards are now/soon to be in place for the social housing sector and the private rented sector respectively, progress on regulation in the owner occupied sector has been notably slower. A legally-binding energy efficiency standard, that applies at a number of trigger points for owner-occupied housing, is clearly required to drive up minimum standards and to ensure that as many homes as possible are brought up to an EPC C standard or equivalent. This would also give a further clear signal to the supply chain to grow. We welcome the commitment in the CCPu that “the Heat in Buildings Strategy will update the Energy Efficient Scotland route map and will commit to putting in place standards and regulation for heat and energy efficiency, where it is within legal competence, to ensure that all buildings are energy efficient by 2035 and use zero emission heating and cooling systems by 2045”. It is difficult to comment further here because the Heat in Buildings Strategy has not yet been published and we therefore don’t know the detail of what will be proposed in this area. In this context it may be sensible (depending on publication dates) for the Committee to scrutinize the Heat in Buildings Strategy in parallel with the CCPu.
  • Building Regulations. Section 6 (Energy) of the Scottish Building Regulations was last updated in 2015, and the last RPP (RPP3, published in February 2018) committed that a “further review of energy standards will commence in 2018 and will investigate a number of measures that offer the potential for further abatement from new buildings and where work is undertaken in existing buildings”. Subsequently the Scottish Government launched a review of energy standards in June 2018 the purpose of which was “to consider next steps to further enhance the energy performance of buildings and contribute to greenhouse gas abatement targets”[2].

The following year the Scottish Government’s Programme for Government for 2019-20 committed to setting “new standards to reduce energy demand, and associated carbon emissions, within new buildings by 2021” and to requiring “new homes consented from 2024 to use renewable or low carbon heat”. At the end of 2019 they published a scoping consultation on a new build heat standard that would apply from 2024 which is a welcome development. We note that, at the end of 2019 both the UK Government and the Welsh Government as part of wider consultations on energy standards to apply from 2025 included proposals to future proof new homes from 2020 in readiness for low carbon heating systems in the future. Specifically, both Governments proposed that wet space heating systems should be designed to operate with a flow rate temperature of 55oC or lower in the final heating circuit. Doing so would make it easier to install heat pumps or district heating in the future. We would like to see an at least equivalent commitment from the Scottish Government that all new homes built between now and 2024 are future proofed in readiness for low carbon heating systems in the future.

2. Do you think the scale of reductions proposed within the sector(s) are appropriate and are the proposals and policies within the CCPu effective for meeting the annual emissions targets and contributing towards the 75% reduction in GHG emissions by 2030 and net-zero by 2045 targets? 

We very much welcome the level of ambition set out for decarbonisation of the buildings sector outlined in the CCPu, in particular ambitions for:

  • zero emissions heating systems to account for at least 50% of new systems being installed each year from 2025
  • at least 50% of Scotland’s building stock is heated using zero emission systems from 2030

The CCPu proposes a significantly enhanced policy package for the buildings sector and we welcome this. The list of new policies that we welcome is too long to detail here but we are particularly pleased to see the commitment to develop a long term public engagement strategy, to design future delivery programmes to ensure significantly accelerated retrofit of buildings, and various proposals to support the projected roll out of heat pumps. We are also very pleased to see that a particular focus for action before 2025 will be on “taking steps to facilitate common works in tenement buildings”. Although we note that while this appears as a focus area in the body of the CCPu there is no reference to this work in the list of policies and proposals provided in the CCPu’s annex. Flats represent a particularly challenging challenge in terms of energy efficiency and low carbon heat and given the significant proportion of flats in Scotland’s housing stock work in this area is much needed. Action to common parts of tenements can only be undertaken if the majority of owners agree to the works being undertaken. If they don’t it can’t go ahead. Thus, the decision of some (even a very small majority) can result in energy efficiency improvements (necessary for the health, well-being and comfort of other residents and indeed necessary for CO2 emissions reductions) not taking place. In addition, vulnerable households who are eligible for grant support are not able to benefit from energy efficiency measures when the necessary levels of communal agreement are not reached.

As noted above we would welcome additional detail about some of the proposed policies but acknowledge that much of this is likely to be forthcoming in the Heat in Buildings Strategy which is due to be published soon.

It is not possible to tell from the information provided in the CCPu what scale of reductions are proposed within the residential buildings sector. This is because the emissions envelopes group together residential and non-residential buildings. We note that the original Climate Change Plan for 2018-2032 published in February 2018 included a target for a 23% reduction in direct residential emissions between 2018 and 2032. The CCPu states (on page 31) that many elements of the 2018 plan still stand and that the CCPu should be read alongside that 2018 plan. However, it is not clear whether the emissions reductions envisaged from the residential sector remain as they were in the 2018 plan or whether they have increased in line with Scotland’s increased climate change ambition.

It would be helpful to include information about the scale of reductions expected from the residential sector in light of the Scottish Government’s new climate change targets – particularly the 2030 target in relation to which the CCC note “The rapid emissions reductions required for a 75% reduction by 2030 may not be feasible without extreme implications for cost and/or required changes in behaviour”. Only then can stakeholders more definitively determine whether the policies and proposals detailed in the update will be effective at meeting these targets.

In the context of the scale of reductions from the buildings sector we note that Annex C, which details the emissions envelopes for each sector, suggests that emissions from the buildings sector are expected to reduce (by between 5% and 22% each year) between 2020 and 2029 at which point they remain stable (at 2.6MtCO2 per year) until the end of the budget period (ie 2032). It is not explicitly clear why this plateauing occurs. We think that some additional narrative in the final CCPu about this would be helpful to make this clearer.

Also included in Annex C is a reference to the fact that additional emission-reduction effort has been allocated out with the TIMES framework across all sectors on a pro-rata basis in order to allow the industrial sector higher emissions to help protect against carbon leakage. This is another area where we believe additional explanatory narrative would be helpful – particularly in the context of the impact that this has on the size of the emissions envelope and resulting impacts on deliverability of reductions in the residential sector.

Additional narrative and data around the impact that different policies are expected to have would also be helpful to allow assessment whether the policies and proposals will be effective meeting for meeting the annual emissions targets and contributing towards the 75% reduction in GHG emissions by 2030 and net-zero by 2045 targets. It was clear from the Scottish Government’s Energy Efficient Scotland consultation of March 2019 that neither business as usual, ie existing approaches, nor business as usual approaches plus regulation at the point of sale, will be sufficient to ensure the delivery of the proposed EPC C standard in all homes by 2040 let alone by 2035 (this latter date is referenced in the CCPu annex). While the CCPu proposes a significantly enhanced policy package there isn’t sufficient information provided to determine the impact this will have on installation rates and so on likely emissions reductions.

3. Do you think the timescales over which the proposals and policies are expected to take effect are appropriate?

As noted in our response to question 1 above the CCC have recently emphasised concerns about how rapidly decarbonisation can be achieved[3]. They have also provided initial advice about how the Scottish Government could go beyond the abatement scenarios outlined in the CCC’s 6th carbon budget report. Two potential options that they outline relate to the retrofit of buildings; the scrappage of high carbon assets such as fossil fuel boilers and the additional retrofit of hybrid heat pumps. Given the challenges associated with this target we believe that it makes sense to bring forward certain delivery dates where possible. In particular, we believe that the Scottish Government should strive towards all homes being energy efficient (ie have an EPC of at least C or equivalent) by 2030 instead of 2035.

We would welcome greater clarity about domestic heat pump numbers and how hybrid and non-hybrid heat pump numbers envisaged by the Scottish Government by 2025, 2030 and 2035 compare to those envisaged by the CCC. As can be seen from the extracts below, it isn’t clear what exactly is envisaged in each five-year period. This makes it difficult to judge whether the timescales proposed in the CCPu are appropriate.

The CCC state that for their balanced pathway (which will not deliver the Scottish Government’s 75% emissions reduction target by 2030): “We already assume around 40,000 hybrid heat pumps and more than 200,000 full heat pumps are installed in existing homes in Scotland in our Balanced Pathway by 2030, but there may be potential to go further, if supply chains can be scaled up sufficiently. By 2035, our Balanced Pathway sees an additional 350,000 full and hybrid heat pumps deployed in Scotland compared to 2030 levels, as supply chain capacity and public knowledge and acceptance of heat pumps increase”. The Scottish Government in the PfG – which appears to be consistent with the figures outlined in the CCPu – note that:

  • “Our ambition is – as a minimum – to see the rate of renewable heat installations in new and existing homes and buildings double every year from a current baseline of 2,000 domestic installations per annum in 2020 to 64,000 homes fitted in 2025 – a cumulative total of around 126,000 homes” and that a peak installation rate of 250,000 homes per annum in the 2030s is expected.

4. To what extent do you think the proposals and policies reflect considerations about behaviour change and opportunities to secure wider benefits (eg environmental, financial and health) from specific interventions in particular sectors?

The proposals and policies and the wider narrative in the CCPu reflect considerations about behaviour change well. We very much welcome that the CCPu, along with the draft public engagement strategy for climate change which was published alongside it, responds to and draws significantly on recent research and advice; in particular that undertaken on behalf of the Scottish Government itself and that of the CCC. The draft public engagement strategy for example responds to the recommendation from an independent advisory report to the CCC on facilitating behavioural and societal change to reach net zero that, “in addition to supporting people to take specific concrete actions to reduce emissions, we need a strategy for creating a wider context that nurtures public engagement with action on climate change” and aims “to create a context that nurtures public engagement on climate change over the next 3-5 years”.

We also welcome the acknowledgements in the CCPu of the following statements from the CCC:

  • “…over 60% of emissions reductions to meet net zero will be predicated on some kind of individual or societal behavioural change”
  • “In the buildings sector, higher impact savings from behavioural changes are needed, driven by increased engagement with the public on emissions reduction, particularly due to low levels of awareness and understanding of the connection between buildings and climate change”

It is vital that people know why they need to act, how they need to act and ultimately that they do in fact act. Only then will all the necessary actions be taken by people to improve the energy performance of their homes (ie that changes occur to both their purchasing behaviours and wider behaviours). Available evidence suggests that there is low general awareness amongst the population of the need to improve the energy efficiency of their homes and to switch away from conventional heating as well as very low awareness of how people can take action. The CCC has emphasised that where people are involved in the changes that are required, they are likely to be achieved faster and at less cost.[4]. A recent survey by the Energy Systems Catapult[5] (ESC) for example, found that less than half the 2,000 people they surveyed were aware that their gas boiler was contributing to climate change (it is responsible for around a third of the average household’s emissions). There was far higher awareness of the contribution to climate change from road and air transport and household waste, despite these all having a lower impact (27%, 12% and 3%, according to ESC calculations). The CCC’s most recent report draws on research from BEIS to emphasise that levels of public engagement are low and in particular that there is low awareness amongst the public of the need to shift to low carbon heating.

In this context we have previously called for a major engagement campaign to build awareness amongst the public. The time sensitiveness of this activity is worthwhile highlighting here. It will be vitally important that people know as soon as possible that the heating system they have now is unlikely to be the same type of system they have in the near-medium term. The CCPu envisages that from 2025 (ie in only four years’ time) zero emissions heating systems will account for at least 50% of new systems being installed each year. We are therefore pleased to see commitments to “build public support for the heat transition through extensive and sustained engagement with individuals, communities and businesses across Scotland”, and to “…maximise the impact of our advice and support schemes to build public awareness and understanding of heat decarbonisation and energy efficiency solutions”. We also welcome the publication of the “Net Zero Nation: A Draft Public Engagement Strategy for Climate Change”.

It is also important that people are adequately supported to take action. The necessary frameworks for supporting customers and incentivising action are already in place in Scotland (through Home Energy Scotland and various financial support schemes) and there will be a continued and growing need for these programmes. Encouraging householders to install low carbon heating systems will mean persuading them to engage with systems that involve more complex choices and significant investment alongside home energy efficiency improvements. Our evidence shows that where Home Energy Scotland provides specialist advice on more complex measures such as small-scale renewables around 83% of customers who received this support and took action attributed that action, at least in part, to the support they received. Our evidence also shows how the specialist advice service has supported customer action on renewables:

  • half of customers reported that the service gave them ideas for action
  • two thirds of customers reported that the service gave them confidence to implement actions
  • half of customers reported that the service provided them with skills and understanding to implement actions

Against this background we believe that, in order to ensure that householders and owners are well advised and supported in making decisions installing a lower carbon heating system it will be essential that the Home Energy Scotland advice function is not only retained but is scaled up to support more householders. It is therefore very welcome that the CCPu commits to “provide enhanced support to households through existing programmes such as Home Energy Scotland”.

One ‘behavioural’ area that we feel would benefit from greater consideration in the plan is around the use of new heating systems once they are installed and the use of heating systems once a home’s energy efficiency has been improved. It is clearly important that assumed savings from energy efficiency measures are actually delivered in practice and behaviour change will obviously have a key role to play here. Given that heat is responsible for such a significant proportion of emissions from the household sector it is particularly important that people use their heating systems effectively, otherwise there is a significant risk that the full potential savings (in terms of comfort, energy, money and CO2) from energy efficiency programmes will not be realised in practice. Low carbon heating systems will in the majority of cases need to be used differently than the systems that they are replacing and it is important that householders have access to the advice and information necessary to ensure that they are able to use them effectively and efficiently. While such advice is currently available under Home Energy Scotland the need for it will become even more significant and will need to be provided to more households in the coming years.

Interestingly there is no explicit mention of ‘behaviour’ in any of the policies listed for buildings. However, as noted above many of the policies will result in behaviour change. We therefore think that there could be scope to make the link between the policies proposed and their impact on behaviour change more explicit.

As well as delivering emissions reductions improving the energy performance of homes delivers multiple additional benefits – including, but not limited to, improved health and well being, additional and sustained jobs, and reduced rates and levels of fuel poverty. Ensuring that energy efficiency makes its full contribution to emissions reductions in Scotland will help to ensure delivery of these additional benefits.

5. To what extent do you think the CCPu delivers a green recovery?

It is worthwhile firstly highlighting that Energy Saving Trust very much welcomes the Scottish Government’s commitment to “securing a just and green recovery” and its intention that the CCPu is seen as a “strategic document on our green recovery from COVID-19”.

The economic benefits of investing in home energy improvements are well documented and have received considerable attention over the last year as part of efforts to determine the ‘best’ means of post-COVID-19 economic recovery.

Many reports have recently been published highlighting the benefits associated with increased investment in energy efficiency and advocating that energy efficiency be a key element of economic stimulus packages. The recently published report from Scotland’s Advisory Group on Economic Recovery for example highlights that, “Non-traded sectors and activities which are less affected by international competitiveness concerns such as domestic heating, energy efficiency and ground transport are all ripe for a programme of investment and innovation which will deliver emissions reductions, jobs and potential opportunities in supply chain development”.

Some of the key economic benefits are neatly summarised in a recent report from the IEA and IMF[6]: “We estimate that 9‑30 jobs would be created for every million dollars invested in energy efficiency measures in the buildings sector. Measures in this area often have short lead-times: existing efficiency programmes, for example, can be rapidly expanded and new projects can be shovel-ready within weeks or months…Government investment in accelerating energy efficiency in buildings would bring long-lasting benefits: it would reduce energy bills for consumers, reduce energy poverty, improve health and comfort, and improve resilience in the face of climate events and price shocks.

Scottish specific research shows a £7.8 billion boost in real GDP over the period of a 30-year energy efficiency programme can be achieved, with ‘sustained delivery of 0.2% GDP in the long term’ as the impacts of energy efficiency gains continue.[7] This suggests there could be a return of £5 in GDP per £1 of government investment, though figures will vary as timescales are brought forward to address the economic and climate crisis. As far as jobs are concerned, analysis within Scottish Government’s Energy Efficient Scotland route map[8] notes that “every £100 million spent on energy efficiency improvements in 2018 (is) estimated to support approximately 1,200 full-time equivalent jobs across the Scottish economy”.

It is therefore clear that policies to improve the energy performance of Scotland’s buildings will undoubtedly make a key contribution to a green recovery for Scotland. However, as noted above there is not sufficient detail to determine the extent to which this will occur and whether or not they will result in energy efficiency making its full contribution to both emissions reductions and economic recovery in Scotland. We hope this may become more apparent in the forthcoming Heat in Buildings Strategy. Ensuring that energy efficiency makes its full contribution to emissions reductions in Scotland will be key to ensuring the delivery of a truly green recovery in Scotland.


[1] See:

[2] The first stage of the review was a call for evidence on the effectiveness and impact that the 2015 energy standards and supporting guidance had/has on Industry in delivering energy efficient buildings.

[3] “Given that Scotland has all but exhausted the potential for reductions in fossil-fired electricity generation that drove progress in reducing emissions in the 2010s, the 2030 target will be extremely challenging to meet, even if Scottish Ministers take action to get on track for Net Zero by 2045. The rapid emissions reductions required for a 75% reduction by 2030 may not be feasible without extreme implications for cost and/or required changes in behaviour”. See:



[6] Sustainable Recovery, World Energy Outlook Special Report, International Energy Agency in collaboration with the International Monetary Fund, 2020.

[7] Potential wider economic impacts of the Energy Efficient Scotland programme, 2018, Centre for Energy Policy, University of Strathclyde.

[8] Energy Efficient Scotland: route map, Scottish Government, May 2018.

Last updated: 13 January 2021