Friends of the Earth Scotland response to the Scottish
Government consultation on
Heat and Energy Efficiency Strategies and
Regulation of District Heating
18 April 2017
Introduction
Friends of the Earth Scotland researches and campaigns for actions that contribute to tackling the
threat of climate change. Shifting our economy away from dependency on fossil fuels is critical in
responding to the climate crisis and Friends of the Earth believe that this transformation is an
opportunity to build a fairer, more equal and socially just Scotland. We believe that if this is to
happen, plans should be made for the transformation of specific economic sectors which should be
driven forward by the Scottish Government as part of the implementation of the Climate Change
Plan. District Heating and Energy Efficiency are two such sectors which will be central to the
delivery of ambition targets.
General Comments
Friends of the Earth Scotland (FoES) welcomes the publication of this consultation, in particular that
it is positioned within the Climate Change Plan and the Energy Strategy. This has meant that it
takes overall energy usage as its starting point, bringing together the actions needed on supply and
demand of energy for heat in order to meet emissions reduction objectives. We also welcome the
link with addressing fuel poverty. However, despite its title this consultation focuses almost entirely
on District Heating, therefore greater connection with the content of the SEEP consultation which
covers energy efficiency is necessary.
We welcome the determination to see a step-change in the roll-out of District Heating; and to ensure
that all of Scotland is covered by the strategy. However, we are concerned that the means set out in
the consultation do not give confidence that the ends will be achieved. Specifically:
 there are no national targets proposed for the uptake of district heating which tie into the Energy
Strategy or the Climate Change Plan
 there is no assessment of the total investment needed to implement the plan and where it will
come from.
 it is not evident that the measures outlined will be sufficient to achieve the emissions reduction
outcomes which are required for the Climate Change Plan; nor is an intent to measure and
monitor this in the future mentioned.
The achievement of GHG emissions reductions is dependent on the decarbonisation of the energy
that supplies district heating networks and this is not dealt with in the document; similarly the
decarbonisation of gas supply is not considered as it is a UK government responsibility. Therefore
the proposals can be regarded as a welcome set of steps in the right direction rather than a holistic
overview of how the contribution from district heating and energy efficiency to achieving the
government’s overall outcomes will be achieved.
Local Heat and Energy Efficiency Strategies
FOES supports the proposals for the creation of Local Heat and Energy Efficiency Strategies
(LHEES), including the proposal that local authorities should have a duty to produce and implement
an LHEES as outlined, since creating and implementing the plans effectively rely on fine-grained
local knowledge, buy-in and participation. For this reason there is a need for greater emphasis on
local participation. Consultation with communities, voluntary organisations and the workforce in the
sector should be part of the duty.
We are aware of the resource constraints facing local authorities and are conscious that imposing a
duty on local authorities does not guarantee the achievement of the outcomes desired if they don’t
have the powers, capacities and resources to develop and implement the strategies. The Scottish
Government should commit to putting in place the technical support, the advisory capacity, the
finance and the investment mechanisms needed to enable the success of a locally-driven strategy.
We agree that LHEESs should set local targets for energy efficiency and decarbonisation. These
must be consistent with the targets set out in the draft Climate Change Plan, though targets should
not be interpreted as a cap on local efforts. At present, there is inadequate clarity about the wider,
long-term targets for SEEP and regular milestones along the way, and inadequate detail on the
SEEP delivery model, including budgets and financing mechanisms.
We believe that all public bodies should be under an obligation to contribute where possible to the
implementation of this strategy; perhaps as a specific expectation regarding the Public Sector
Duties under the Climate Change Act.
Making it happen and ensuring a Just Transition1
In order to ensure that rapid growth of district heating is achieved, FoES believes that a plan must
be put in place that can overcome the barriers that have so far limited its development in Scotland.
While the proposals for LHEES address some of those issues, the Scottish Government should also
address the nature and scale of investment needed.
District Heating has the characteristics of the kind of investment which the UK’s capital markets are
bad at funding, having high initial capital costs, though low operational costs, requiring long-term,
patient investors. Much more work is needed to develop the mechanisms for delivering the funding
at a scale and on terms which will ensure delivery of the strategies. We are arguing for a Scottish
National Investment Bank which can raise and direct sufficient investment into district heating,
decarbonisation and energy efficiency 2. Also the case for renewable energy bonds as a mechanism
for investment should be considered.
We welcome the suggestions made in the consultation document concerning implementation of
LHEES, including the powers to compel large users to connect, where it can be shown that this is a
necessary means for ensuring implementation. We are aware that voluntary approaches are not
guaranteed to work and the creation and use of this power sends the necessary signals to large
enterprises in the private and public sector.
1
2
http://www.foe-scotland.org.uk/Just-Transition
http://www.foe-scotland.org.uk/banks
We support the proposals for zoning of areas for district heating roll-out and the creation of
exclusive concessions. However we are also aware that giving a concession does not ensure that it
is used, at least in a timescale necessary for achievement of the emissions reductions which are
aimed at. Therefore we believe that the option of the local authority taking direct responsibility for
implementing district heating programmes should be included; as should the creation of locallyowned not-for-profit trusts. The role of a government-owned energy company (as mooted in the
Energy Strategy) and of local authorities as energy suppliers should be explored. The Scottish
Government should conduct research into the comparative effectiveness of these different delivery
mechanisms in different circumstances to support local decision-making.
While supporting the creation of new powers to underpin the implementation of LHEES, the winning
of public and consumer support is vital; price is therefore a vital factor for successful roll-out, as well
as consumer confidence in the technology. Funding must be in place to help de-carbonised district
heating achieve a cost advantage over other heating methods. In addition there should be
engagement with the workforce and trade unions in the sector about the best ways to expand the
sector and the provision of skills training. Implementation of the strategy will depend on the design
and funding of a training and recruitment programme; for local authority staff initially. Planning
ahead for large-scale expansion of workforce including creating opportunities which can reduce
unemployment in target areas and groups, and achieve gender balance, is crucial to the success of
the strategy.
Governance
It is essential that a national governance body (whether new or an expanded remit for an existing
body) is put in place with a clear oversight function to ensure that the sum of individual LHEES
targets adds up to the overall targets for SEEP and the residential and services sectors in the draft
Climate Change Plan.
Contact:
Mary Church, Head of Campaigns, Friends of the Earth Scotland
e: [email protected] t: 0131 243 2700