This paper constitutes a response from UNISON
Scotland to the Scottish Executive Fuel Poverty Statement consultation
UNISON is Scotland's largest trade union. It
is also the largest trade union representing staff in the Scottish
utilities directly involved in providing energy. In addition
UNISON Scotland has many members in the NHSiS, local government
and the voluntary sector who deal with the consequences of fuel
poverty on a daily basis.
UNISON has played a significant role in recent
years at both Scottish and UK level in the campaign to eradicate
fuel poverty. We were joint sponsors of the Keeping Scotland
Warm programme, which promoted a domestic energy efficiency
policy for Scotland. We have also jointly sponsored a video
that highlights the startling facts that surround fuel poverty
today in Scotland. We support the revised Keeping Scotland
Warm statement "Fuel Poverty Now".
These facts include 30% of Scottish households
that live in fuel poverty and the nine out of ten homes that
fall below current energy efficiency standards. Only a quarter
of Scotland's homes are adequately heated.
The Scottish Statement
UNISON Scotland welcomes the publication of
the Scottish statement and the requirements on the Scottish
Executive as set out in s88 of the Housing (Scotland) Act 2001.
For far too long the approach to fuel poverty as been dissipated
amongst several departments and agencies.
UNISON Scotland welcomes the acknowledgement
of fuel poverty and the commitment in the Act to ensure, so
far as is reasonably practicable, that persons do not live in
fuel poverty. We do not support the definition of fuel poor
households chosen by the Scottish Executive. By including benefits
the definition has the effect of falsely inflating household
income and ignores the fact that households have little control
over housing costs. UNISON believes that the definition net
of housing costs should be used.
UNISON Scotland has supported the Scottish Executive's
programme of central heating for pensioners and other vulnerable
households and the warm deal. This compliments the investment
programmes initiated by local authorities and housing associations
in their own housing stock.
UNISON does not support the New Housing Partnerships
initiative. In our submission to the Scottish Executive we highlighted
the additional costs and the loss of democratic accountability
by handing over control of public housing to financial institutions.
We argued that the outstanding debt could be taken over by central
government freeing up massive resources from rents to improve
housing stock. The additional cost of NHPs could be used more
effectively in addressing fuel poverty.
Other current programmes are listed in the statement
including affordable warmth and the improvement and repairs
grant system. However, there are few new proposals and we would
wish to see existing programmes strengthened.
There is a welcome recognition in the strategy
of the impact of wider social policy issues and the need to
work in partnership with other agencies. What is missing in
this strategy is the formal co-ordination of initiatives to
enable the more effective use of resources and to ensure that
no household falls between different programmes. In particular
there is a need to improve the NHSiS involvement in this issue.
A Comprehensive Fuel Poverty Strategy
In 2000 UNISON joined with Energy Action Scotland
and Transco to bring together a wide range of experts and interested
bodies to produce recommendations to eliminate fuel poverty
in Scotland. The statement Keeping Scotland Warm (see
attached) has recently been revised and launched at a seminar
in Edinburgh on 21 May 2002. The statement sets out a range
of proposals that include a role for the Scottish Executive
and UK government departments as well as Ofgem and the domestic
The key elements of Keeping Scotland Warm
In a number of formal and informal responses
UNISON Scotland has been highly critical of the role of Ofgem
in this area. We do not believe that price competition alone
is sufficient to assist those in greatest need and the Social
Action Plans have generally been an inadequate response to the
problem. Research sponsored by UNISON has demonstrated that
privatisation has not been the cause of lower electricity prices.
The promotion of competition has inevitably
resulted in all the domestic energy companies in Scotland chasing
high value customers who can pay by direct debit. This is increasingly
at the expense of services to disadvantaged customers. The most
recent example of this has been the wholesale closure of High
Street shops with their easy access to advice and cash payment
systems, firstly by Centrica and more recently by ScottishPower.
A survey by the National Right to Fuel Campaign
confirms that competition has exacerbated long standing inequalities
between certain low income groups and more affluent customers.
The activities of doorstep sales staff has been a significant
problem and the survey concluded that access to competitive
energy markets was associated with access to other related services,
particularly financial services.
UNISON believes that government support for
the mantra of competition needs to be reviewed together with
the Ofgem terms of reference and we have spelt out these concerns
in more detail in our submission on the UK Energy Policy Review.
Without this solutions will always seek to work with "the
grain of the market". What is needed is direct intervention
and incentives to encourage good practice.
UNISON Scotland believes there is much in the
consultation draft to be welcomed and we recognise that this
is the first government at UK and Scottish level to seriously
address this issue. Our main reservations are over the need
for a more co-ordinated and comprehensive approach. Without
such an approach the elimination of fuel poverty may remain
an elusive target.