Energy Consumers Network
Note of Meeting 7
Date: Tuesday May 13th
Location: Consumer Scotland offices, Edinburgh, and online
Attendees:
Chair - Lewis Shand Smith
Advice Direct Scotland - Conor Forbes
Age Scotland - Lyndsay Clelland
Changeworks - Laura Webb/Morven Masterton
Community Energy Scotland - Jenni Marchant
Citizens Advice Scotland - Matthew Lee
Consumer Scotland - Douglas White, Christopher Jones, Alastair Wilcox, Diarmuid Cowan
Energy Saving Trust - Beth Mukushi
Energy Action Scotland - Frazer Scott
Local Energy Scotland - Laura Campbell
Scottish Federation of Housing Associations - Cassandra Dove
Scottish Government, Community Energy - Emma Shephard
Trust Alliance Group/Energy Ombudsman - Craig Wilson
Ofgem (Observer) - Adam Cochrane-Williams
Secretariat, Consumer Scotland - Andrew Faulk
Apologies
Development Trusts Association Scotland - Pauline Smith Energy Action Scotland - Frazer Scott Foundation Scotland - Rachel Searle
Fuel Bank Foundation - Matt Cole The Wise Group - Suzanne McWilliams
Welcome and introductions
1. The Chair welcomed members to the meeting.
Notes of last meeting
2. The notes were agreed without changes.
Chair’s update
3. The Green Heat Finance Task Force had produced its second report, on area-based approaches to energy efficiency and low carbon heating. The report had emphasised the need for policy certainty, to give corresponding, long term confidence to business and thereby encourage investment. Linked, the report emphasises that lack of confidence around delivery models, rather than lack of capital, is the key barrier delivery.
4. A seminar had also explored leading practice from elsewhere in relation to finance and delivery. This had included an Irish one-stop shop, co-financed by government and energy industry. The initiative includes similar information, advice and grants provision to that available in Scotland, but also extends to bespoke advice and helping households find contractors. Further, part of the grant can be spent on associated, non-energy works.
5. The Chair had also attended a meeting with the First Minister and some SEAB members, including Consumer Scotland, on zonal pricing. As covered in the media, electricity generators are not in favour of the proposals.
6. The Chair and Consumer Scotland representatives had put forward the consumer perspective. Electricity prices in GB are very high by comparison with those elsewhere, and this has two impacts:
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- Firstly, electricity bills contribute significant to fuel poverty - electricity accounts for just over half of a typical dual fuel bill as defined by Ofgem
- Secondly, electricity prices undermine the case for consumers to install electrically powered, low carbon heating
7. There is therefore wide agreement on the need for lower electricity prices, and that the current situation is not sustainable. There are indications that zonal pricing could deliver lower prices, especially in Scotland, although the industry view is that the benefits may be overstated if investment costs rise.
8. A presentation on electricity market reform and zonal pricing was delivered immediately after the meeting, and slides are attached.
Member updates
9. All members highlighted continuing concerns around the Radio Teleswitch Service (RTS) meter replacement process, which are grouped together below.
10. CAS
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- Continuing previously reported trends, energy costs and energy debt remain key issues for clients, with 9,900 energy specific cases over the three months January – March
- Also seeing repeat clients for whom advisers are unable to provide assistance as clients have reach the limits in terms of fuel vouchers or benefit credit
11. Consumer Scotland
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- Attended the first meeting of the Heat in Buildings Strategic Advisory Group since the announcement of the revised approach
- On electricity networks, hosted two short term secondments from NESO, and forthcoming paper on REMA and Locational Marginal Pricing
- The Heat Network consumer advice function is now live
- Forthcoming publications include an updated energy affordability tracker, and a rapid evidence review of future retail issues. The latter explores issues and opportunities, particularly for low income or disadvantaged consumers around changes through the low carbon transition
- Continuing work on Electric Vehicles with Transport Scotland
- Contributing to UK group on Ofgem review
12. Changeworks
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- Looking at ways to improve efficiency of delivery in area-based way
- As raised in the SEIC report and subsequently, issues with lack of multi-year funding are again a significant concern, both with managing new projects and auditing as 24-25 projects are closed - other members echoed and reinforced this issue. Additionally, the administrative burden of some short term projects is large enough that Changeworks has had to pull back from them, even where they would be beneficial to clients
- Highlighted the national tenant energy service being delivered for housing association tenants, through a strategic partnership with SFHA. The service covers in particular gaps around post-installation advice, including for those moving on to heat networks
13. Ombudsman Services
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- Cases are falling as energy prices fall, but concerns remain that only a fraction of those eligible for support seek it
- Ombudsman income and adviser headcount is directly related to caseload, and so falling caseload means a reduction in advisers and capacity
- Decisions are currently about 65-70% in favour of consumers. This is down from a peak of around 80%, indicating that supplier performance is improving, albeit to a limited extent. There are still concerns around the consistency of signposting from suppliers to the Ombudsman, however. Further, Ombudsman remedies are not always implemented, resulting in the need for follow up work
- The Ombudsman is closely involved in the Ofgem review, and highlighted that it is important that revisions work together, especially around any potential expansion in the scope of energy products or services to be covered. There is also discussion about a potential reduction in the time before Ombudsman can take up a case
- The Ombudsman also has a role in relation to Heat Networks. However, as the regulations are yet to be implemented, there remains a lack of clarity in some areas, for example backbilling. There is a need for awareness raising among heat network consumers
14. SHFA
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- Trying to improve relationships between suppliers and Housing Associations, and arranged a conference to explore issues, including delays to meter replacements, in March. Key concern remains that void properties, by definition, do not have a related consumer and hence are low priority, even though the tenant waiting to move in is likely to be in vulnerable circumstances.
- RTS meter replacements are a linked and sometimes overlapping concern, also discussed at the conference
- Waiting for the Social Housing Net Zero Standard to be finalised. General view is that timescales might shift, but the overall aims are likely to remain similar
- Funding remains a key concern in relation to delivery of both fabric and heating investments
- Also now engaging more on heat networks
15. Age Scotland
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- 1000 energy advice instances delivered January – March, with central focus on affordability, possibly driven by changes to Winter Fuel Payment. Responding through
- Provision of food and fuel vouchers; some issues digitally excluded people unable to redeem on line only fuel vouchers; and
- Access to warm packs (e.g. electric blankets)
- Also looking at older people awareness and experience of accessing support. Awareness of EPCs and the information in them is very low
- Continuing to promote PSR, such as through work with SP Energy Networks.
- 1000 energy advice instances delivered January – March, with central focus on affordability, possibly driven by changes to Winter Fuel Payment. Responding through
16. Advice Direct Scotland
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- Consumer contacts indicated continuing affordability challenges - still getting enquiries about Fuel Insecurity Fund support
- Energy is part of a wider picture of an increase in affordability / bill increase enquiries, including other utilities as well as council tax. This is leading to an consequent increase in demand for ADS welfare advice. Energy is often the first trigger, with conversations then identifying wider debt
- Linked, increase in self-disconnection
- Conversations with suppliers on debt write off; some more open to this than others
- Heat Networks advice started April. Not many enquiries as yet, and most are about billing, but already an issue around transparency. This is compounded by some heat network suppliers outsource billing, also leaning to a lack of accountability
17. EST
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- Over the 24-25 financial year, a total of 95,000 unique households received energy advice, with 51,000 of these households likely to have been in fuel poverty
- 9,000 referrals were made to Warmer Homes Scotland
- Reviews have flagged issues around the customer experience of grant and loan schemes and these are now being addressed
Radio Teleswitch (RTS) Phaseout
18. Ofgem advised that, at most recent supplier update, 392,000 RTS meters remain in place, 132,000 of which are in Scotland. Suppliers are currently replacing around 1,000 meters a day; the rate of replacement is still increasing. Supplier can replace RTS meters with a standard smart meter, pre-configured smart meter (for example, set to E7 or E10), or a meter linked to a comms hub, which uses 4G mobile signal.
19. However, it seems extremely unlikely that all will be replaced by the end of June phaseout date. Ofgem share the frustration expressed by members, and is consulting on changes which mean suppliers will be in breach of licence if RTS meters still in place. The switch off plan is being coordinated by an industry task force, with weekly discussions on both meter replacement and on mitigation.
20. Most ECN members reported both an increase in direct contacts with consumers around the RTS meter replacement programme. Concerns raised by consumers include:
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- What might happen after the switch off, in terms of both possible interruption to supplies and costs under subsequent arrangements and inability to arrange meter replacement appointments, particularly with Scottish Power and Ovo, as the main RTS suppliers in Scotland
- Questions around smart meters more generally, including whether consumers have to accept one as a replacement for RTS meters
- Support for consumers associated with remedial work necessary to change meters
21. Given this situation, members asked if any changes to the timing of the switch-off were proposed. Ofgem said that, under current plans, the switch off will be risk based, with the area with fewest remaining meters switched off first, both to understand what happens in practice, and to allow a geographic concentration of resource to respond to issues. The Highlands and Islands area will probably be towards the end of the sequence, especially as responding to issues is likely to be more difficult given travel.
22. Suppliers are also in discussion with the BBC about possible extension of the signal beyond September, but that any such extension is likely to be very short. Ofgem will check whether the public sector is party to those discussions.
23. Members also asked about possible sanctions on supplier. Ofgem advised that while compliance and enforcement action can be taken, but acknowledged that by then detriment will already have happened, as licence conditions don’t allow for pre-emptive action.
24. Members raised further issues which Ofgem will consider around:
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- The mitigation actions being put in place, and the timescale for developing and publicising these
- Whether there is a requirement for suppliers to provide alternative heating
25. There is currently a monthly check in call between Ofgem and consumer groups. It is possible this will move to fortnightly given the approaching the deadline. Ofgem also assured members than the group will continue to meet after the deadline, given the issue will not be resolved by then.
Community Energy
26. Local Energy Scotland
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- Following contract renewable, will continue to manage CARES scheme on behalf of the Scottish Government, with an advisory board including Community Energy Scotland, Development Trusts Association Scotland, and Regen. CARES provides advice to communities seeking to develop their own renewable energy resources, as well as to those engaging with suppliers on community benefit or shared ownership packages.
- 121 community buildings were supported to take action in the last round, 105 of which including low carbon heating.
- The previous community heat programme which supported groups of households to explore communal solutions (for example, very small scale heat networks) will not be continued, but an evaluation is underway to ensure lessons from experience are recorded
- The register of community benefits is being updated, including where information is available on how funds have been used
27. Community Energy Scotland
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- Looking at shared ownership and also at the potential for local markets for community generated electricity; regulations are currently a barrier to this
- Recently responded in depth to the SG consultation on Community Benefits. Key points are that community benefits:
- should be mandatory and higher, and
- communities should decides how to use the funds
28. Scottish Government
- As discussed at the September 2024 and January 2025 meetings, the Scottish Government has asked the ECN to expand its remit to include discussion of community energy issues.
- Emma Shephard, from the Community Energy Team at the Scottish Government, outlined the background to the request, and the issues on which they would welcome the input of the ECN. The approach to community benefits is likely to be the most immediate area for discussion. Currently, the quantum of community benefit funding is in excess of £30m annually, and this is expected to rise considerably. Grant systems and capacity support for communities among other areas are likely to be in scope.
31. ECN members agreed that community benefits would be a topic to which they could add value, including by exploring synergies and tensions between the affordability and other issues facing energy consumers and the use of community benefit funds. A first meeting on this topic will be organised in the coming weeks.
32. Discussion on community generation is likely to follow in the late summer / autumn.