Response to Scottish Government consultation on HEETSA

Dear colleague,

Thank you for inviting Consumer Scotland to contribute to the Scottish Government’s consultation for a Heat and Energy Efficiency Technical Suitability Assessment (HEETSA) and to comment on the potential impacts for consumers when identifying the right retrofit measures. As the statutory advocate for energy and heat network consumers in Scotland, we welcome the opportunity to contribute to the further scoping and development of HEETSA and more broadly on the Scottish Government’s ongoing work on the transition to low carbon heating and more energy efficient buildings.

Consumer Scotland recently published a new framework[1] to help policymakers take account of the consumer perspective when developing policies and interventions to address climate change. This framework sets out the key issues for consumers in the transition, as follows:

• Cost: The costs of responding to the climate emergency are distributed fairly
• Convenience: Sustainable products and services are designed in ways that fit easily into consumers’ lives
• Clarity: Consumers understand what they need to do and why
• Confidence: Consumers trust sustainable products and services, have strong protection, and have access to redress

This ‘four Cs’ framework underpins our response to the consultation.

Heating, ventilating, and cooling (HVAC) Scotland’s buildings currently accounts for more than a fifth of Scotland’s annual greenhouse gas emissions[2]. Consumer Scotland is supportive of the introduction of a more tailored retrofit assessment which supports consumers looking to understand what improvements they could make to the thermal efficiency of their home or what alternative non-polluting heating systems they could install. Research carried out by Consumer Scotland in 2023 found that domestic consumers are supportive of taking action to tackle climate change.[3] However, our research also found that consumers in Scotland need more guidance and support to enable them to participate effectively in the energy transition.

Consumer Scotland’s recent investigation highlighted the potential for Energy Performance Certificate’s (EPC) to be powerful tools to improve the energy efficiency and heat decarbonisation of Scotland’s homes.[4] One of the key recommendations in our investigation report was that the Scottish Government should make Energy Performance Certificates clearer and more action-focused, supported by robust quality and enforcement systems. A reformed EPC will help consumers to make better informed choices when installing a new heating system or improving the fabric efficiency of their homes. However, we recognise that a more detailed assessment, alongside technical advice, will better support consumers through this journey.  

Heat and Energy Efficiency Technical Suitability Assessment

The introduction of the proposed Heat and Energy Efficiency Technical Suitability Assessment will be an important step in engaging consumers on the actions they can take to decarbonise their homes, and where they can go to get appropriate support. Consumer Scotland is supportive of more tailored assessments that support households in making energy efficiency improvements. These should be presented in a manner which is easily digestible to property owners and doesn’t require an advanced knowledge of energy efficiency standards in order to facilitate fabric improvements.

Consumer Scotland has not taken a position on the specific technical methodologies, skill requirements or assessors qualifications outlined in the consultation. It is important to emphasise that consumers must have access to a straightforward yet reliable mechanism to ensure that assessors possess the necessary qualifications, skills, and competencies without requiring consumers themselves to have technical expertise. We are keen to engage further with the development of the assessment to ensure that the consumer journey is central to this work.

Consumer Scotland agrees that the quality of energy retrofit advice could be improved to provide more tailored recommendations beyond those of the Energy Performance Certificate by helping households identify the most effective and appropriate measures. In advance of the roll out of the HEESTA we would encourage the Scottish Government to consider how consumers might engage with the assessment, including any support, advice and information that may need to be made available. In particular, we would encourage the Scottish Government to consider how consumers can then take action on the tailored recommendations. It is essential that recommendations are clear, accessible and easy to understand so that consumers can easily understand what action they can take. It is also essential that adequate guidance and support is in place, especially if the HEESTA process is entirely digital or requires technical understanding. We recommend that the process for obtaining a HEETSA is designed with accessibility in mind to ensure that all consumers can engage with both the assessment process and with any recommendations.

Consumer Scotland is broadly supportive of advanced energy efficiency assessments to enable households to make informed and effective improvements. However, while the potential financial impact on social housing providers is a legitimate concern, our primary interest lies in understanding how these costs might ultimately affect consumers particularly social housing tenants. It is therefore important that the Scottish Government engages with relevant bodies in the social housing sector to assess the potential impacts and explore what support may be needed to protect tenants from unintended financial consequences.

For HEESTA to be fully effective, it is essential that consumers have clarity about what actions they need to take, when, and why. While building public understanding and acceptance of the need for change is important, a sole focus on information risks placing too much responsibility on individual consumers. To truly empower consumer action, the Scottish Government must also provide a robust enabling framework that includes accessible consumer finance options, strong protections, and clear routes to redress. Products and services should be designed, marketed, and delivered in ways that highlight their environmental impact or benefit, supported by meaningful and timely information.

Enhancing the population’s climate literacy will help build awareness of climate challenges and solutions, but this must be complemented by systemic support that makes it easier for consumers to act with confidence and without undue financial risk

Next steps

Consumer Scotland is keen to engage with and support the Scottish Government as this work develops. While we have not responded to the substantive questions within the consultation, we would welcome further opportunities to discuss these proposals and the impact that the proposed assessment can have on consumers, as set out above.

Yours faithfully,

Alistair Hill

Head of Energy Transition