1. Consultation response
Consumer Scotland is pleased to have the opportunity to engage with this consultation on the draft vision and objectives which will underpin the Rural Delivery Plan. Our views are set out below.
About Us
Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses.
Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:
- To enhance understanding and awareness of consumer issues by strengthening the evidence base
- To serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
- To enable the active participation of consumers in a fairer economy by improving access to information and support
Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, redress and sustainability.
We have a particular focus on three consumer challenges: affordability, climate change mitigation and adaptation, and consumers in vulnerable circumstances.
The Overall Framing of the Plan
Consumer Scotland defines the consumer in its broadest sense, in line with our legislation, to include small businesses with up to 49 employees. As at March 2024, there were over 352,000 small businesses in Scotland providing an estimated 917,000 jobs and contributing 27% of private sector turnover – around £94 billion. These businesses are fundamental to Scotland’s economic growth, prosperity and wellbeing. It is estimated that many small businesses operate in rural areas of Scotland – around 28% of registered small businesses in March 2024.
Consumer Scotland also has a statutory role to consider the needs of both current and future consumers. Many legislative, financial, regulatory and policy decisions are required today, across a range of sectors, that will impact on the outcomes experienced by future generations of consumers. This includes decisions regarding substantial investment in infrastructure, as well as decisions about the goods and services available to consumers across different markets.
Consumers are a vital force for growth, economic prosperity and delivering the transition to net zero in Scotland. Vibrant economic markets require consumer demand, the availability of appropriate and affordable goods and services, and consumer confidence. For this to be achieved, consumers must be treated fairly. They must be well informed about the goods and services they are buying or using, be empowered to make the right choices for their circumstances, be appropriately protected from harm and be able to access redress if something does go wrong.
Reflecting this broad context, Consumer Scotland recognises the potential benefits offered by the new vision for the Rural Delivery Plan “for a vibrant, sustainable, equal and inclusive rural Scotland, with its diverse rural communities thriving across economic, cultural, social and environmental dimensions, feeding, powering, inspiring, providing homes and livelihoods to, and nurturing the wellbeing of current and future generations”.
This framing appears to align well with existing legal provisions regarding wellbeing which are already in place, including provisions relating to the wellbeing of consumers in Scotland. Specifically, we would highlight that the Consumer Scotland Act 2020 provides Consumer Scotland with the function to undertake consumer advocacy and advice with a view to “advancing inclusion, fairness, prosperity and other aspects of wellbeing in Scotland”.
Given the central role of consumers in promoting sustainable consumption and economic growth, we recommend that the Scottish Government should give further consideration as to how consumers might be referenced more directly in this vision. The wellbeing of consumers impacts upon a number of aspects of the plan. When consumers are active participants in the economy, when opportunities for better outcomes for consumers are identified and acted on, and when there is a deep understanding of consumer issues across policy makers, regulators and businesses in Scotland then this has a positive effect across a range of outcomes. We would welcome consideration of how the needs of consumers in rural areas can be best addressed, and aligned with, the plan.
Issues Affecting Consumers in Rural Scotland
A number of key Scottish Government research sources, such as the Rural Dashboard, the Scottish Household Survey and Rural and Islands insights reports, point to the distinctive outcomes, opportunities and experiences of rural consumers. The evidence base particularly highlights a range of pressing issues for rural consumers on the availability and cost of different products and services, including :
- issues with accessing services, in relation to both public and private bodies
- a potential lack of choice of provider across some services due to lower numbers of operators being active in rural areas
- issues due to greater travel times to access retail and other services, which can result in higher costs in relation to food, clothing and transport
- issues around delivery costs for items purchased
- issues around energy costs which can lead to fuel poverty.
Many of these are matters where Consumer Scotland has actively considered how rurality affects the consumer experience. A sample of more detailed examples of these issues are set out below.
In relation to broadband and telecoms, Ofcom’s Connected Nations Report 2024 notes that Scotland remains, by many metrics, the least connected of the four nations. Some 16,000 premises in Scotland cannot access decent broadband from fixed-lines or fixed wireless access and many of these premises are in rural areas. Scotland also has the lowest level of full fibre residential access. In relation to mobile services, although coverage is improving, Scotland has the lowest 4G coverage across the nations and the highest percentage of “not spots” where services cannot be obtained. Our work on the switch from traditional landlines to digital internet based calling (VOIP) has also highlighted that there are specific risks to landline consumers in rural Scotland. This is because, without additional backup, VOIP services will not operate in the event of a power cut. Many rural areas experience more frequent, or longer lasting, power cuts, and this combined with generally poorer levels of mobile coverage, can put consumers at risk. In our submissions to Ofcom and others we have noted the importance of developing and maintaining robust infrastructure across multiple services to protect the interests of rural consumers.
In relation to access to cash and to financial services, we have also addressed the specific rural aspects of this issue. Beng required to travel further to access cash, or to find businesses who accept it, can cause additional costs for consumers and reduce choice. Reduction in physical banking services can also result in greater travel distances, and difficulty in accessing face to face services for those consumers who prefer to access these or who have difficulty in accessing or using digital services. These issues are more likely to be prevalent in rural areas.
We are currently carrying out research into the experience of disabled consumes who live in rural Scotland and access to transport has emerged as key factor which can either enable or reduce access to a range of other services, including retail, leisure, health and social care and education services and employment opportunities. A lack of affordable access to public transport can reduce opportunities for those who do not have access to a car. Those who are reliant on car travel are likely to experience higher fuel prices, placing more pressure on household budgets.
In relation to housing, our work suggests that private sector tenants in rural area often report being happier with their property. However, relatively higher numbers of tenants report struggling to find a property to rent. Other research in this area has highlighted issues around the supply of affordable housing and the energy efficiency (and associated fuel costs) of housing in rural areas.
Developing Indicators and Delivery Measures
These issues illustrate the unique challenges and opportunities experienced by consumers in rural Scotland. Given the discussion above, we support the inclusion in the plan of specific objectives in relation to housing, transport, connectivity and access to services. We would encourage the development of indicators, and delivery measures, that take account of the experiences of consumers in rural Scotland, who will often have similar challenges (especially in relation to cost and accessibility) across a wider range of consumer markets.
It will be important that this work strengthens measurement of the consumer experience in Scotland, to ensure that consumers are properly taken account of in decision-making. There is no mention of ‘consumer’ within any of the existing indicators. We recommend that the Scottish Government gives further consideration on how to develop indicators which measure broad consumer experiences, such as indicators that assess, for example:
- whether people feel able to influence or shape the goods and services that they use
- the extent to which people understand their rights as consumers
- whether people feel well informed when taking decisions about whether to buy or
- use particular goods or services
- how consumers take sustainability into account in their decision making; and how they are informed or supported to do so
- where consumers may have experienced detriment or harm
- which consumers may be more likely to be in vulnerable circumstances and what is
- the nature of this vulnerability
- overall consumer confidence.
Consumer Scotland is currently scoping the content and data requirements of a new Consumer Welfare Report for Scotland, which we have a statutory duty to publish every three years. We would be pleased to work with the Scottish Government to identify how the measures and data sources used to inform the Consumer Welfare Report might also support a new set of consumer-focused indicators within the National Performance Framework.
Finally, in relation to the delivery of public services, the Consumer Scotland Act 2020 places a duty on named public bodies in Scotland to have regard to the impact of strategic decisions on consumers; and to the desirability of reducing harm to consumers when making decisions of a strategic nature. Aligning the plan with the requirements of the Act will be important to help support public bodies take a coherent, joined up approach delivering public services and improve consumer wellbeing in a clear, focused way. Further guidance on the implementation of the duty is available on our website.
We would be happy to engage further as development of the plan progresses.
Yours sincerely
Douglas White