SFHA responds to draft Heat in Buildings Strategy Consultation

The Scottish Federation of Housing Associations (SFHA) has responded to the Scottish Government’s consultation on its Draft Heat in Buildings Strategy by saying that while it welcomes the steps being taken to address climate change and fuel poverty, the strategy lacks both technical and funding detail.

SFHA’s response was informed by recent input from members, including the federation’s forthcoming research with Changeworks on EESSH2, its report on development costs, member survey results, and previous roundtable discussions. SFHA found that its members remain concerned about delivering a just transition to net zero and further funding is required in order to make sure that tenants do not bear the brunt of additional measures.

SFHA said that social housing sector will play a key role in the design and delivery of the policies outlined in the strategy. The federation added that the creation of the Zero Emissions Social Housing Taskforce (ZEST), which brings together key strategic organisations and practitioners with experience of delivering decarbonisation projects in the social sector to drive progress towards the aim of zero emissions housing and is co-chaired by SFHA’s CEO Sally Thomas, is an important first step in this process. SFHA expects ZEST to provide further recommendations which will feed into the final strategy.

SFHA’s response has highlighted the following key points for the social sector:

• Delivery challenges: The current pathway to 2045 lacks detail on both the technical and financial delivery framework needed to achieve the proposed targets. The social housing sector needs greater certainty to assist long-term planning.
• Funding for the social sector: If we are to ensure a just transition, and protect those on the lowest incomes from bearing the costs of measures (both capital and operational), social landlords need additional grant funding to deliver the required improvements and support tenants in the process. SFHA is therefore proposing the Scottish Government establishes the following:

1. A multi-year grant fund for social landlords, which distributes funds fairly across the social sector, to help alleviate fuel poverty and support those least able to pay. This should cover at least 20% of the costs of all ‘no or low regret’ strategic measures, including fabric upgrades. 
2. An additional flexible fund to cover up to 50% of the costs of innovation and demonstration projects over the next 5 years, including solutions for hard-to-treat and multi-tenure properties. 
3. An emergency redress fund for social landlords and their tenants, to protect those on low incomes from being negatively impacted by the rollout of new technologies and the transition to net zero. 

• Addressing fuel poverty: Climate change policies and targets need to be aligned with the forthcoming Fuel Poverty Strategy. SFHA members want to ensure investment decisions are in the best interest of their tenants, however, a just transition to net zero will require further actions to address all four drivers of fuel poverty.
• Community engagement: As trusted community anchors, social landlords will play a key role communicating with tenants and engaging them in the transition. However, engagement activity can be resource intensive, and we would like to see further financial support made available to sustain this work.
• Remote and rural communities: There are concerns about both the capital and ongoing maintenance costs of zero emission technologies and access to qualified contractors in remote and rural areas. The introduction of PAS2030/35 standards could also put local supply chains and delivery programmes at risk. The Scottish Government should consider the recent report by Energy Action Scotland on this issue and respond to its recommendations.

SFHA Chief Executive Sally Thomas said: “We welcome the steps the Scottish Government is taking to address climate change and fuel poverty, however, it is clear from our members that they have concerns that must be addressed. The strategy is lacking both technical and funding detail and both are vital in order to provide certainty for social landlords and to assist long-term planning.

“Climate change policies and targets must be aligned with the forthcoming Fuel Poverty Strategy, and if we are to ensure a just transition and protect those on the lowest incomes from bearing the costs of future measures, social landlords need additional grant funding to deliver the required improvements and support tenants in the process.

“It’s vital that the social housing sector plays a key role in the design and delivery of the policies outlined in the strategy, so I look forward to representing members’ views as part of the Zero Emissions Social Housing Taskforce and to working with stakeholders and the next Scottish Government in order to help meet Scotland’s climate change targets and end fuel poverty.”

SFHA’s full submission also contains more detailed responses to the consultation questions and can be accessed here: