Publications

Citizens Advice Scotland (CAS) believes the Universal Credit (UC) system must change if the benefit is to work for all citizens across Scotland, and the rest of the UK. By ‘work’ CAS means the UC system should not cause financial destitution or debt, should be accessible to everyone and should support people who are in work.

This briefing paper outlines the scale of the challenge to improve the energy performance of Scotland’s housing stock. It presents CAS’ estimate of how much it will cost to raise the energy performance of all homes in Scotland to at least an EPC C by 2040 (EPC B for social sector homes) in line with the Scottish Government’s target under Energy Efficient Scotland (EES).

Citizens Advice Scotland welcomes the opportunity to respond to this consultation. It is important that we recognise the role that all bodies and sectors have to play in achieving the new and ambitious climate change targets that were passed in the Climate Change Bill in September 2019. 

It is, however, imperative that the Scottish Government properly supports public bodies to meet any new duties or roles. It is important that public bodies are able to continue to provide the same (or higher) standard of service to citizens without inadvertently or intentionally passing on the cost of achieving emissions reductions to the very citizens they are trying to support.

In this response, Citizens Advice Scotland lays out our support of the broad aims of the principles within the policy statement, but urge that much more must be done to strengthen consumer protection and ensure that communities are involved in the process in an inclusive, sustainable way that meets their needs. 

Citizens Advice Scotland has called for phone, broadband and pay-TV providers to recognise that vulnerable consumers need extra support in accessing these services.

In a response to a consultation by Ofcom which is seeking to provide guidance to providers on treatment of vulnerable consumers, CAS calls for an inclusive approach which widens the definition of vulnerability to include rurality, and which recognises that consumers can be vulnerable at different times in their lives.

Citizens Advice Scotland (CAS) believes it is more important to get the smart meter rollout right than it is for it to be rushed through to arbitrary deadlines, and we have long been concerned that the 2020 smart meter deadline was so unrealistic that it risked having a negative effect on consumers. In June 2016 we therefore published a report that called for the smart meter rollout to adopt an interim target of 80% smart meter coverage by the end of 2020, with 100% coverage achieved no later than the end of 2025. We reiterated this call in August 2018, and so we welcomed the UK Government’s September 2019 announcement that the smart meter rollout is to be extended to the end of 2024.

This new-found pragmatism provides an opportunity for a review of the targets, incentives and penalties to which energy suppliers will be exposed as the smart meter rollout progresses over the next 5 years. However, it must also be acknowledged that there remain multiple technical barriers to the universal rollout of smart meters, particularly in remote rural areas and for many Scottish households that use traditional electric storage heaters as the primary form of space heating.

These constraints lead CAS to be concerned that consumers reliant on electric heating in Scotland will be among the very last in GB to benefit from the smart meter rollout. Indeed, under current proposals we believe that it would be possible for electricity suppliers to comfortably exceed the proposed post-2020 smart meter targets without a single Scottish consumer with traditional electric heating having benefited from the rollout. This risks placing the costs of maintaining the traditional meter network onto a relatively small customer base, increasing prices for a group of consumers where a majority (52%) already struggle to afford to heat their homes to an acceptable standard.

CAS does not underestimate the significant challenges required to overcome these issues, but we are equally clear that the smart meter policy framework and the regulation of the retail energy market post-2020 must not unfairly burden consumers with additional costs they have no opportunity to avoid. We therefore believe that there may be a need to provide short-term protection for consumers whose ability to access the benefits of smart meters is restricted by the industry's readiness to provide them with suitable metering equipment. We also consider that suppliers could be better encouraged to deliver a market-wide smart meter rollout in all areas of GB if the proposed minimum coverage level were to apply separately in each electricity distribution network area.

While CAS supports proposals to move away from the “all reasonable steps” obligation that currently governs suppliers’ smart meter engagement programs, we are also cautious about the impact of holding suppliers to binding, linear annual targets given the technical barriers referred to above. The Citizens Advice network in Scotland already hears the concerns of consumers who have felt pressured into accepting a smart meter by their energy supplier, and even of instances where attempts to install smart meters have been made by domestic energy supply licence holders that are not the registered supplier at the property concerned. This suggests that while the imposition of installation targets backed by financial penalties for non-compliance may be driving the pace of the smart meter rollout, such targets may adversely impact consumers’ experience of smart meter installation and could jeopardise levels of engagement with the planned transition to a smarter energy future. We believe that suppliers may already be suitably incentivised to encourage their customers to embrace smart meters, and we therefore urge Ofgem to place its post-2020 focus on the enforcement of a high quality customer journey throughout the energy transition.

Citizens Advice Scotland (CAS) welcomes the opportunity to provide evidence to the inquiry. In 2018-19, Scotland’s CAB network provided advice on 311,714 issues related to benefits, representing 44% of all advice given in that year. To further inform our submission, CAS surveyed 65 CAB advisers, representing a wide range of geographical areas, to gain their insight into issues surrounding benefit uptake.

Prices changes during the next regulatory period 2021 – 2027 may have a bearing on paying customers, particularly those on low income. CAS recently conducted research using Fraser of Allander Institute to understand how potential price change scenarios may affect aspects of affordability. Research sought to identify what proportion of Scottish households would be likely to spend more than 3% of income on water and sewerage under four charge scenarios between 2021/22 and 2027/28 (2%, 2.5%, 3% and 3.5%).

CAS welcomes the FCA's commitment to vulnerable consumers and the guidance they have published to help firms understand their obligations.