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CAS is enthusiastic about the potential for the devolution of winter heating benefits to drive a meaningful improvement in the rates and lived experience of fuel poverty in Scotland. Done well, devolution of Cold Weather Payments (CWPs) and the Winter Fuel Payment (WFP), taken alongside the assistance provided by the Warm Home Discount (WHD) scheme, the Scottish Government’s fuel poverty and energy efficiency programmes, and additional support for vulnerable households such as the Child Winter Heating Assistance, could create a coherent package of measures which work together more effectively to reduce inequality and improve the health and wellbeing of citizens most vulnerable to the effects of living in a cold home.

We agree that reforms to the existing CWP scheme could deliver greater consumer benefits than the scheme that currently exists. However, we do not agree that the Scottish Government’s proposals for Low Income Winter Heating Assistance (LIWHA) achieve this. Indeed, we are concerned that for many consumers, LIWHA will often make fuel poverty, and in particular extreme fuel poverty, worse. Evidence also strongly suggests that in a cold winter, LIWHA is likely to prove prejudicial to the health of many vulnerable low income households. We are extremely concerned about the negative consumer outcomes this will deliver, including the impact on winter mortality. CAS cannot support a policy that holds significant potential to increase inequality and endanger the health and wellbeing of consumers in Scotland, and as a result we cannot support the Scottish Government’s proposals for LIWHA in their current form. We are however mindful of the tight deadlines to which the Scottish Government is working to deliver the devolution of CWPs before the end of 2022. We therefore propose a practical series of evidence-led actions that we believe would safely deliver a Minimum Viable Product to the required timeframes which significantly improves on the current CWP scheme and to which future improvements can be made as time and resources allow