Running Public Consultation events: Heat and Energy Efficiency Strategies and Regulation of District Heating

Mags Tingey, Dave Hawkey, Ruth Bush and Jan Webb – Heat and the City Team researchers (University of Edinburgh), give their views on the Consultation on Heat & Energy Efficiency Strategies, and Regulation of District Heating.

We’ve been researching sustainable heat and local energy systems in Europe for eight years. As social science researchers, we strive to develop an objective view point, using evidence to inform our statements. Our data is derived from expert interviews, social surveys, ethnography and documentary analysis; hence we work closely with practitioners from across Scotland and the UK, as well as Denmark and Germany. Over the years, this has helped us gain a relatively well informed understanding on peoples’ thinking in the sector.

But when we were asked by Scottish Government to facilitate two consultation events around an area of policy so close to our research, we were intrigued to see how energy practitioners from across Scotland would react to these new, and potentially radical, proposals.

Our role in organising the consultation events continues our contribution to developing the proposed policy and regulatory framework. We have been members of the successive working groups and expert commissions which have fed in to the development of Scottish heat policy and the content of the consultation document. We also convened a series of workshops for the Scottish Heat Network Partnership (HNP) Practitioner Group between 2014 and 2016 on behalf of Scottish Government.

The proposals in brief:

The consultation concerned a high level policy scoping document, and sought views on a potential scenario for two related proposals:

  1. Statutory heat and energy efficiency planning at local government area level
  2. Regulation of district heating

Both of these areas would be significant new developments for Scottish Government and Local Authorities.

The proposals build on a number of policy developments, notably, Scotland’s new Energy Strategy – one of the 3 themes is ‘a smarter model of local energy provision’ (Scottish Government 2017). In addition, in 2015 energy efficiency was declared a National Infrastructure Priority in Scotland, the related Scottish Government Heat Policy Statement was published, and Scotland’s Energy Efficiency Programme was announced (Scottish Government, 2015).

In this blog we talk about views on the proposal for a statutory duty to be placed on local authorities to develop local heat and energy efficiency strategies.

Should a statutory duty be placed on Scottish local authorities to develop and implement local heat & energy efficiency strategies?

Some local authorities have already developed sustainable energy action plans for their areas. New statutory plans however, would likely involve more direct participation of Scottish government (for example, in setting out common socio-economic assessment methodologies to be used). The consultation also suggests that such strategies could identify zones within which support for specific low carbon heat technologies would be targeted.

Most consultation participants saw this proposal as something of a natural step for local authorities to be tasked with a role in planning and implementing area-based heat decarbonisation and energy efficiency. Existing climate and housing duties mean most local authorities have already done some relevant work. The Climate Change Act 2009 for instance, places duties of Scottish public bodies to contribute to emissions reduction targets. Local authorities also have a longer history of energy efficiency interventions, dating back at least to the Home Energy Conservation Act in the 1990s. More recently they’ve been involved in delivery of area-based Scottish housing energy efficiency programmes.

Equally Scottish local authorities are responsible for housing strategies, planning, economic development, and many have significant estates.

All of these interact with energy infrastructure and carbon emissions at locality scale, especially in buildings and transport.

Varied views and perspectives on a number of issues

A broad consensus on the value of local heat and energy efficiency strategies was however, accompanied by a variety of views about the details, notably:

  1. The most appropriate scale at which plans should be developed. Should they be produced by every local authority, or at regional scale with local authorities working together? Most participants suggested it would not be the most efficient use of resources to develop one strategy for every one of the 32 local authorities. But no clear consensus emerged around an alternative model. Some looked to regional approaches, while there was also interest in a publicly owned Scottish Energy Company, mooted in the main Energy Strategy consultation document , as a vehicle for developing and implementing strategies. The questions intersect with questions of resourcing, support, skills and expertise which were raised by many.


  1. Balancing heat decarbonisation on the one hand and energy efficiency on the other. Should the eventual policy prioritise integrated local heat and energy efficiency, with both aspects considered together? Or should there be a greater focus on energy efficiency than heat decarbonisation? There were views in support of both approaches.


  1. Some participants identified a conflict between ending fuel poverty and meeting decarbonisation How will both objectives be met when natural gas is calculated to be cheaper than renewable sources of heat but is not lowest carbon?


  1. Other participants focussed on what they identified as a related conflict between developing area based solutions and targeting fuel poverty. Will it prove difficult to link an area based scheme with other domestic (non fuel poor), and non-domestic, buildings in an area based approach?

Overall consensus on the importance of the proposals

Whatever participants’ views on the detail of local strategic planning, it was seen as critical, alongside district heating regulation, to meeting both Scotland’s new energy strategy and climate change targets. Local energy planning and district heating regulation have both been key to development in other European countries including Denmark, Norway and Sweden.

The need for greater public debate

In Scotland public debate on these issues has so far been within distinct cross-sector interest groups.

And whilst there seems to be an emerging consensus on many fundamental points in the consultation across energy, housing and public service practitioners in Scotland, what about civil society? Many communities of practice, and communities of place, (think small business owners, major local employers, local homeowners and renters, students, educators…the list goes on), surely will also need the opportunity to be involved in a public debate?

The potential gains are high – with more affordable and sustainable energy for households, businesses and public sector. In the words of Tom Burns, first Professor of Sociology at Edinburgh University, “It is the business of sociologists to conduct a critical debate with the public about its equipment of social institutions” (Burns’ 1965 Inaugural Lecture Sociological Explanation).

Taking heed of Burns means taking seriously that these discussions go beyond distinct cross-sector interest groups, and that an informed public debate is developed.

Some of the proposals discussed within the consultation represent a significant change from the status quo. How would people feel about local and national governments taking a more proactive role in energy provision and efficiency within buildings?

The draft Climate Change Plan proposes ambitious targets for low carbon heat (by 2032, 80% of domestic heat and 94% of services). Achieving these may involve far more disruption to daily life than the decarbonisation of electricity has so far. Such innovation is likely to require far more extensive public debate to build enduring support for interventions. Local heat and energy efficiency strategies could be a vehicle for that debate if structured appropriately.

Too early in policy development for conclusions

It is difficult to draw conclusions on the eventual form of policy, legislation and regulation. Not only is Scottish Government at a ‘policy scoping’ stage, but there will also be views submitted to the consultation that were not represented at the events we ran.

Further consultations and proposals will address the detail, so if you missed the 18th April deadline, there will be plenty of opportunity to contribute.

Feedback from the events will be published with the Scottish Government response to the consultation.

The consultation in full is available at:

Who’s who?

Professor Jan Webb  served as a member of the Short life Working Group on Regulation of District Heating, technical adviser to the Special Working Group on Regulation, and member of the Expert Commission on District Heating and DH Loan Fund Advisory Panel.

Dr Ruth Bush served as a technical advisor to the Special Working Group on Regulation and is now postdoctoral research fellow evaluating Scotland’s Energy Efficiency pilot Programme.

Dr Dave Hawkey served as facilitator for the Short life Working Group on Regulation of District Heating and co-convenor of the Scottish Heat Network Partnership (HNP) Practitioner Group. He was recently interviewed on You and Yours BBC radio 4 programme about district heating regulation and consumer protection. Listen to the broadcast on 28 April here .

Ms Mags Tingey served as co-convenor of the Scottish Heat Network Partnership (HNP) Practitioner Group.

Our own independent consultation response can be viewed here:

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