UKIFDA Responds to Scottish Energy Efficiency Consultation

29th April 2020

The trade association for the liquid fuels distribution industry, UK and Ireland Fuel Distributors Association (UKIFDA) has urged the Scottish Government to consider the 135,000 households in Scotland who use oil to heat their homes when setting energy policy in its response to the recent ‘Energy Efficient Scotland: Improving energy efficiency in owner occupied homes’ consultation.

Proposals outlined in the government consultation which closed earlier this month include the introduction of a legally binding standard to ensure all homes in Scotland meet Energy Performance Certificate (EPC) rating C at point of sale or major renovation, from 2024.

UKIFDA Chief Executive, Guy Pulham comments: “In submitting our views to this consultation by the Scottish Government, we expressed our support for the proposals to improve the fabric of homes and improve energy efficiency and we agree EPC Band C is a realistic target. It is important though that this must be rolled out in a way which does not adversely affect owner occupiers who are already struggling with household costs. Energy efficiency improvements must not be pursued at the cost of making housing unaffordable for people and put added burden on those currently in fuel poverty. The focus must be on providing tailored support, including financial, and advice on the most suitable technology available to households.

“We agree that new homes should be first to adapt new technologies given the fabric of the building allows for a range of solutions but off gas grid homes are not the easy low hanging fruit that many seem to suggest. The very specific nature of the housing stock that our UKIFDA members serve – generally larger, older homes, in rural locations with poorer than average insulation means they are difficult to adapt to new technologies such as heat pumps and are perfectly suited to new drop in liquid biofuels.

“The design of these houses (and this includes a very high proportion of farmhouses and buildings) is such that retrofitting heat pumps will require a huge capital expenditure to improve the insulation of the properties. If this work is not carried out, the running costs of any form of heat pump would be prohibitive.

“A further challenge here is that the demographics mean that many of the owners are cash poor and asset rich (pensioners, farmers etc) and they will find it very difficult to raise the required capital to undertake major refurbishment of these homes. With the introduction of biofuels as a replacement to heating oil it would mean off grid households would not need such a large capital investment to improve the energy performance of their homes”

In the run up to this consultation being published, UKIFDA has been lobbying the Scottish Government to consider liquid biofuels as part of any energy strategy and is currently working with other industry trade associations OFTEC and the Tank Storage Association on the introduction of a low carbon liquid fuel to replace heating oil.

Guy Pulham adds: “To ensure that the whole industry can invest and implement engineering advancements such as biofuels, we believe government should outline the energy efficiency plans in 2020 for implementation.”

“We also believe it is also important that once an Energy Efficiency standard is in place it should be subject to periodic review, where it can change with improvements such as technology, innovation, fuel prices and carbon emissions. In the longer term where it can be assumed that energy efficiency will improve over time, improved EPC targets could be then introduced.

“Ultimately, we would like policy-makers to recognise the positive contribution that evolving liquid fuels can make to an economically and socially fair energy transition. It is crucial to maintain a varied energy mix and a free choice of technologies by consumers to alleviate fuel poverty. By focussing on the consumer and meeting their individual needs, we can meet both the Net Zero targets and do so in a realistic, supportive fashion.”

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