Open letter - The need for an adjustment for rurality in the new definition of Fuel Poverty

Please join our call for the Scottish Government to reconsider its proposal not to include an adjustment for rurality in the new definition of fuel poverty. Although this open letter has been submitted and responded to we are still seeking supporters as the Bill is now going through Parliament. if you would like to be added to the list of supporters please email your name and attribution to 

The argument is also covered in more detail in an article by our friends at Commonspace:

You can read the Scottish Government's response here.

The need for an adjustment for rurality in the new definition of Fuel Poverty

Open letter to Kevin Stewart, Minister for Local Government, Housing and Planning, the Scottish Government

Dear Mr Stewart,

We, the undersigned, as experts in fuel poverty, energy policy, housing, and related disciplines are writing in response to the Scottish Government’s proposal not to include an adjustment to reflect the higher costs of living (including, but not limited to, energy costs) as part of the new Scottish definition of fuel poverty as set out in the Fuel Poverty (Target, Definition and Strategy) (Scotland) Bill (known as the Warmer Homes Bill).

We note that the Scottish Government has now commissioned three reports, including an authoritative academic panel review of the fuel poverty definition, which have recommended the need for such an adjustment [1,2,3]. We further note that the only two studies to investigate the socio-economic influences on fuel poverty in rural and island Scotland using real (as opposed to modelled) data on household energy expenditure have found the impact of the urban / rural divide to be significantly greater than current statistics suggest, and that the nature of the distributions is notably different across this divide [4,5,6]. We also note that the conclusions from these studies are in line with findings from recent reports commissioned by Citizens Advice Scotland [7,8]. Finally, we note that the continued reliance on energy performance certificates (EPCs) as a driver for policies to address fuel poverty, which only measure heating and lighting amenity, will serve to further disadvantage householders in these areas by continuing to drive ‘fabric first’ interventions to improve building energy efficiency at the expense of more effective, and cost effective, holistic ‘folk first’ interventions [9,10].

The strength of the effect of rurality results from several factors that go beyond the higher energy costs considered by the Scottish Government under the current proposals, including higher overall costs of living, the greater barriers to accessing support services, and the additional costs incurred by both installers and support services operating in these areas [11]. This inequality is also exacerbated by the ability of those households using oil, LPG and solid fuels to buy in fuel supplies (and in larger quantities) during the summer period when prices are lower. This opportunity cannot be afforded by those in the lowest three deciles of income and it is not supported by the current winter fuel payment schedule. In addition, those reliant on oil for their main heating fuel are poorly served by the national fuel poverty statistics in Scotland which rely on a GB oil price underpinning the fuel poverty model rather than a Scottish, or even a rural/island price for oil.

Given the strength of the evidence and the high degree of expert consensus on this issue we call upon the Scottish Government to amend the Bill to include such an adjustment before it is passed. We are strongly of the view that if such an adjustment is not made the Bill, as it stands, will further exacerbate the influence of the urban / rural divide and further disadvantage the fuel poor and otherwise vulnerable households in rural and island Scotland.   

[1] Bramley, G., Fitzpatrick, S., Liddell, C., & Webb, J., 2017. A new definition of fuel poverty in Scotland: A review of recent evidence. Report for the Scottish Government.
[2] Scottish Government, 2016. A Scotland without fuel poverty is a fairer Scotland: Four steps to achieving sustainable, affordable and attainable warmth and energy use for all. Report by the Scottish Fuel Poverty Strategic Working Group, October 2016.
[3] Scottish Government, 2016. An action plan to deliver affordable warmth in rural Scotland. Report by the Scottish Rural Fuel Poverty Taskforce, October 2016.
[4] Mould, R., & Baker, K.J., 2017. Uncovering hidden geographies and socio-economic influences on fuel poverty using household fuel spend data: A meso-scale study in Scotland. Indoor and Built Environment, 0 (0), 1-23, DOI: 10.1177/1420326X17707326.
[5] Baker, K.J., Mould, R., & Restrick, S., 2016. Proiseact Spéird – The Spéird Project: Understanding influences on fuel poverty in rural and island Scotland. Final report for the Eaga Charitable Trust, November 2016. Available at:
[6] Mould, R., Baker, K.J., & Emmanuel, R., 2014. Behind the Definition of Fuel Poverty: Understanding differences between the Fuel Spend of Rural and Urban Homes. Queens Political Review, Vol. II, 2014, Issue 2, pp. 7-24.
[7] Ipsos Mori & Bill Sheldrick, 2018. Speaking up: Understanding Fuel Poverty Support Needs. Report for Citizens Advice Scotland, June 2018. 
[8] Maiden, T., Baker, K.J., & Faulk, A., 2016. Taking the Temperature: Review of Energy Efficiency and Fuel Poverty Programmes in Scotland. Report for Citizens Advice Scotland by CAG Consultants, Glasgow Caledonian University, and the Energy Agency.
[9] Baker, K.J., Mould, R., & Restrick, S., 2018. Rethink fuel poverty as a complex problem. Nature Energy, 2nd July 2018. DOI: Available at: 
[10] Mould, R., & Baker, K.J., 2017. Documenting fuel poverty from the householders’ perspective. Energy Research & Social Science, 31, (2017), pp.21–31.
[11] Citizens Advice Scotland, 2015. Remotely Excluded: Barriers facing Scotland’s rural consumers. Citizens Advice Scotland, September 2015.


Dr Keith Baker, Researcher, School of Engineering and the Built Environment, Glasgow Caledonian University, and Co-founder of the Energy Poverty Research initiative

Scott Restrick, Technical and Training Manager, Energy Action Scotland, and Co-founder of the Energy Poverty Research initiative

Ron Mould, Research student, School of Engineering and the Built Environment, Glasgow Caledonian University, and Co-founder of the Energy Poverty Research initiative

Helen Melone, Research, Information and Project Officer, Energy Action Scotland, and the Energy Poverty Research initiative

Dr Geoff Wood, Pivot Natural Resources, and the Energy Poverty Research initiative

Susan Roaf, Emeritus Professor of Architectural Engineering, Heriot Watt University, Edinburgh

Robert Leslie, Energy Officer, Orkney Housing Association Ltd 

Craig Spence, Chief Executive, Orkney Housing Association Ltd

Amanda Burgauer, Chair, Scottish Rural Action

Kate Macintosh, RIBA

Dr Aimee Ambrose, Centre for Regional Economic and Social Research (CRESR), Sheffield Hallam University

Stacie Cohen, Policy and Strategy Officer, Manchester City Council

Dr Paul Griffiths, FRCR

Dr Kerry Burton, Senior Research Fellow, Glasgow Caledonian University Centre for Climate Justice

Lavinia Steinfort, the Transnational Institute

Dr Andrew Crossland PhD CEng, Energy Storage & Power Systems Specialist