Draft Winter Heating Assistance (Low Income) (Scotland) Regulations 2022: scrutiny report
The Scottish Commission on Social Security's scrutiny report on the draft Winter Heating Assistance (Low Income) (Scotland) Regulations 2022
The Scottish Commission on Social Security (SCoSS) has completed pre-legislative scrutiny of the draft Winter Heating Assistance (Low Income) (Scotland) Regulations 2022. These create a new form of Scottish social security assistance, Low Income Winter Heating Assistance (LIWHA), which will replace the UK Cold Weather Payment (CWP).
It is the Commission’s view that the regulations generally meet the policy intent to mitigate some of the impact of additional domestic heating costs in winter by providing targeted, reliable financial support to households with low incomes that is not dependent on the weather. In doing so, they represent a contribution towards fulfilment of the principle that the Scottish social security system is to contribute to reducing poverty in Scotland. However, LIWHA can only ever represent a contribution to supporting a particular group of people with heating costs. Even since the draft Regulations were referred to SCoSS the scale of increase in heating costs has been significant; consequently, the introduction of LIWHA is even more timely, yet will achieve less of a reduction in fuel poverty than originally envisaged. Further, for people on low incomes in the coldest parts of Scotland, the shift from cold weather contingent payments to a single payment per winter could represent a considerable reduction in support. For a small but significant group of people, therefore, the change from CWP to LIWHA will increase exposure to poverty and cannot be described as an example of continuous improvement in a way that puts the needs of those who require assistance first.
The need to launch LIWHA for winter 2022-23 means there is limited scope for change to the recommendations. However, the commitment to continuous improvement means there is a clear need for a review of how the Scottish social security system provides support with winter energy costs. The recommendations in this report should be given due consideration at that point, if they cannot be implemented for the coming winter.