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Local Heat and Energy Efficiency Strategy (Lhees)

Argyll and Bute Council · 21 November 2024
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ARGYLL AND BUTE COUNCIL                COUNCIL
DEVELOPMENT AND ECONOMIC GROWTH           21 NOVEMBER 2024 
LOCAL HEAT AND ENERGY EFFICIENCY STRATEGY (LHEES) 
1.0 EXECUTIVE SUMMARY 
1.1  This report advises Members of the outcome of the Local Heat and Energy
Efficiency Strategy (LHEES) public consultation exercise, which had a positive
response both in terms of volume of response and general support for the
strategy.
1.2  Following the public consultation exercise, the LHEES has been revised to
take account of the relevant consultation feedback. This paper presents the
revised Strategy and Delivery Plan to Members to be considered for adoption
by the Council. (Appendix 1 and 2), along with an analysis of the consultation
feedback in Appendix 3. 
RECOMMENDATIONS 
It is recommended that Council:
a) Consider and approve the contents of this report; 
b) Adopt the LHEES Strategy and Delivery Plan included at Appendix 1
and 2.

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ARGYLL AND BUTE COUNCIL                COUNCIL
DEVELOPMENT AND ECONOMIC GROWTH           21 NOVEMBER 2024 
LOCAL HEAT AND ENERGY EFFICIENCY STRATEGY (LHEES) 
2.0 INTRODUCTION 
2.1 The purpose of this report is to provide Members with the revised Argyll and
Bute Local Heat and Energy Efficiency Strategy (LHEES) and Delivery Plan
(Appendix 1 and 2) as well as to provide the outputs from the recent public
consultation (Appendix 3).  
3.0 RECOMMENDATIONS 
It is recommended that Council:
a) Consider and approve the contents of this report; 
b) Adopt the LHEES Strategy and Delivery Plan included at Appendix 1
and 2.  
4.0 DETAIL 
4.1 Background 
The production of an LHEES became a statutory duty for local authorities in
May 2022 through The Local Heat and Energy Efficiency Strategies
(Scotland) Order 2022. This requires local authorities to publish their LHEES
strategy and associated delivery plans. 
The Heat Network Regulations resulting from the Heat Networks (Scotland)
Act 2021 are currently under development. The Council continues to work
closely with the Scottish Government to understand the potential impact of
these regulations on the LHEES.

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4.2 The LHEES addresses key priorities, including improving energy efficiency,
reducing greenhouse gas emissions and tackling fuel poverty. Additionally, it
aims to advocate for a “just transition” to low or no carbon heating for
residential and non-residential buildings while examining the opportunities for
community wealth building presented by the net-zero agenda.
4.3 The report to the Committee on the 26th of September outlines the process of
developing the LHEES and its key components.  (LOCAL HEAT AND
ENERGY EFFICIENCY STRATEGY AND DELIVERY PLAN.pdf (argyll-
bute.gov.uk))
4.4 Stakeholder engagement 
The LHEES has been developed through an engagement process with key
stakeholders. This included delivering two stakeholder events to determine
priorities, and further sessions were held with Argyll and Bute Energy
Efficiency Forum and Climate Change Board. Engagement with electricity
network distributors, such as Scottish and Southern Energy Networks and
Scottish Power Energy Networks, was also undertaken. 
4.5 Public Consultation Exercise
Argyll and Bute Council’s public consultation on the LHEES Strategy and
Delivery Plan ran from the 26th of September to the 13th of October, 2024. The
consultation received 112 responses from individuals as well as submissions
on behalf of groups or organisations. However, the vast majority (97%) of
submissions were from individuals. Appendix 3 outlines the consultation
findings and references any changes made to the draft LHEES to reflect those
findings.
4.6 A variety of approaches were used to ensure the reach of the consultation
was maximised. This included: 
• Informing Registered Social Landlords, the Community Planning Partnership,
the Climate Change Board and  The Energy Efficiency Forum members
• Direct messages to individuals and organisations who had previously
contacted the Council regarding the LHEES. 
• Online promotion, including a dedicated webpage for the LHEES, was set up.
This page was then promoted by the Council’s social media team 
• Emails were also sent out through the Keep in the Loop (KITL) framework.
4.7 The consultation outputs show support for the proposals outlined in the
LHEES, with 69% of answers highlighting agreement or strong agreement
with the LHEES aims (compared to 12% of answers highlighting
disagreement or strong disagreement). The outputs for all questions are
detailed in Appendix 3.

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The main themes that emerged from the consultation exercise were as
follows:
4.8 The cost is too high to enable delivery
Several respondents were sceptical that installing energy-efficiency measures
or decarbonised heating systems would occur, particularly during a Cost-of-
Living Crisis. This viewpoint is expressed nationally, and once the Heat and
Buildings Bill is enacted in 2025, we will have a clearer understanding of how
decarbonising buildings will be enforced and the financial support available.  
4.9 The strategy is too focused on Heat Pumps.
The Scottish Government stated in the Heat and Building Bill consultation
document that “The clean heat systems that are most likely to be adopted are
heat pumps, modern efficient storage heaters and heat networks”. Argyll and
Bute’s LHEES assessed the viability of heat networks, and if the Scottish
Government’s methodology is utilised, there are only five potential heat
networks in Argyll and Bute. Therefore, most households within Argyll and
Bute will not have access to a heat network. To attempt to mitigate this, the
Council has taken on an additional piece of work to assess the viability of very
small-scale heat networks. This work, which the Council is doing in
partnership with Zero Waste Scotland, is mentioned in the LHEES but will be
expanded upon when it is completed. Therefore, electrical heating systems
will be the most viable decarbonised heating source for most households in
Argyll and Bute. These electrical heating systems include all types of heat
pumps and direct electrical heating, including storage heaters, electric boilers
and electric radiators. However, direct electrical heating is more expensive to
run and consequently, heat pumps are more favourable.
Other alternatives are:
4.10  Hydrogen 
We are still awaiting a policy position from the UK and Scottish Governments
regarding their policy on hydrogen. There is a pilot project on the east coast of
Scotland, and some work is being done in Argyll and Bute to determine if the
“town gas” network can support hydrogen. However, as the Scottish
Government acknowledges in the Heat and Buildings Bill consultation,
hydrogen will be used as the exception, not the rule. Additionally, the Scottish
Government acknowledge that although Hydrogen is a potential consideration
for the future, it is not at present.
4.11 Geothermal 
The LHEES strategy stated that one of the actions in the Delivery Plan would
be to explore other potential heat sources. Following the consultation
feedback, the strategy has been amended to explicitly state that this
technology will be explored. Appendix 3 outlines the other actions the
Council will take to address the comments made during the consultation
process.

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4.12  Biomass
Although biomass is not a zero-emissions heating system, it may now be able
to be considered as the Scottish Government’s position on biomass has
softened as it has suspended its banning of biomass in new build properties.
This change of position results from councils like Argyll and Bute lobbying for
this fuel source to be permitted in rural areas. 
4.13  The difficulties of installing measures
This point included the difficulties people faced in engaging installers, having
adequate grid capacity, and having access to impartial advice on
decarbonising. The LHEES has prioritised addressing all these points as it is
acknowledged that these are barriers to decarbonising.
4.14  Next steps 
An interagency LHEES Delivery Group will be established to develop detailed
delivery actions and mechanisms.
4.15 The LHEES process is in its early stage; stakeholders are working to collect,
aggregate and disseminate data to enhance the LHEES. Consequently, there
has been a rapid proliferation of new data streams. The decarbonisation
industry is also undergoing rapid evolution, introducing innovative technical
solutions at an accelerated pace. Additionally, the regulatory and financial
landscape in this policy area is also rapidly changing. For instance, the Heat
in Building Bill and the revised Energy Performance Certificate (EPC)
legislation, both of which will significantly impact the LHEES, are scheduled to
be enacted by the Scottish Parliament in 2025. Consequently, the LHEES will
need to be a flexible document that is regularly updated to align with the
duties outlined in these bills, take account of new technological solutions and
reflect new funding and investment opportunities as they arise.   
5.0 CONCLUSION
5.1 The LHEES consultation process generated a considerable number of
responses (112), more than most councils. The vast majority of responses were
from individuals who supported the aims and priorities outlined in the LHEES.
5.2 The LHEES has been revised to take into account valid comments that were
within the scope of the consultation.  The revised LHEES is being presented for
adoption.  
5.3 Once adopted, the LHEES will be published on the Council's website to fulfil
the statutory duty set out in the Local Heat and Energy Efficiency Strategies
(Scotland) Order 2022.

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6.0  IMPLICATIONS
6.1  Policy – The Local Heat and Energy Efficiency Strategy 2024 sits within the
framework of national policy objectives and local requirements. It relates to
the Council’s Decarbonisation Plan, LDP and Local Outcome Improvement
Plan and will relate to the Community Planning Partnerships Climate Change
Plan. 
6.2 Financial – The Scottish Government provides resources to local authorities
to develop the LHEES strategy and delivery plan and for staff to coordinate
the implementation of the plans. Additional resources would be required to
implement the actions outlined in the LHEES Delivery Plan but further work
will be required to develop any future proposals and costings. 
6.3  Legal - All appropriate legal implications have been taken into consideration.
6.4  HR – None. 
6.5  Fairer Scotland Duty - The Fairer Scotland Duty, Part 1 of the Equality Act
2010, came into force in April 2018. The duty places a legal responsibility on
particular public bodies in Scotland, such as Argyll and Bute Council, to pay
due regard to (actively consider) how they can reduce inequalities of outcome
caused by socioeconomic disadvantage when making strategic decisions and 
how this has been implemented.
6.5.1 Equalities - All activities have complied with all Equal Opportunities/Fairer
Scotland Duty policies and obligations.
6.5.2  Socio-economic Duty - One of the key priorities within the LHEES is to tackle
fuel poverty.
6.5.3  Islands - The LHEES will include priorities and actions that will be delivered
across Argyll and Bute, including the island communities. 
6.6  Climate Change - Strategic priorities and activities will address the net zero
transition agenda. 
6.7  Risk - Buy-in by key partner agencies and stakeholders could be challenging
due to the uncertainty around future funding streams. If Grid infrastructure
works are not undertaken quickly, this may have significant implications for
implementing projects that enable the electrification of heat. 
6.8 Customer Service – None. 
6.9  The Rights of the Child (UNCRC) – None. 
Kirsty Flanagan, Executive Director with responsibility for Development and 
Economic Growth 
Councillor Jim Lynch, Policy Lead for Economic Development, Islands, Rural
Communities and Housing.

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For further information contact: 
Fergus Murray, Head of Development and Economic Growth 
Fergus.Murray@argyll-bute.gov.uk 
Matt Mulderrig, Development Policy and Housing Manager 
Matt.Mulderrig@argyll-bute.gov.uk 
Kirsty Jackson-Stark
Kirsty.Jackson-Stark@argyll-bute.gov.uk 
APPENDICES
Appendix 1 - LHEES Strategy 
Appendix 2 - LHEES Delivery Plan  
Appendix 3 - Summary of Public Consultation