FBF supports the lowering of the obligation threshold – and in particular from 2023/4 – since this is something we have campaigned on previously. We also support the value of a Broader or Core payment increasing to £150 in line with England and Wales.
We do, however, have material concerns about the impact on fuel poor customers in Scotland who risk being less able to access WHD Broader Group help due to individual supplier schemes being over-subscribed, given the higher percentage of households who will meet the eligibility criteria. This may be a concern for those customers supplied by one the original legacy energy companies who have a higher proportion of customers in fuel poverty.
We also have significant concerns that receipt of WHD may be used as a future passport to access additional financial support to address the current energy crisis and cost of living challenges. The existing lottery that many households face in being accepted for WHD, despite meeting the Broader Group eligibility criteria, is already a material concern that is of significant detriment to some families.
Any further financial support being channelled to those in receipt of WHD would widen the detriment for those who, for whatever reason, meet Broader Group eligibility criteria, but do not receive it. It is critical therefore for BEIS to report on the percentage of eligible households who receive Broader Group support in Scotland and to ensure that suppliers trade Broader Group capacity with other suppliers, rather than increasing their spend through Industry Initiatives. Should material numbers of households meet the eligibility criteria but not receive a Broader Group payment then this should be addressed through the proposed annual review detailed above.