Common Weal Consultation Update - June 2025
An update on some of the Government consultations that Common Weal has responded to this year.
Source: Unsplash
Long time supporters will know that Common Weal tries to be as engaged with the Government’s policy-making processes as we can and an important part of this is responding to public consultations. As a statutory requirement of making legislation, the Scottish Government (or any MSP bringing forward a Members’ Bill) must submit the proposal for public consultation. They also do this at other stages of policy-making such as putting out a Call for Views very early in the process to try to guide the development of the policy long before it is legislated for and there are other engagements that look and like those consultations but are more about the implementation of the policy or guide other technical details. This is, of course, a time consuming activity especially when the Scottish Government publishes several hundred consultations every year – we can’t respond even just to all of the ones we’re interested in, never mind all of them. There are currently 13 active consultations on the Government’s CitizenSpace platform – you can view or respond to them yourself here.
Add to this the fact that other public bodies, Local Authorities and quangos also often consult the public and add in that ALL of this also happens at a UK level too and you can see how busy we can be kept even without developing our own policies on important topics. I say all of this to give a reason (though not an excuse) as to why while we’ve been busy responding to consultations, we have struggled to post our responses to our policy library as we’ve been submitting them (I’ve also been moving the policy library over from the old website – a mammoth task given that it represents more than a decade of work and one that, thankfully, I’ve recently completed!).
Enough of the reasons though. It’s time to show you what we’ve been saying to Government. Three of our recent consultation responses are now live in our policy library and I’m taking this week’s newsletter as an opportunity to take you through them. Click on the title headings to read the full responses.
Consultation on Radio Telecom Services
This response was directed at a consultation run by Ofgem earlier this year in the run up to a self-imposed deadline to shut off transmitters that send signals to radio controlled home heating systems across the UK by the 30th of June this year. These systems are a legacy technology and are being replaced with modern smart meters but when they were installed they provided a very useful means of automatically switching heaters in water storage tanks on and off in line with off-peak energy times which reduces demand on the grid and allows home owners to heat their homes using off-peak energy tariffs. This proved a vital lifeline particularly in rural areas where over-the-air radio broadcasts were a more reliable means of sending such signals than mobile cellular signals, never mind broadband internet or other cable transmissions.
However, the transition to smart meteres is incomplete with an estimated 600,000 RTS meters still installed across the UK with perhaps 100,000 of them being in Scotland. The effect of switching off the transmitters without replacing the meters would be profound for those who rely on them. At a bear minimum, it could force residents to have to adjust their heating manually (which will likely cost more if they can’t match the cheap overnight tariffs) but in a worst case scenario could result in heaters being switched off without the ability to turn them on manually or – perhaps even worse – heaters being locked into an active setting which could well represent a danger to life.
Amongst other recommendations in our response, we called for a delay to the transmission cuttoff deadline to give more time for meters to be upgraded and for the industry to accept full responsibility for the situation – compensating residents for any excess fees or damage resulting from the switchoff so that residents are not penalised for a problem that is entirely outwith their control.
Vision for Scotland’s public electric vehicle charging network
While our plans for the future of transport is one that relies very much less on private car ownership than does the Scottish Government’s (especially since they’ve ditched their target of reducing car miles by 20% by 2030), we recognise that they will still feature prominently in post-carbon Scotland.
Anyone who has tried to take a long EV car journey in Scotland just now can attest that the charging infrastructure is not yet sufficient for current needs, never mind future demand, and so it needs to be both expanded and made more robust. This consultation response urges the Scottish Government to reverse its policy of relying almost entirely on the private sector to do this as it will result in mis-matched standards across the network, incompatible charging methods (especially via payment systems) and will result in massive profit extraction and increased costs to consumers – negating the incentive to transition to an electric vehicle.
The major problem of the current system of allowing private companies to tender to install chargers in particular areas is that this will disincentivise installing infrastructure in rural areas (where lower density means lower profits and more expensive maintence) and in deprived areas (where there are generally lower levels of car ownership in general, never mind EV cars). We recommend that the Government follow principles similar to some bus contracts where a condition of bidding for highly profitable rich, urban tenders is tied preconditionally to also servicing lower profit areas. We do, however, call as a first principle that the infrastructure should be publicly owned.
Community Benefits from Net Zero energy developments consultations
That communities gain some kind of monetary benefit from allowing renewable energy developments to be built near them was a laudible idea when it was first implemented, however this policy has not kept up with the times or with changing technology.
The baseline fee of £5,000/MW/year given to communities near to wind turbines is now far too low and should be increased (adjusting for inflation, the baseline should be closer to £7,500/MW/year). However, the fundamental idea of how this baseline is calculated is also subject to challenge.
Right now, this statutory fee applies only to onshore wind turbines. It does not apply to other forms of renewable energy like solar farms (hence communities being offered derisory payments of as low as 2% of this baseline) and it doesn’t apply to battery farms which can make money for their owner without “generating” energy at all, simply by buying cheap off-peak energy to charge the battery then selling it at a profit during peak times. They also don’t apply to communities who happen to be in the way of the transmission cables required to move the energy from where it’s generated to where it’s needed.
We call for community benefit schemes to apply to all forms of local energy infrastructure but we also call for the method by which it is calculated to be changed. Due to the different “capacity factors” of wind versus solar and due to the way that other infrastructure like batteries generate revenue, it’s clear that a “per MW” basis is no longer appropriate. It would be better to define the community benefit based on a percentage of the value of energy delivered to the grid by the infrastructure. Better still, would be for the Scottish Government to support public ownership of energy and to mandate that all large renewable developments are approved only on the condition that there is a local community-ownership stake of not less than 10%.
Ultimately, however, the current arrangements of developers negotiating directly with communities is failing and is leading to corporate entities effectively predating on communities who lack the cohesive democratic structures to properly advocate for themselves (I personally have witnessed one company sending an employee to spy on a closed community discussion about a local development). If Scotland wants to properly equip local communities to be able to take on these developments, to own them, and to responsibly deploy the resources they gain from them then we also need an overhaul of local democratic structures including the refounding of a municipal level of local government.
Conclusion
These are just three of the consultation responses we’ve submitted in the past few months. We’ve also submitted responses to consultations on care, home improvements, zonal charging and justice reform – we’ll get them up in our policy library as soon as we can. Just to remind folk though that we do all of this on a budget that totals less than the salary of the First Minister so if you’d like to support the work we do then please consider signing up as a regular donor.
As for the consultations themselves, we’ll keep going with this vital (if sometimes thankless) work of holding Government to account and trying our best to ensure that the policies they implement are as positive as possible for All of Us.
