The consultation asked for views on the aims of the commission, which is independent from Government and consists of experienced representatives serving energy consumers in their communities with the design of strengthening the voice of energy consumers in Scotland.

“UKIFDA supports the overall aims of the Energy Consumers Commission draft work plan and welcomes the focus on finding low carbon heating options,” says Guy Pulham, UKIFDA chief executive.

“Tackling climate change and finding ways to achieve the UK’s net zero targets is vital, and as the national voice for the liquid fuels distribution industry we want to play our part and know that our sector can and will help to reduce carbon emissions in the off-grid heating sector.”

The commission outlined the key areas to focus on and the most effective approaches to achieve this, within its draft work plan for 2020/21.

Mr Pulham said: “The objectives detailed in the draft plan are clear and achievable, although we do question if the time frame needs to be extended given the ongoing impact of COVID-19.

“We also question the focus of the decarbonisation theme on electric alternatives such as heat pumps. There are more than 135,000 households using heating oil across Scotland – which is why it’s so important the commission engages with off-grid trade associations like UKIFDA.

“Our members deal directly with heating oil customers across Scotland on a daily basis and have a wealth of knowledge that could provide invaluable insight for the commission.

“Whilst the current plan does focus on the right themes to improve outcomes for Scottish consumers – residential housing, budgets, consumer protection and the running costs of new technologies – consumers need a varied energy mix and a choice of technologies that are both affordable and energy efficient.

“We urge policymakers to recognise the positive contribution liquid biofuels can make. Biofuels are cost-effective for homeowners, providing an immediate reduction in carbon emissions for minimal outlay as the fuel can be swapped in place of heating oil and run on the existing heating system. Plus, future biofuels will provide an even lower carbon option for homeowners.”

In recent studies carried out by trade association OFTEC and consultants In Perpetuum (2019) liquid biofuels offered the most efficient and cost-effective way to reduce carbon emissions in off-gas grid homes due to the fabric and build type of these properties.

“The cost of retrofitting homes to make them suitable for heat pumps or biomass technology is often high,” explains Guy Pulham.

“Many homeowners would be better off making step changes initially – improving insulation, upgrading to a condensing boiler, and maintaining the current heating system so it runs well would all cut carbon emissions. This would pave the way for bigger changes once liquid biofuels are further developed.”

Guy Pulham concludes: “To help achieve a fair energy market in Scotland, policymakers need a balanced approach, one that considers affordability and accessibility alongside the carbon emissions of each option and the energy efficiency at household level, together with incentives for the residential sector to cut carbon emissions in the first place.

“We fully support the commission’s draft plan but urge them to consider rural and off-grid consumers in Scotland in their planning and to engage with consumers, energy suppliers and industry trade associations to ensure a balanced, effective approach.

“UKIFDA is currently undertaking liquid biofuels trials across the UK and would be happy to meet with the commission to discuss this together with the wider draft work plan and help ensure off-grid homeowners are given the energy options they need to cut their carbon footprint cost-efficiently.”