Edinburgh Research Explorer Understanding policy divergence after United Kingdom devolution

This paper examines diverging energy efficiency policy in Scotland and England, consequent on UK devolved government. It makes two main contributions. First it provides new empirical insights into the political dynamics of energy efficiency policy divergence by analysing Scotland’s divergence from policy in England, in the context of UK devolution. Second it introduces the concept of strategic action fields (SAF) to extend institutionalist approaches to analysing energy policy governance. Use of the SAF concept shows that formal devolution of powers is necessary but not sufficient to explain policy divergence; the political process creates scope for interpretative flexibility to enable differential policy and institutional innovations. Contrasting political-economic objectives in successive UK Conservative-led, and Scottish SNP-led, governments have sustained a motive for Scottish policy divergence. UK government political narratives centred on liberalised markets, prioritising short-term energy supply prices, reducing ‘green levies’ on tariffs and ending public funding for energy efficiency. Scottish government political narratives centred on a social market model, cultivating a strategic action field to legitimise commitments to universal retrofit of building stock. Lacking powers over energy supply, Scottish policy-makers articulated a whole systems approach to reducing carbon emissions, constituting demand-side policies as welfare, climate and economic gains, rather than as cost burdens. The result is a more comprehensive, planned approach in Scotland than England, with specific policy institutions and funding.


Introduction
On 9 June 2015, sixteen years after UK Parliamentary devolution of powers, Scottish National Party (SNP) minister Aileen McLeod, announced to the Scottish Parliament that improving the energy efficiency of Scotland's buildings would be designated 'a national infrastructure priority'.The aim would be to upgrade all buildings for low energy use and clean heating, in line with commitment to net zero carbon emissions.The statement marked the political commitment to distinctive energy efficiency policy in Scotland, in the context of dismantling of policy in England.
For relatively recent, but extensive, policy domains like climate protection and energy transition, devolved states provide a particularly valuable 'natural experiment' for comparative analysis, enabling researchers to investigate policy divergence and policy learning [1,2].In the UK, devolution has evolved alongside climate and energy policies, reinforcing the opportunity for comparative analysis.UK devolution is not federalism: decision-making powers are delegated to Scotland, Wales and Northern Ireland by the UK Parliament, which retains formal sovereignty.England is governed by the UK Parliament, with uneven devolution of executive powers to some regions [3].Devolved policy making is hence situated in complex, inter-locking formal devolved and reserved powers.UK devolution is considered particularly permissive of policy variation, because of both the varied structural arrangements between devolved and central governments, and the provision of block grant funding to devolved governments without stringent ties to UK-wide objectives [4,5,6].Interrelationships between political devolution and policy divergence are however by no means linear or straightforwardly predictable.Explanations for divergence range from geographical conditions and scale [7], to regional identities and competences, to the dynamics of competition and collaboration between administrative bodies and political coalitions.
In this paper, we focus on the latter, examining the interplay of political and institutional aspects of policy divergence between Scotland and England in a key domain of energy policy: energy efficiency in the built environment.Energy use in buildings accounts for the largest share of energy consumption in many economically advanced countries, including the UK.By international comparison, UK housing is particularly old [8] and subject to high energy losses [9], indicating major potential for fabric improvements.Upgrades to building fabric are also expected to ease whole system transition by reducing the need for investment in new supply assets and network infrastructures, while conferring employment, welfare and environmental benefits [10].Over the last decade, this policy domain has however been neglected at UK level [11], creating opportunities for devolved governments to go further.
Research on inter-connections between political governance of policy and energy systems is also limited, often forming part of the background rather than foreground of energy transitions research (see systematic review [12]).Where such research has been done, it has rarely analysed policy divergence or policy learning in devolved states [13], although a few studies are now emerging [14,15,16,17,5].In addition, the balance of transitions research has been towards supply rather than energy use, where a prominent aspect is energy used for heating buildings.Existing research on energy efficiency policy in the context of devolved UK government is hence extremely limited.De Laurentis and colleagues examined the Welsh Government 'Arbed' domestic retrofit programme through the lenses of economic geography, regional studies and innovation studies.They describe the social networks and the EU, UK and Welsh Government funding streams assembled to achieve a distinctive regional innovation [17], showing the centrality of cross-sector governance.In the related area of fuel poverty, Muinzer [5] analyses policy in Northern Ireland, focusing on formal legal and regulatory institutions which comprise a complex UK energy constitution, but he does not directly address the politically-contingent dynamics of policy making.This paper hence aims to make two main contributions to the emerging field of research on energy policy governance.First it provides new empirical insights into the political dynamics of energy efficiency policy divergence by analysing Scotland's divergence from policy in England, in the context of UK devolution.Second it uses Fligstein and McAdam's concept of strategic action fields [18] to extend the institutionalist frameworks increasingly used to analyse the governance of energy transitions.The fields concept is valuable in investigation of the political dynamics and relational processes of policy formation.
The paper is structured as follows.The next section presents our conceptual framework for analysing devolution and policy divergence; the third section explains methods of data collection; section four examines the formal institutions of devolution, and their framing of the potential for policy divergence.This demonstrates the complexity of powers relating to energy policy, and grey areas, which suggest scope for strategic action over policy innovation.Section five presents the main findings: a 'thick description' [19] of energy efficiency policy evolution in Scotland and England examined through the lens of strategic action fields.This centres on political narratives; associated policy goals and instruments; cross sector actors, and strategies for institutionalising new forms of governance.The discussion section reflects on motivations for policy divergence and resulting differences in policy, and the concluding section summarises findings and implications.

Conceptual frameworks for analysing energy efficiency policy in UK devolved government
Recent interest in analysis of policy mixes to enable energy transitions has led to greater attention to the strategies shaping policy decisions, and hence to questions about political actors and institutions (see ERSS special issue edited by Rogge et al, 2017 [14]).Energy policies have varying degrees of coherence, attributable to processes of satisficing, compromise and trade-offs between multiple goals [20,21,22,23].Since compromise may be tenuous or faltering, and is typically crafted in relation to pre-existing policy commitments, policies may drift or be adapted to new goals; new policies may be layered on existing ones, and in some cases existing policies may be replaced [24,25].This research has indicated the centrality of formal and informal institutions in defining the range of legitimate policy problems, goals and instruments, suggesting the value of institutional theories as a means to further insights [26,27].

Institutional theories and the concept of strategic action fields
Moving away from a social order structured around fossil fuel energy systems entails major changes in corresponding frameworks of institutions [20].Institutions are the formal regulative, as well as the more informal normative and cultural, rules governing a social order; they are embodied in organisations of state, markets and civil society [28].Different variants of institutional theory, from rational choice to sociological, discursive and historical, are now being used in analysis of energy transitions [20].Here we rely mainly on sociological variants, because of their focus on the dynamics of social interaction in reproducing and changing institutions, which can be applied to analysis of multi-level governance.Sociological perspectives have moved away from conceptualising institutions as objects exerting top down forces of compliance.Instead institutions are understood as relational and discursive: they are enacted and struggled over by interested parties with differential powers and resources to enforce, maintain, contest or disrupt the status quo [29].While formal and informal institutions constrain action, they are always subject to interpretation and contestation.This is demonstrated in political narratives and contextual practices including those relating to multi-scale energy transitions [27].In the case of devolved states, there is hence scope for degrees of interpretative flexibility or plasticity in formal institutions, which may be brought to bear on policy formation.Sociological theory of institutional fields uses the concept of strategic action fields (SAF) [18] to analyse the dynamics of stability and change in a social order.The concept is now being used in research on energy transitions [30].However, it has yet to be applied to multilevel governance contexts, or demand-side energy policy, where shifting institutional fields are integral to dynamics of governance.The SAF concept is a form of mid-range theory, describing a rule-governed meso-(rather than micro-or macro-) level social order, where interested parties have something at stake, which draws them into interaction around the rules.Such mid-range theory provides insights into inter-connections of particular people (micro) with macro-level economic and societal structures; it highlights the continual crossscale transactions entailed in producing both stability and change.In policy context, the strategic action field concept directs attention to the exercise of agency by parties with something to gain and something to lose; each party typically has differential capacities, powers and resources to shape outcomes.Shared understandings between parties develop through interaction over time; these include understandings of what is at stake, the positions adopted by each party, and their relative power, as well as rules of conduct.
In a field such as energy efficiency policy, political narratives about, and definitions of, legitimate actors, policy goals and relevant expertise are likely to be part of the struggle.
Coalitions may form around perceived opportunities to achieve partially compatible goals, for example combining fuel poverty amelioration with commercial objectives through strategy to increase budgets for housing retrofit.
Any particular policy action field is embedded in multiple inter-linking fields encompassing economic, welfare, environmental and development planning policies, across and within scales of governance.States may facilitate or constrain policy fields and their evolving interconnections, through changes in legal, regulatory or bureaucratic institutions.UK devolution introduces significant institutional changes of this kind, opening up new areas of agency over policy fields, including in allocation of energy competences [17].Sub-state governments have scope to bring differing political narratives to bear on inter-linked fields, asserting authority through diverging policies.Cowell et al [31] for example found that successive Scottish governments cultivated cross sector, cross party, support to exercise considerable influence over the field of UK renewable energy policy.Using the concept of policy communities, they show the assertive use of devolved economic development powers to advance wind power developments faster than elsewhere.The achievements of a more cohesive policy community in Scotland contrasted with the more fragmented, and conflictual, issue networks which resulted in stop-start investment in England.In this instance there was however overlapping interest between devolved and central jurisdictions: UK government needed to meet obligations under the EU 2009 Renewable Energy Directive; Scottish government gained significant investment, simultaneously supporting political-economic strategies, and building capacity for further energy policy making.
It is unclear whether a similar political strategy can work in the field of energy efficiency policy.Governance institutions have differential importance in the political economic order: in advanced economies, the dominant institutions are those of economic growth.The status of other policies typically depends on their alignment with growth objectives [21].This is an important factor for understanding the particular difficulties of making policy to reduce energy demand.Such policies are one component of the complex UK and Scottish politics of combining net zero carbon targets with economic growth, while addressing questions about social justice, public good, taxes, borrowing and competing priorities for public spending.
Despite advocacy of its business, employment, environmental and welfare value [32], policy to retrofit buildings -unlike supply side policy for renewables -is not straightforwardly aligned with a growth narrative.Retrofitting buildings to improve their thermal efficiency requires substantive investment by highly differentiated property owners and supply chain businesses.Its economic results are hard to measure, and the economic returns from public funding are contested.This makes energy efficiency policies a demanding field of strategic action, where insights into associated political narratives are likely to be critical to understanding policy trajectories.
In this paper, we treat energy efficiency policy in Scotland as a strategic action field, situated in the inter-dependent, and only partially stabilised, cross-scale institutional fields of UK devolved governance.The emphasis is on accounting for Scottish divergence from historically similar policies across the UK.As a mid-range theory, the SAF concept focuses on questions about the interactions between formal institutions of devolved government, interested parties with something at stake, and political narratives interpreting and contesting formal institutions, as exemplified in policy making practices.Particularly because of the uncertain status of energy efficiency, or demand reduction, in relation to core institutions of economic growth, policy divergence is expected to depend on political narratives with sufficient legitimacy to mobilise state, business and civil society actors around new policy goals and institutions.

Methods and data
To gain insight into energy efficiency policy divergence, we used a mix of qualitative methods.The main focus of this paper is analysis of policy documents, but this is guided by semi-structured interviews with policy makers and practitioners, and by participant observation.The key documents for comparison were first the UK and Scottish climate change policy frameworks, notably the UK Clean Growth Strategy (CGS) 2017 [33] and the Scottish Climate Change Plan (SCCP) 2018 [34], updated 2020 [35].These are documents required by climate legislation and should specify the policies necessary to reduce emissions in line with successive carbon budgets.Second, the policy goals, and proposed institutions in the Energy Efficient Scotland (EES) 2018 Routemap [36] are analysed.There is no equivalent detailed policy framework for English building stock; the main recent update is the Green Homes Grant scheme 2020, which is incorporated in analysis.For comparability, therefore, the UK CGS and Scottish CCP were used as the starting points for analysis, before proceeding to analyse the EES Programme in more depth.Documents were analysed thematically, focusing first on the narratives used to articulate and justify strategy, including a word count to indicate key terms, and second on the proposed institutions.Document interpretation was informed by interviews with policy makers and practitioners, and participant observation.In 2016-17, the lead author conducted semi-structured interviews with six UK government senior officials responsible for heat and energy efficiency policy, and eight senior managers and chief executives representing UK energy efficiency trade associations, NGOs and consultants.During 2017-18, the lead author interviewed five Scottish government officials responsible for development of EES.All interviews were audio-recorded, transcribed and analysed thematically.These are drawn on as background in this paper, and served as a source for cross-checking interpretation of documents.(See [37] for analysis of UK government interviews, and [38] for analysis of Scottish government interviews.) Participant observation provided insight into the strategic action field of energy efficiency policy development.Access was most extensive in relation to Scottish policy.The lead author participated in the two cross-sector 'Thought Leaders' events (early and late 2015) informing EES political narrative and programme development.This author was also responsible for research evaluation of three rounds of EES local authority pilot projects from 2016-2020.Evaluation research was conducted in collaboration with Scottish Government officials, Resource Efficient Scotland (government agency responsible for non-domestic energy efficiency advice, grants and loans) and Energy Saving Trust Scotland.The latter conducted the technical evaluation of EES pilots and is also responsible for domestic energy efficiency advice, grants and loans.The research advisory group held circa four meetings per year from 2017-2019, and organised additional specialist cross sector workshops to test early findings and to inform policy development.In addition, the author worked with Scottish Government in two rounds of public consultations on EES proposals; convened and participated in EES workshops with local authorities and participated in EES economic and environmental impact assessment events.She was a member of the academic panel responsible for reviewing the Scottish definition of fuel poverty, and a member of the Infrastructure Commission for Scotland.The latter advised government on infrastructure investment for net zero carbon targets, including retrofit of buildings.In relation to UK Government, in 2016 the same author participated in two Ministerial-led cross sector roundtables on domestic energy efficiency and heat policy.She is also a reviewer for UK Government-commissioned research informing heat and energy efficiency policies, and was a member of the heat and energy efficiency policy steering group for UK Policy Connect (2019-2020), which is a UK parliament cross-party think tank.

United Kingdom devolution and institutions governing energy efficiency policy
Formal institutions of devolution frame the potential for differential policy trajectories; complex devolved and reserved powers relating to energy, and uncertainties or grey areas, suggest scope for strategic action over policy innovation [15,39].The main powers over regulation, licensing and tax of energy supply in England, Scotland and Wales (but not Northern Ireland) are reserved to the UK Parliament, although demand side policy powers are more diffuse (see Table 1).Devolved governments in Scotland and Wales cannot therefore make autonomous decisions about energy or carbon taxes, levies on energy bills such as the supplier energy efficiency obligation, or priorities of the gas and electricity market regulator.Powers over market competition and consumer protections are also reserved (under the Competition and Markets Authority), limiting the power to change standards of customer protection for building retrofit.Table 1 however shows the wide range of fully devolved powers relevant to energy use in buildings, demonstrating scope for strategic action on energy efficiency through inter-linking policy fields from economic development to health and welfare.The concept of strategic action fields situates the inter-play of reserved and devolved powers in political interactions, emphasising that devolution is a process rather than an event.The Scotland Acts (2012 and 2016) for example devolved further powers over income tax, stamp duty, land tax, and some welfare benefits, including cold weather payments for low-income households and a winter fuel payment for older people.Institutions governing Scottish borrowing were also made more flexible, and capital borrowing ceilings for infrastructure investment were raised.In principle, more flexibility on borrowing and taxation provides a basis for more radical energy efficiency policies, including the mix of grants and loans to property owners, or materials' procurement to reduce costs for areabased retrofit.In addition, powers over particular policies may be executively devolved to suit regional economic goals; this includes the renewable energy subsidies which were critical to Scottish strategic action to define wind power investments as economic development [16].Under UK devolution agreements, any policy powers not explicitly reserved to the UK parliament are also presumed to be devolved.This may leave formal institutions relevant to newer policy fields unspecified.Policy relating to decarbonising heat for example was described by one UK official (in a research interview) as 'devolved by default', because heat is not formally regulated, despite comprising almost a third of UK energy use, and thus being critical to meeting carbon budgets.
Conceived as a strategic action field, policy for energy efficiency in buildings is hence a complex area.Any policy framework may encompass multiple instruments, with differential impacts.These include advice and promotional services for building owners, subsidies, loans, taxes and regulatory standards, and direct or outsourced services such as cladding of buildings.Energy efficiency cuts across governance specialisms including housing, communities and local government; energy and climate protection; and business, skills and economic development.The resulting diversity of formal and informal institutions and resources which can be brought to bear on policy offers significant discretionary scope for government action.This includes collaboration or contest between and within governments, as well as across sectors.Policies to reduce energy demand also interact with non-energy policies with potentially contradictory results [42].
Any systematic policy framework to improve thermal performance of building stock is hence likely to require institutional innovations inside government to embed divisions of responsibility, leadership and collaboration, and to secure necessary budgets.This places corresponding demands on political narratives, and political and officer prowess and capability, including engagement with local governments, business and civil society, to make policy effective.Conversely the same diffuseness and complexity of this policy field means responsibility can be variously avoided or passed between different levels and sectors of government, resulting in little material change.

5.
Diverging policy frameworks for energy efficiency in buildings in England and Scotland: political narratives, policy and institutional change The previous section examined the complex of formal devolved and reserved institutional powers which frame potential for energy efficiency policies and policy divergence.In this section we examine political and inter-relational aspects of fostering and institutionalising a strategic action field in Scotland: defining legitimate actors; engaging across sectors, and deploying formal and informal powers to establish distinctive policy.First, we explore the differing political narratives in UK and Scottish governments, which shape rationales for divergent policies.Second, we exemplify the translation of the differing political narratives into climate policies.The dismantling of policy in England means that there is no dedicated energy efficiency policy framework for comparison with the draft framework in Scotland.
Hence we use climate policy documents as a basis for comparison.Third, we discuss key proposals in the Energy Efficient Scotland programme which are designed to institutionalise policy.Lastly, we consider briefly the material importance of policy divergence by comparing the building-related carbon and energy demand reduction targets defined in the UK Clean Growth Strategy (2017) and Energy Efficient Scotland (2018), and the published financial commitments.

Political and cultural narratives shaping an energy efficiency strategic action field
Foundations for energy efficiency policy divergence between England and Scotland are rooted in differing political narratives.Since the 1980s, UK governments have largely relied on advocacy of liberalised markets, competition and outsourcing as a means to improving public services.This has been consistently resisted in Scotland, where a distinctive narrative of 'social market centrism' [43] has prevailed [1], and public institutions of health, education and housing have continued to be central to cultural and political norms [44,45].Since devolution, the social market narrative has been integral to fostering strategic action fields in public policy, resulting in more pronounced divergence from UK policy in welfare, economy and environment [46].These fields have been characterised mainly by domainspecific and relatively stable actor networks, largely avoiding major contestation [47].
Energy and climate policy fields, including energy efficiency, however, intersect with economic, employment, welfare and development planning policies.Difficult compromises are likely to be needed, with political narratives critical to establishing legitimate policy goals and instruments.This is evident in the break away from historically convergent energy efficiency policies across Britain, which commenced in 2010, consequent on election of successive UK Conservative-led governments, and politically opposing Scottish National Party-led governments in Scotland since 2007 (Table 2).A UK government neo-liberal political narrative of austerity in public finances and criticism of 'green levies' on energy bills has been instrumental in major scaling back of energy efficiency policy and public funding in England, as well as reducing obligations on energy suppliers to invest in energy efficiency in households [48].This pattern continued until 2020, when an English Green Homes Grant was introduced, although this is now closed to new applicants (see Table 3).In Scotland, energy efficiency policies remained in place.Public investment of around £190 million per annum to improve housing insulation and heating for low income households was maintained, alongside funding for EST Scotland.More broadly, a political narrative centring on a social market, social inclusion and cross-sector, as well as intra-government, collaboration has been used to shape a distinctive, and hence divergent, policy field.In the parliamentary domain, cross-party support has been orchestrated around welfare benefits of area-based home energy-saving schemes for low-income, fuel poor, households.There was also unanimous support for the Climate Change (Scotland) Act 2009, updated 2019.In cultivating broader cross sector commitment, energy efficiency has again been situated in the devolved domain of economic development, harnessing prior political capacity built around wind power investments [31].
In line with strategies of successive Scottish governments, the 2015 designation of energy efficiency of all buildings as a national infrastructure priority was associated with prior mobilisation of a broadly-based cross sector group of policy actors.This group was asked to evaluate potential -and hence provide a justificatory rationale -for integrated economic, The field was further articulated in a 2017 Scottish energy strategy, where limited direct powers over supply side policy arguably led to strategic emphasis on a whole systems model.The strategy gave prominence to demand reduction through 'energy productivity' and thermal upgrade of the whole building stock.Demand reduction was again situated in economic strategy through envisaged skills and supply chain development and jobs.In Scottish, as opposed to UK, policy, energy demand-side policies have therefore been constituted in political narratives and strategic initiatives as opportunities for economic and welfare gains, rather than as cost burdens.

Political narratives embedded in contrasting climate policy commitments
The impact of differing political narratives on policy can be exemplified using climate policies in England and Scotland.Dismantling of energy efficiency policy in England means that there is no dedicated policy framework.Comparisons in this section are therefore between the UK Clean Growth Strategy (CGS) 2017 (with brief reference to an updated Ten Point Plan 2020), and Scottish Climate Change Plan (CCP) 2018, also updated 2020.(Note however that the UK government Ten Point Plan is a brief outline of potential policy.)These documents apply contrasting narratives to governance of carbon budgets, casting light on the reasons for energy efficiency policy divergence (see Table 4).Although a frequency count of key terms is a very simple measure of political narratives, it is nevertheless useful as a summary indicator of contrasting priorities and objectives.Close reading of document texts also informs the analysis.Two particular institutional innovations are likely to be significant in embedding governance commitments into practices.The first is proposed creation of a dedicated national body to integrate the programme into central government and provide cross sector coordination.This is intended to manage intra-government divisions between health, housing, social welfare, climate change, economy and enterprise.Options appraisal recommended establishment of a dedicated structure ('directorate') inside government [58].
The second institutional development, a proposed statutory power for local authorities to In principle this provides the basis for assessing necessary resources, although such assessment is itself a sphere of political contest and ambivalence [61], leaving the status of LHEES uncertain.A draft Heat in Buildings Strategy 2021 [62] does not resolve the status of LHEES proposals, implying continuing political contestation.

Policy Commitments of UK Clean Growth Strategy (CGS) 2017, Energy Efficient Scotland (EES) 2018 and draft Scottish Heat in Buildings Strategy (HiBS) 2021
Finally, it is worth brief consideration of the materiality of diverging energy efficiency policy narratives in order to assess potential impacts.Comparison between UK CGS and Scottish EES/HiBS efficiency targets shows their similarity (see Table 5).Both rely on modelled, rather than actual, energy use, through Energy Performance Certificates (EPCs), despite known problems of reliability [63].Requirements to meet targets are also qualified with respect to cost and technical feasibility, creating scope for significant exceptions, and again indicating processes of compromise behind policy.Outwith the scope of this paper, but relevant for future research, major questions remain about the material impacts of diverging policy.Both UK and Scottish governments set cautious energy efficiency targets, despite abundant evidence of urgent need for, and value of, rapid change.Both have very limited policy for non-domestic buildings, and Scottish area-based pilots have revealed the difficulties of engaging all scales of property owners, from corporations to small businesses and home owners [61].The test of a distinctive Scottish institutional field, structured around economically consequential retrofit of building stock, will be in securing cross-sector, cross-party trade-offs, and discovering common ground, over routes to 'net zero emissions' from buildings within the target dates of 2030-2040.At present, action remains optional for most property owners, and it is unclear how an area-by-area, rather than individual 'property owner' choice, model could be implemented.Institutional structures for a major retrofit programme, including finance, quality assurance, supply chains, skills and procurement, are only partially developed.
Strategic actor networks will need to manage trade-offs across inter-linking, and partially conflicting, policy domains of economic development, welfare, housing and climate protection.

Conclusions
This paper has sought to explain the divergence between Scottish and English policy for energy efficiency in buildings.The expectation was that political devolution opens the door to policy divergence, and that Scottish Government may be motivated by a range of factors to develop distinctive energy efficiency policy.These factors include political opportunity (having devolved competence, when UK government is unambitious in this arena); area characteristics (e.g.fuel poverty, colder climate and housing stock) and scale (e.g.smaller population may reduce the number and complexity of partnerships required, resulting in lower transaction costs).Using institutional theory, particularly the concept of strategic action fields (SAF), this paper has however exposed more complex and dynamic processes which largely explain how, and partially explain why, Scotland has developed more holistic policies.The analysis highlights the political and societal dynamics of argument, ideas and advice -and the skilful handling of controversy, contest and objection -as central to material change.At least within the particular settings of devolution in the UK, study of these factors can reveal much more about the drivers of policy divergence and convergence than could be gleaned from a comparative study of more easily observable static factors, such as those mentioned above.
Moreover, the SAF lens provides more nuanced perspectives on policy change, illustrating why policy divergence under devolution cannot be assumed to lead to constructive policy learning, and subsequent convergence.Progressive emulation of policy between Scotland and the UK has been limited in the context of political divisions.Given the power imbalance inherent in devolution, as opposed to federalism, UK policy-makers are arguably less receptive to learning from sub-state, national policies, although there is some suggestion that should policy learning occur against the flow of power, then it can produce radical institutional change [68].In the current period of political division, 'learning' has mainly taken the form of policy differentiation, institutionalising distinctive political values and priorities.The same diffuse qualities of energy efficiency and heat governance institutions mobilised in Scotland appear to have allowed successive UK governments to delay questions about concerted action to retrofit English building stock.
In summary, this paper draws attention to the political-economic rationales and strategies underpinning the course of energy efficiency policy in different jurisdictions of the UK after 2010.In England, long term commitments to climate protection have been pursued through supply-side strategies for short-term economic growth in liberalised markets, marginalising demand-side energy efficiency.Political strategy, around a social market narrative in Scottish government, situated clean energy as central to economic development.Lacking devolved powers over energy supply, Scottish policy-makers articulated a whole systems approach, constituting demand-side policies as integrated welfare, climate and economic gains, rather than as cost burdens.
In Scotland, governance capacity to develop a sense of shared purpose and mutual benefit between central and local scales of government, and across sectors, has been critical to policy to upgrade existing building stock, and will be central to its implementation.
Maintaining meso-scale institutional fields to address the inter-locking social, technical and economic issues of retrofitting the entire building stock will require concerted political ingenuity, and further devolution of powers.Building upgrades need to be customised to geographies and types of property, and costs for older buildings may be high.On the industry side, retrofit supply chains are fragmented, and innovation has been set back by weakening of UK policy and budget reductions [69].Enabling and institutionalising new fields of strategic action to achieve zero waste of energy needs more coordinated, multi-level UK government frameworks for a renewed social contract between markets, state and civil society.

Table 1
Devolved powers relevant to Scottish policy making for energy efficiency in buildings Aspects of UK policy may be executively devolved Energy market support (eg.Renewable energy obligations) Energy efficiency taxes, including tariff structures or levies Competence devolved to Scotland Economic development Land use and development planning and consents Environment and climate change law Building standards Property law Stamp duty land tax Local government and taxes Housing and communities Promotion of energy efficiency Amelioration of fuel poverty Winter fuel payment Cold weather payment Sources: [15, 40, 41].
welfare and environmental gains in a social market context.Characterised as 'thought leaders', participants represented energy utilities, trade associations, housing bodies, social enterprise and community organisations, academics, environmental NGOs and central and local government and their agencies.A first workshop, chaired by an independent facilitator, was structured by detailed cost-benefit assessment of the economic, fiscal, and environmental impacts of a domestic sector energy efficiency programme[50].A second workshop, chaired by the government director of energy, focused on assessing the feasibility and likely outcomes of specific policy instruments, finance options and pilot projects.The existence of a senior Scottish official responsible for energy itself served as a statement of political intent to exert agency, despite limited formal powers.Local government commitment was also sought through funding for pilot schemes, commencing in 2016.These tested area-based heat and energy efficiency planning and retrofit of buildings.A broad definition of legitimate interests was hence brought to the formation of a strategic action field; interactions concerned the development of a workable compromise over governance structures, standards, timetables and supply chains.
develop comprehensive Local Heat and Energy Efficiency Strategies (LHEES), embeds governance in inter-dependence between central and local scales.The proposal reinforces Scottish Energy Strategy 2017 orientation to multiple inter-linking localised strategic action fields, where local authorities and social enterprises act as 'trusted intermediaries' between commercial suppliers and local property owners.The LHEES would be the first local statutory power over energy since the 1995 UK Home Energy Conservation Act (HECA).HECA required local authorities to report on domestic energy efficiency improvements, but, lacking new resources, it operated in largely voluntary fashion.LHEES is intended to serve as a hinge between national and local scales of governance for planning, costing and prioritising building stock retrofit and heat decarbonisation options.A social market narrative is again embedded in proposed socio-economic metrics to assess the long-term societal value of climate protection, welfare and local economic regeneration, beyond the financial case.Draft methodology proposes weighted criteria in line with political priorities: equal and majority weight is attributed to reducing carbon emissions and fuel poverty (60% overall), while financial costs, local economic impact and resilience each have a nine per cent weighting, and environmental and social impacts each have an eight per cent weighting[59].Proposed LHEES imply extension to local responsibilities, including public engagement, management of area-based programmes and enforcement of regulated standards, engaging both political and administrative dimensions of governing.Politically, the dynamics of national-local negotiations, with local politicians represented by the Convention of Scottish Local Authorities (CoSLA), are framed by long standing struggles about centralised control over local priorities, and ongoing reductions to local budgets [60].Local politicians are resistant to new responsibilities in the absence of commensurate resources, and greater local control over priorities and finances.Administratively, local authorities have had to outsource most technical services, limiting capacity for comprehensive heat and energy efficiency planning and implementation.There are questions about local costs and benefits of rebuilding in-house expertise vs dependence on external technical consultancy.All thirty -two local authorities have piloted LHEES methodology, database creation and prioritisation.

Table 2 :
UK and Scottish Governments since 1998.

Table 3 :
UK Government energy efficiency policy initiatives Year Policy Introduction or Withdrawal 1992 Energy Savings Trust (EST) created for domestic sector services 1994 Privatised electricity suppliers obliged to provide domestic energy saving advice 2000 Privatised gas suppliers obliged to provide domestic energy saving advice 2000 English Warm Front funding scheme for vulnerable households 2001 Carbon Trust created for private & public sector services 2005 Building regulations require installation of condensing boilers 2011 English Warm Front funding ended 2012 Residential sector Green Deal policy introduced 2012 Core grant funding ended for Energy Savings Trust (EST) & Carbon Trust 2013 End to subsidies under the energy supplier obligation CERT programme 2015 Withdrawal of planned 2016 zero carbon homes standard 2016 Closure of residential sector Green Deal policy* 2018 Annual Energy Supplier Obligation (ECO) budget halved for 2018-2022 period 2019 CRC non-domestic energy efficiency scheme abolished 2020 English Green Homes Grant introduced (closed to new applicants in March 2021) [49] Green Deal was developed by the Conservative UK government to supersede the energy supplier Carbon Emissions Reduction Target (CERT), but proved expensive and ineffective[49].

Table 4
The Scottish Climate Change Plan (CCP), updated in 2020 in line with a revised 2045 target date for net zero emissions, is literally more planning-oriented, including use of the terms 'duties' and 'principles'.The overarching carbon budget is broken down sector by sector, and uses specific measures down to the level, for example, of the proportion of lofts with at least 200mm of insulation.Progress indicators are specified for monitoring and review.The CCP also emphasises social inclusivity, fairness, community and collaboration narratives.
The differential political narratives are relative, rather than absolute.The UK CGS and Scottish CCP are noticeably similar in references to markets and competition; indeed the updated Scottish CCP (2020) makes greatest use of 'market' vocabulary, albeit in the context of 'inclusion', 'fairness', 'communities' and 'collaboration', reinforcing a narrative of social market centrism.Nor does the UK CGS altogether eschew the terminology of plans and planning frameworks.Both also share an orientation to flexibility: the Scottish CCP 2018 states that the sectoral plans are 'one potential option for achieving our climate change targets, and should not be considered sector targets' (p.58); the UK CGS states a In principle, EES 2018 attributes higher value to energy saving than the UK CGS 2017.The SNP government commitment, in 2017 Energy Strategy, to prioritise a renewable energy system narrows supply-side options, and puts corresponding emphasis on demand-side reduction.Achieving this outcome without formal institutional powers over energy markets necessitates political ingenuity to devise policy instruments suited to multiple, potentially only partially compatible, goals.Developing a Scottish cross-party and cross-sector strategic action field has correspondingly relied on aligning climate protection with established crossparty political commitments to welfare, social justice and economic regeneration.EES provided a vehicle for the Fuel Poverty Act 2019, through its objective of removing poor energy efficiency in housing as a factor in fuel poverty, while simultaneously reducing positioning energy efficiency as integral to economic development, with policies structured around a social-market narrative.

Table 5
Comparison of Energy Efficiency Policy Measures in UK Clean Growth Strategy (CGS) 2017 and Energy Efficient Scotland (EES) 2018, updated in draft Heat in Buildings Strategy (HiBS) 2021 UK Government statutory targets to improve homes of fuel poor households pre-existed the CGS 4. Regulations to include date for assessment of all buildings above specified floor area & provision for amendments Despite equally cautious targets, spending plans indicate stronger commitment in Scotland than England.The Scottish government intends to invest £0.5 billion during the current Evidence suggests that such policies have not been subject to the same test of short-term economic pay back as demand side energy saving [67].UK Clean Growth Strategy integrated carbon reduction into economic strategy, but lacked policies to achieve net zero emissions from buildings.The EES programme is integrated into Scottish economic strategy, with plans for developing skills, supply chains and accessible certification for local businesses.In contrast to the CGS, which considers regions only in one policy proposal for industrial strategies, EES proposes new institutions for local and central government coordination and shared authority.Political contestation over these proposals will however continue between [37]he intersecting strategic action fields of energy, economy and energy efficiency policy in England and Scotland, historically stabilised formal institutions of economy, property, tax and welfare, and more informal normative, institutions have been disrupted.Contrasting political-economic narratives in successive UK and Scottish governments have sustained a motive for Scottish policy divergence to establish distinctiveness.In this context, English cross-sector actor coalitions advocating progressive energy efficiency policy and budgets, based on socio-economic as well as environmental value, have gained limited traction[37].Conceived as a strategic action field, demand-side policy innovations in Scotland have spanned epistemological and political dimensions.Innovations include: (I) redefining the problem by designating energy efficiency of buildings as an infrastructure priority; (II)