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This is a non-technical summary of the Environmental Report of the Proposals for a Heat in Buildings Bill Consultation (‘the consultation’).
To achieve our climate change targets, we need to stop using gas, oil and other fossil fuels to heat our homes, shops, offices, schools and other buildings, and make the transition to new systems such as electrically powered heat pumps or (in some areas) to local heat networks.
The proposals contained within the consultation on proposals for a Heat in Buildings Bill set out standards and targets for all built stock, both domestic and non-domestic, with dates for compliance and triggers to bring about earlier action. With a focus on the prohibition of direct emissions (referred to as “polluting” from here on) heating systems, it also provides a driver for the improvement of energy efficiency standards in the domestic stock before 2033 (with the exception of social housing, which will remain subject to a separate but equivalent regulatory standard).
The consultation fulfils the commitments made in the Heat in Buildings Strategy to develop proposals and an approach which brings together ambitions on energy efficiency and heat decarbonisation for Scotland into a single regulatory framework.
The proposals set a backstop date of 2045 for the prohibition on polluting heating systems, giving a twenty year span to achieve significant change. The consultation recognises the need for proposals to be fair, achievable and proportionate, and ensuring a Just Transition as part of which no one is left behind.
The consultation, and this assessment, also recognise the role of lower tier plans and future regulations which will be needed to bring to life the powers proposed in the consultation document. Where any future policies and proposals are developed, these will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act (2005).
What is Strategic Environmental Assessment
Strategic Environmental Assessment (SEA) is the assessment of the likely significant environmental effects that a public plan, programme or strategy will have on the environment if implemented. Where possible, it proposes how negative effects can be avoided or reduced and identifies opportunities for positive effects to be maximised. SEA provides an opportunity for the public to express their views on the proposals for the bill and on an Environmental Report setting out the assessment findings.
The Environmental Report has been prepared in accordance with the Environmental Assessment (Scotland) Act 2005. The SEA focused on the effect of the proposals contained within the consultation on climatic factors, air, population and human health, material assets, and cultural heritage.
The Environmental Report sets out the assessment findings and makes recommendations for mitigation and enhancement where appropriate. Early comments from the SEA Consultation Authorities (NatureScot, SEPA and Historic Environment Scotland) have been taken into account in shaping how the assessment has been undertaken, what it covers, and the level of detail presented in the Environmental Report.
Key Environmental Issues
Climatic Factors: Summary and Key Issues
- Observed climate change trends are likely to intensify in the future – wetter winters and drier summers with an increase in the frequency of extreme weather events and climate change can negatively impact energy infrastructure – e.g. through flooding.
- Key issues for climate change include greenhouse gas emissions from a range of sources, with energy supply and use of homes and buildings contributing to emissions.
- Climate change can also give rise to indirect effects arising from mitigation and adaptation measures.
- Climate change has also been identified as a primary pressure on many of the SEA topic areas
Population and Human Health : Summary and Key Issues
- Scotland’s population is growing and Scotland has experienced a small increase in heat demand in recent years.
- Heat in buildings accounts for approximately a fifth of Scotland’s GHG emissions.
- Challenging weather, poor energy efficiency and reduced heating options (especially in rural areas) can make fuel bills unaffordable, resulting in fuel poverty.
- The potential impacts of climate change on population and human health will not be evenly spread. ( e.g. negative health impacts are likely to be disproportionately severe in area of high deprivation).
Cultural Heritage: Summary and Key Issues
- Scotland’s many and varied historical sites are unique and irreplaceable.
- Development is a key pressure on the historic environment and cultural heritage, both directly in terms of damage to known and unknown features, and possible impacts on setting.
Air: Summary and Key Issues
- Whilst air quality has improved significantly, poor air quality in certain areas continues to affect human health and the environment
- Air pollution can contribute to a number of health problems and climate change may exacerbate these issues and alter current patterns and concentrations.
- Key issues for air include emissions from a number of sectors leading to air pollution with air quality and GHG emissions intrinsically linked as they both arise from broadly the same sources.
- Measures that seek to reduce emissions from buildings such as from improved energy efficiency and heat decarbonisation , have the potential to broadly contribute to improved air quality
Material Assets: Summary and Key Issues
- Today, heat is responsible for approximately half of Scotland’s energy use and buildings/ Infrastructure associated with the development/deployment of heat decarbonisation will play a key role in ensuring the future of its security of supply and decarbonisation.
- Key issues for material assets include those associated with development and infrastructure and pressure on land use.
- Changes in land use required to meet Climate change targets could also have environmental effects.
What are the conclusions of the assessment?
The assessment concludes that the proposals which may form the basis of a future Heat in Buildings Bill are likely to have significant positive effects on climatic factors, air, population and human health and material assets. This is likely to be gradual but increasing towards the backstop date of 2045. This is particularly true when considering the reduction in GHG emissions which will result from the prohibition of polluting heating systems.
The potential for effects in combination with other plans, programmes and strategies has also been considered. The proposals and subsequent Bill form part of a wider framework which has the potential to positively and cumulatively contribute across a wide range of Scottish Government policy areas within the context in which it sits.
The assessment identifies the potential for mixed/uncertain secondary effects on a range of SEA topics as a result of the deployment of strategically important energy efficiency measures and heat technologies ready for deployment (including energy efficiency measures, heat pumps and heat networks) at the local level. Existing mitigation measures can help to address these.
The assessment further recognises that any future roll out of the powers contained within the proposed Heat in Buildings Bill will require secondary regulations which will be the subject of future and more detailed assessment.
Existing mitigation at the local level can help to address adverse effects and relevant emerging PPS also has the potential to provide mitigation at the strategic level.
What are the proposals for mitigation and enhancement.
Where there is potential for secondary adverse effects associated with the development and deployment of energy efficiency measures and clean heat technologies in the short term further consideration should be given to opportunities to mitigate any such effects including at the local level. There are existing controls in place, for example through the relevant consenting and licensing procedures, that can help to address these.
In addition to local mitigation measures identified, the development of emerging and future PPS (secondary regulation and delivery programmes) improvements to the supply chain associated with heat decarbonisation are particularly relevant as they could potentially provide mitigation at an appropriate level.
The SEA findings support the dates proposed in the consultation with triggers and backstop dates to drive action. Reductions in GHG emissions will contribute to significant positive environmental effects across both domestic and non-domestic sectors.
In order to help obtain maximum environmental benefits, a focus could be given to:
- actions that support opportunities for early take up across domestic stock. This could be done through support, advice and messaging to raise the profile of the proposed Heat in Buildings Standard (“the Standard”) and works needed to meet it.
- people living in deprived areas and in rural areas where extreme fuel poverty rates are highest. This could be done through the existing delivery programmes where there is a focus on those in or at risk of becoming fuel poor.
- deployment of zero direct emissions heating technologies (referred to from here as “clean heating systems”) in areas which currently use high carbon heating fuels, in areas recognised as being cost effective in the short term and in areas least likely to receive a heat network in the longer term. This could be done through focused targeting and messaging.
- working with stakeholders, such as Historic Environment Scotland, to develop more solutions to transition Scotland’s historic buildings to zero emissions heating while respecting and preserving the special characteristics of our buildings and places.
Section 19 of the Environmental Assessment (Scotland) Act (2005) requires the responsible authority to monitor significant environmental effects of the implementation of the PPS. This should be done in a way to enable the authority to take appropriate remedial action where applicable
A wide range of existing programmes have associated monitoring in place at the national level. At a programme level, the Heat in Buildings Strategy committed to the publication of a monitoring and evaluation framework in 2023. This will help provide the basis for future monitoring of the effects of the proposals contained within this consultation.
What Reasonable alternatives have been considered
The 2005 Act requires the Environmental Report to identify, describe and evaluate the likely significant effects on the environmental of reasonable alternatives to a plan, programme, or strategy taking into account its objectives and geographical scope.
Do nothing/business as usual is not a reasonable alternative to the proposal to introduce a Heat in Buildings Bill because the Climate Change (Scotland) Act 2019 requires plans to be laid that set out the pathway to reaching our net zero and interim emissions reduction targets. A Bill as proposed will play an essential part in achieving zero emissions in the built stock.
There are different strategic technologies that are available now, or could become available in the future, to reduce emissions from space and water heating. These include electric heating options such as heat pumps and storage heaters, heat networks and potentially the use of renewable hydrogen as a replacement for methane gas in the mains gas network.
The main technologies available for deployment today, and which are likely to remain the main strategic options for the next ten years, are electric solutions (and in particular heat pumps) and heat networks. Subject to the safety and commercial case being established we may see 100% hydrogen becoming available in parts of the gas network towards the end of the decade.
The consultation is technology neutral, however, on the basis that there are no recognised and reasonable alternatives to a mixed or blended technology pathway as the most effective and credible means of achieving our statutory emission reduction targets in the buildings sector.
Finally, future PPS may set further and more specific ambitions in this context; for example, there may be a need for technology specific PPS (such as any new and emerging hydrogen and bioenergy PPS) as well as lower tier plans. Where any future policies and proposals are developed, these will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act
Next steps and consultation
Public views and comments are invited on both this Environmental report and the consultation on Proposals for a Heat in Buildings Bill to which it relates. Responses are invited by 8 March 2024. These can be submitted:
- Online using the Scottish Government’s consultation platform, Consultation Hub, at: https://consult.gov.scot/energy-and-climate-change-directorate/heat-in-buildings-strategy/. Consultation Hub allows you to save and return to your responses while the consultation is still open. A copy of your final response will be emailed to you.
- By Email: Responses can be submitted by email, with the Respondent Information Form to HiBConsultation@gov.scot
Following the consultation, a Post-Adoption Statement will be prepared. The Statement will reflect on the views provided on the findings of the assessment and the proposals in the consultation paper and will explain how the issues raised have been taken into account in finalising the Heat in Buildings Bill.
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