Delivering net zero for Scotland's buildings - Heat in Buildings Bill: consultation analysis

10. Conclusions

Many individuals and organisations with detailed knowledge participated in the consultation, sharing their views on the proposals to change the way Scotland’s homes and buildings are heated. This report provides a high-level summary of the consultation responses^[4].

While the closed-ended question results indicate support for many of the proposals presented in the consultation, a range of views were expressed in open-ended comments with both supporters and opponents often highlighting issues to consider if the proposals are progressed. Several themes were evident in responses to multiple questions. These overarching themes reflected respondents’ concerns about the cost and affordability of the proposals, the feasibility of the proposals in different types of building, criticism of the Scottish Government’s approach, reasons for support and calls for further clarification.

Overall, the closed-question results recorded majority support among those answering for the proposal to prohibit the use of polluting heating systems in all buildings after 2045, and to introduce a minimum energy efficiency standard to be met by private sector landlords by the end of 2028 and by owner occupied homes by the end of 2033. However, respondents highlighted a range of considerations to ensure the transition to clean heating is equitable and just. There was strong support for the continued use of bioenergy in some circumstances, particularly in rural, remote and island areas.

Mixed support was evident for installing a list of measures to meet a minimum energy efficiency standard, or an equivalent standard if the list of measures was not appropriate for specific properties, with organisations more likely to be in favour than individuals. The need for flexibility was emphasised to accommodate the construction and energy efficiency demands of different building types. Both positive and negative views were expressed about the effectiveness of using a reformed EPC as an alternative to a list of measures.

Very mixed views were evident regarding introducing a requirement to end the use of polluting heating following a property purchase. While many strongly supported the proposal, many others, particularly individuals, were strongly opposed. Similarly polarised views were evident in relation to giving Scottish Ministers powers to extend the circumstances in which people could be required to end their use of polluting heating. There was, however, more support for both a grace period and cost-cap, but with no clear consensus on which of the proposed options for each would be most appropriate. Qualitative comments were also mixed, with respondents raising a range of issues and concerns, in particular the potential negative impact on Scotland’s housing market.

The proposal to give powers to local authorities and Scottish Ministers to connect new buildings to a Heat Network Zone was well supported. However, concerns were expressed around the level of development and long-term viability of heat networks and consumer protection, leading to calls for more information about these proposals and heat networks in general. There was broad support for powers to mandate non-domestic building owners to share information about unused heat and to provide this to a local heat network. However, questions were raised about whether this would work in practice and how any additional burden on organisations would be minimised.

There was a preference for a nuanced approach to monitoring and enforcement with respondents more often supporting a combination of monitoring methods and a mix of ways to enforce the Standard. While high levels of support for exemptions and time extensions were recorded in closed questions, open questions allowed many respondents to articulate concerns, considerations and caveats to their support, in particular the need to provide financial support for the transition and for exemptions and extensions to be fair, flexible and pragmatic. A wide range of different types of buildings and groups of people were suggested as being eligible for modifications to the Standard, though this was opposed by some who believed the standard should apply to everyone equally.

While there was widespread support for public authorities to lead by example by transitioning to clean heating by 2038 and for new duties to help them plan for the transition, concerns were raised about the cost and staff resource implications of both the change to clean heating systems and monitoring progress.

Overall, the key message is that while there is support for the proposals, respondents identified multiple challenges and potential consequences of implementing the measures. The responses provide valuable and informative evidence for the Scottish Government to draw on when developing a Heat in Buildings Bill and providing information to explain the nature, design and timings of any regulations that the proposed Bill may enable.