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

2. Overarching qualitative themes

On average, one third of respondents left a qualitative comment at each open-ended question or explained their views in alternative format responses. In the same way that the quantitative analysis is based on those answering the closed questions, the themes highlighted in this report represent the views of respondents who chose to comment.

While the consultation questions asked respondents to reflect on the individual proposals, several themes were evident in response to multiple questions. To avoid repetition, this chapter outlines these overarching themes, which include:

• The cost and affordability of the proposals.
• The feasibility of the proposals in different types of building.
• Concerns about the Scottish Government’s approach.
• Calls for further clarification.

Common themes have been grouped together, but the groupings and themes within each group are ordered from most to least prevalent.

As noted in the introduction, while the closed-ended question results indicate support for many of the proposals, a range of views were expressed by respondents in open-ended comments. Both supporters and opponents of proposals raised concerns or highlighted other issues to consider if the proposals are progressed, while supporters often qualified their support or reiterated the importance of considerations or mitigating actions that were noted in the consultation paper. For example, depending on a respondent’s view, comments about cost and affordability could be given as a reason for opposing a proposal, or highlighted as a necessary consideration for the proposals to be successfully implemented..

Cost and affordability

The potential cost of the proposals was the most prevalent and recurring issue across almost all consultation questions. Multiple themes were evident in relation to cost, but with two main areas of focus: questions about who would pay for the transition and the assertion that the Scottish Government would need to provide a significant level of financial support to cover the costs. More information about the types of people who might benefit from being exempt from the proposals is provided in Chapter 7.

Financial support is required

The most prevalent theme across all questions was that the Scottish Government would need to provide substantial support to see change on the scale that is desired. Most calls for support focused on financial support in the form of grants, subsidies, zero or low-interest loans, or funding to cover all or most of the fabric modification and heating system transition costs. This was the most common overarching theme among individuals and the second most prevalent among organisations and was particularly prevalent in Q3 (introducing a minimum energy efficiency standard in owner occupied homes by the end of 2033). A few comments expressed the view that the current funding options for home energy improvements are too complex and disjointed.

Calls for non-financial support were more limited, and focused on where advice and guidance to householders and businesses would be useful; these instances are detailed under specific questions.

“Unless there is financial support and sweeteners - grants, etc - people are going to be reluctant to make expensive changes, as they can’t afford it on top of everything else. There needs to be government subsidies to make the change.” – Individual

“To meet the nation’s Net Zero commitments, our members recognise the need to decarbonise heating in UK housing in addition to improving home energy efficiency and are thus supportive of this measure. We would caveat this support by noting that the proposal needs to be coupled with other measures to support the transition to clean heating and ensure that homeowners are not burdened with unaffordable mandates… At a minimum, for consumers, this strategy should include advice and guidance on home energy efficiency and financial support for those least likely to afford compliance. The latter could take the form of grants and subsidies, but other measures to make this more affordable should also be considered.” - Building Societies Association

Cost of transitioning to clean heating systems

Many respondents, particularly individuals, made general comments about the cost to individuals and businesses of making the changes outlined in the consultation. It was often argued that the proposed changes would be expensive, and that replacing a heating system could also come with additional costs if other changes had to be made to the fabric of the building to ensure the new system runs efficiently. Respondents argued that households and businesses do not typically have reserve funds to make these changes, especially in the current cost-of-living crisis or if they have just had the expense of buying a new home.

“The cost will be such that most will not be able to afford to make the changes and that the Scottish Government will not be able to subsidise this.” - Individual

“The cost to decarbonise all the households in Scotland is estimated to be £23.5bn-£26bn by 2030 (Affordable Warmth report, WWF Scotland, 2023) and the current support from Scottish Government has only a budget £1.8bn for this Parliamentary term that is also for all buildings including non-domestic. The huge financial gap cannot be expected to be covered by homeowners and private sector.” – Scottish Property Federation

A small number of comments were made across the consultation about how the proposals could lead to increased costs to the public sector, or ultimately back to the taxpayer, if local authorities or the Scottish Government needed to subsidise or pay for the changes being made or had to increase taxes to generate funds to provide financial support.

Affordability of energy

A more specific theme about the cost of implementing the proposals was a concern that it could increase heating costs and create a rise in fuel poverty. Respondents highlighted that many of the potential clean heating systems run on electricity and that the per-unit price of electricity is more expensive than gas. As a result of switching, households could need to spend significantly more to heat their homes to the same level as before. While mentioned by few throughout, this theme was particularly prevalent in relation to Q5, Q6 and Q7 about using a list of measures to meet a minimum energy efficiency standard.

“From a purely climate change-orientated perspective, we strongly support these proposals. It is good to see a clear cut-off date for polluting heating systems. We cannot, however, support them from a fuel poverty perspective. At the time of this consultation, the retail price of electricity, per kWh, is approximately four times more expensive than gas.” - The HEAT Project, part of Blairgowrie and Rattray Development Trust

Feasibility in different types of buildings

Respondents repeatedly raised concerns that the proposals were impractical or unfeasible for a large proportion of Scotland’s housing stock as well as other buildings. In particular, traditional buildings, flats and rural properties were frequently noted as being less suitable for both energy efficiency improvements and clean heating systems. These themes were especially noticeable in responses to Q1-Q8 about the Heat in Buildings Standards and Q18-Q23 about monitoring and enforcement.

Traditional buildings

Comments about traditional buildings cited old, historic, or listed buildings and mostly focused on how the construction of those properties made them unsuitable for clean heating systems. This included the challenges of incorporating clean heating systems into the building and taking a fabric-first approach to improving the energy efficiency of the building. Characteristics such as stone walls were often cited. This was the third most prevalent overarching theme among individuals.

“The nature of the building must also be considered; historic buildings do not have cavity walls for example and their outside stonework does not simply lend itself to external insulation. There is not sufficient clarity regarding the position of historic buildings, nor even a definition of these, to enable constructive comment.” - Individual

Remote, rural and off-gas grid buildings

Respondents often cited the proposals as impractical for remote and rural buildings. Again, there were concerns about the typically more traditional construction of these buildings, as outlined above. Respondents also highlighted the need for heating systems that do not rely on electricity due to the inclement weather in more remote parts of Scotland and the lack of suitable alternatives, e.g. heat networks in rural areas. As well as the questions above, this issue was commonly raised in Q8 about the continued use of bioenergy.

Flats and tenements

Concerns were also frequently raised about the difficulty of applying the proposals to blocks of flats. Two main issues were highlighted. Challenges with traditional blocks of flats, particularly stone tenements, were often noted and were the same as the concerns about traditional buildings more generally. More specifically, respondents argued that flats were less able to use alternative heating systems such as solar^[2] or heat pumps or to connect to heat networks than individual homes. The other issue raised was the challenge of getting multiple owners to agree to changes to the overall structure of the building.

“Tenements – whether they are historic stone-built buildings, 50’s and 60’s-era four-in-a-blocks, or modern apartment complexes – are home to millions of people across Scotland. As Scotland’s only charity dedicated to providing information on repairs, maintenance, and retrofit for owners of tenement flats, we are concerned that the Government will not be able to achieve the goals set out in these proposals by 2045 due to the complexity of rules governing tenements repair, maintenance, and retrofit.” – Under One Roof

Measures need to be relevant / flexible to individual buildings

While there were calls for exemptions from the Heat in Buildings Standard, as covered in Chapter 7, not all felt this was necessary. Another overarching theme, particularly among organisations, was that there needs to be more flexibility in the proposals and that they should only apply to appropriate buildings. Respondents frequently stated that the proposals need to consider the variety of Scotland’s housing stock, be relevant to different types of buildings and have the flexibility to consider applying the measures or allowing exemptions on a case-by-case basis depending on the suitability of each building.

“There needs to be consideration of the different archetypes of building, given that every building will have specific requirements in terms of maximising energy efficiency. The way a building is designed and built is closely linked to the optimal way it should be heated. It will be important to avoid unintended consequences where new buildings may have more sustainable heating systems, but their design means they are less energy efficient and the materials they use for insulation have high levels of embodied carbon.” – Highlands and Islands Enterprise

“In addition, there are concerns around the proportionality of the Standard. For example, there are some building types that just cannot be modified to reach minimum energy efficiency standards. If the owner of a building has done almost everything they can do based on the restrictions of say a stone built listed building in a conservation area, then that should be reflected in their EPC rating. The building should be rated based on its limitations - it should not be rated alongside a modern energy efficient building.” – Royal Institution of Chartered Surveyors (RICS)

Criticism of the Scottish Government’s approach

A third group of overarching themes expressed criticism of the proposed approach. Three themes were raised consistently across the consultation, mostly by individuals, with many repeating the same comment in multiple questions.

Should not be up to the government to decide

A frequently raised concern was that it should be up to the individual or business to decide how to heat their property rather than being told how to do so by politicians or the Scottish Government. While some comments focused on the need for free choice, others went further and described the proposals as government interference or overreach. This was the third most common individual overarching theme overall and the second most prevalent among individuals across the consultation.

“Your drive to 'compel' everyone to achieve these standards is impractical, and financially unachievable for most people. The costs you indicate that people might incur are hugely underestimated. The desire for 'compulsion' should be ended and instead, you should trust people to make their own choices.” - Individual

Negative views of politicians

Other respondents made more general comments about the effectiveness of politicians, the SNP, the Scottish Green Party, and the Scottish Government. These included comments about the political agenda being too driven by green issues and the inability of politicians and the Scottish Government to work effectively.

Unlikely to make a difference

A less common overarching theme was general cynicism that the proposals would have any impact. Some felt that the scale of Scotland’s emissions was low compared to larger countries, and, therefore, any reduction due to the proposals was unlikely to have a significant impact at a global level. Some others expressed a view that there is no climate emergency and there is, therefore, no need to reduce emissions or for the proposals.

Further clarification required

While not raising a specific issue, calls for further information or more detail about the proposals were raised throughout responses. This was the second most prevalent individual overarching theme overall, and the most common among organisations. Details about the specific clarifications requested is provided under the analysis of each question, but it is important to note the need for further clarification more generally.

Other overarching themes

Lack of suitable alternatives

Concerns were often raised about the proposals making assumptions about the availability and effectiveness of clean heating systems. It was often argued that this technology is still developing and is currently either not effective for Scotland’s climate or housing stock, or too expensive. Some respondents noted that, should a property owner need to make a change in the next few years, it could be to the detriment of a cheaper or more effective alternative becoming available at a later date. Many of these comments focussed on the effectiveness of heat pumps. Heat networks were also considered, but these are addressed more in Chapter 6.

“I feel the disruption and expense require more time. Also technology needs more time as some heating systems which currently would not meet the proposed standards may meet them in the future. Homeowners could find themselves removing a heating system and incur high costs to discover later that this was not needed due to improved technology.” - Individual

Incentivise rather than enforce

Some respondents argued that the proposals had too strong an emphasis on enforcement and penalising those who did not comply, rather than considering what could be done to encourage people to change to clean heating systems. For example, it was suggested that rather than focusing on fines for non-compliance, there should be incentives such as a reduction in Council Tax to encourage people to comply. Some disagreed with the use of legislation to compel people to change.

“Encouraging the public to transition towards net zero should be based on persuasion and incentive, not regulation, enforcement and "civil penalties". - Individual

Timescales

While comments about timescales were made throughout the consultation, these were more prevalent in relation to proposals which had a set target date and are therefore addressed in more detail under each of those questions.

Capacity concerns

A concern that was repeatedly raised by some respondents issue was Scotland’s capacity to implement the proposals. Given the timescales provided in the consultation paper, it was often suggested that the lack of skills, equipment and capacity could make it challenging to meet the target dates given the likely increase in demand. This focused on three areas. Firstly there were concerns about a lack of skilled people to install and maintain clean heating systems; a few noted this could be a particular challenge in rural areas. Others commented on the lack of a developed supply chain to meet the potential demand for clean heating systems. A smaller proportion noted that, because many of the clean heating alternatives rely on electricity, Scotland’s electricity generation and distribution infrastructure would need a significant upgrade to ensure it is fit for purpose.

“The capacity of the skilled workforce within the heating and plumbing profession to meet the surge in demand for clean heating installations is equally crucial. Assessing the readiness of the current workforce to tackle this upsurge, including the availability of skilled professionals, the necessity for further training programmes, and the opportunities for job creation in the sector, is essential. Achieving the lofty aim of converting all buildings to non-polluting heating systems by 2045 hinges on a strategic commitment to workforce development and skills training.” - Scottish and Northern Ireland Plumbing Employers Federation (SNIPEF)

While not raised frequently, a few respondents across the consultation and a small number of event participants noted the importance of regulating organisations who install and maintain new heating systems. There was a concern that unskilled tradespeople could provide bad advice, install inappropriate systems or install them badly, and so there were calls for suitable protections for consumers against bad practice.

Important for decarbonisation and tackling climate change

When respondents expressed support for the proposals they often gave specific reasons for doing so; these are outlined under specific questions. However, another overarching theme was a broader expression of support for the proposals as they were felt to be important to help Scotland on its path to net zero. These respondents acknowledged the need for change and believed the proposals were an important way to drive behaviour change and decarbonisation in the way Scotland heats its buildings.

“Garnering public support will be crucial to success. To balance the considerable costs of decarbonisation, the RSE recommends highlighting the significant benefits from this transition. The narrative must demonstrate that clean energy and building retrofit is advantageous for health, comfortable homes, workplaces, community facilities and local jobs, and essential for ensuring that Scotland does its part in creating a liveable environment for generations to come.” Royal Society of Edinburgh