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

3. Campaign Responses

Two campaign responses were identified within the 1637 consultation responses. To avoid the thematic analysis being dominated by the views put forward by one specific campaign, this chapter summarises the number of responses and key points raised in each campaign, with key themes then noted at appropriate points throughout the report.

Campaign 1: Replacing oil heating with renewable liquid fuels

A total of 156 respondents submitted their response by letter or email, using a pre-prepared template^[3] as follows. This represents almost one in ten of all those responded to the consultation. These respondents expressed their opposition to the proposals, particularly in relation to the impact of the Standard on traditional buildings, and called for the continued use of bioenergy in certain circumstances, particularly rural properties.

Submission to Heat in Buildings Bill Consultation

As a homeowner with oil heating, I want to play my part in reducing my carbon emissions, but I am very concerned about these plans.

As one of the 135,000 homes in Scotland on oil heating, I am submitting my views to the Heat in Buildings Bill Consultation for consideration:

• I strongly oppose the proposal to prohibit the use of polluting heating systems in all buildings after 2045. Systems that use biofuels such as HVO such be permitted, and indeed supported.
• I support the aim of improving energy efficiency but I oppose your plans to introduce a minimum energy efficiency standard to be met in owner occupied homes (which still have a polluting heating system) by the end of 2033, unless they are redesigned in a way that avoids imposing unreasonable cost or disruption on owners of homes that are difficult to improve – for example due to constraints such as solid walls.
• I strongly agree that the use of bioenergy should continue to be permitted in certain circumstances as, for many properties, switching to the government’s preferred choice of a heat pump will be very expensive and disruptive.

According to the government’s online calculator, for many rural properties the cost of installing a heat pump and making all the necessary changes to make it work effectively could exceed £20,000. This is because new radiators are often required, alongside insulation improvements, new piping and the introduction of a new hot water tank. There is also a cost associated with the disposal of the old heating system and storage tank.

I’m sure you would agree this is simply unaffordable and would be highly disruptive.

I am therefore submitting my view that households like mine should be given the choice to instead keep their oil boiler but switch to a renewable liquid fuel such as HVO.

A report on an industry demonstration project which saw nearly 150 properties make the switch from oil heating to HVO has demonstrated it is a viable option, with the conversion costing less than £500 and emissions being reduced by nearly 90%. All the evidence shows this is the most affordable and realistic low carbon solution for my property.

If the Scottish government is serious about making the kind of changes we need to in order to achieve our net zero ambitions, then renewable liquid fuels must be recognised and supported alongside heat pumps and other low carbon heating technologies.

Thank you for taking the time to read my submission. I look forward to seeing the publication of the full consultation responses.

In addition, 25 respondents emailed the consultation team to express similar concerns about the impact of the proposals on properties in rural areas. While the wording of each email differed, the same key points were raised by respondents. These included:

• Calls to allow and promote the use of bioenergy such as HVO (Hydrogenated Vegetable Oil) in rural or off gas-grid homes which currently use oil or kerosene central heating.
• Challenges of using heat pumps in traditional properties without significant modifications, or concerns that heat pumps will not work effectively in older or listed properties. A few also noted the higher running costs of heat pumps.
• Calls to acknowledge the need for alternative heating systems in rural areas where electricity supply is less reliable in bad weather.

Campaign 2: Support for the proposals

Nine respondents sent in similarly worded emails in support of the proposals. These emails were brief, with respondents noting their support for the following five points:

• The proposal to prohibit the use of polluting heating systems in all buildings after 2045.
• The proposal that people buying a property comply with the prohibition on polluting heating within a specified period following purchase.
• A minimum energy efficiency standard to be met by private landlords by the end of 2028.
• A minimum energy efficiency standard to be met in owner occupied homes by the end of 2033.
• The proposal to require all buildings owned by a Scottish public authority to be using clean heating systems by 2038.