Funding to Rural Stirling Housing Association (RSHA) for the Croftamie development: FOI release

Information requested

I am writing to seek clarification on the conditions attached to Scottish Government funding provided to Rural Stirling Housing Association (RSHA) for the Croftamie development, specifically in relation to the installation of the air source heat pump (ASHP) systems.

I would be grateful if you could confirm:

1. Whether funding provided through the More Homes Division for the Croftamie development was intended to be used, in whole or in part, for the installation of air source heat pumps as the primary heating system; and

2. Whether, as a condition of that funding, there was a requirement or expectation that the ASHP installation be carried out by an installer certified under the Microgeneration Certification Scheme (MCS).

I note that while published, More Homes Division guidance focuses primarily on building standards and performance outcomes (such as the provision of zero direct emissions heating), wider Scottish Government policy and practice treats MCS certification as the recognised quality and competence standard for heat pump installations supported by public funding. This is reflected in other Scottish Government programmes (for example, Home Energy Scotland schemes) and in the provision of an MCS Certification Fund to support installer accreditation.

Given this wider policy context, I would appreciate clarification on how installer competence and certification requirements were intended to be addressed for ASHP installations funded through the More Homes Division at Croftamie.

Can you also supply any supporting links or documents that confirms a breakdown of the conditions of this funding including the requirements or rules rsha must meet to ensure rent is affordable and remains affordable going into 2040.

Also please advise who i can raise any concerns with if I feel rsha has not met or adhering to the conditions of the funding. For example if the cottage flats on this development are not proving to be energy efficient.

Id ask that this information is provided in easily clear understandable layman terms.

Response

The answer to your questions is provided below:

Whether funding provided through the More Homes Division for the Croftamie development was intended to be used, in whole or in part, for the installation of air source heat pumps as the primary heating system.

Rather than being for specific items, our grant offer of 28 July 2023 was a contribution towards the total cost of delivering the homes at Croftamie. The cost of installing air source heat pumps was part of that total cost.

Whether, as a condition of that funding, there was a requirement or expectation that the ASHP installation be carried out by an installer certified under the Microgeneration Certification Scheme (MCS).

I note that while published, More Homes Division guidance focuses primarily on building standards and performance outcomes (such as the provision of zero direct emissions heating), wider Scottish Government policy and practice treats MCS certification as the recognised quality and competence standard for heat pump installations supported by public funding. This is reflected in other Scottish Government programmes (for example, Home Energy Scotland schemes) and in the provision of an MCS Certification Fund to support installer accreditation.

Given this wider policy context, I would appreciate clarification on how installer competence and certification requirements were intended to be addressed for ASHP installations funded through the
More Homes Division at Croftamie.

There were no specific conditions attached to the grant funding that would have required or expected the air source heat pump installation to be carried out by an installer certified under the Microgeneration 
Certification Scheme.

However, the 32 local authorities in Scotland are appointed by Scottish Ministers as verifiers to administer the building standards system for their own geographic area. The Scottish Government is unable to comment on individual cases and, accordingly, any project specific issues should be directed to Stirling Council’s building standards department as the administrating authority. The following is provided on that basis.

Mandatory standard 6.3 ‘Heating system’ of the Scottish building standards system requires that “Every building must be designed and constructed in such a way that the heating and hot water service systems installed are energy efficient and are capable of being controlled to achieve optimum energy efficiency”.

Guidance in support of the mandatory standard is provided in clause 6.3.1 ‘Performance of fixed heating systems in new and existing buildings’ within the Domestic Technical Handbook. This guidance refers to the Domestic Building Services Compliance Guide for Scotland which sets out the minimum performance of space heating and hot water systems, heating appliances and controls. Guidance within Section 4: Heat Pumps indicates that “It is recommended that heat pumps should be designed and installed in accordance with the technical standards given in the Microgeneration Certification Scheme’s Microgeneration Installation Standard: MIS 3005”.

Can you also supply any supporting links or documents that confirms a breakdown of the conditions of this funding including the requirements or rules rsha must meet to ensure rent is affordable and remains affordable going into 2040.

I enclose a copy of the grant offer letter for the Croftamie development dated 28 July 2023 showing the conditions associated with the offer. An exemption under section 38(1)(b) of FOISA applies to a small amount of the information you have requested because it is the personal data of a third party and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

In addition to the terms of the grant offer letter, registered social landlords have a legal responsibility for setting rents in consultation with their tenants. In this respect, the Housing (Scotland) Act 2001 requires a landlord – where it is proposing to increase rents or any other charges for Scottish Secure Tenants – to consult those of its tenants who would be affected by the proposal and to have regard to the views expressed by those consulted. The Scottish Social Housing Charter highlights this legal duty and the importance of taking account of what current and prospective tenants are likely to be able to afford, with the Scottish Housing Regulator monitoring social landlord’s achievement of the Charter.

Also please advise who i can raise any concerns with if I feel rsha has not met or adhering to the conditions of the funding. For example if the cottage flats on this development are not proving to be energy efficient.

Concerns about not meeting or adhering to the conditions of funding should be addressed to Keith Fernie, North & East Area Manager, More Homes Division – keith.fernie@gov.scot.

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FOI 202600506189 - Information Released - Croftamie grant offer letter

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