Housing to 2040: consultation analysis

Report summarising and describing the responses to the public consultation on Housing to 2040.

Analysis of Question 5. Do you have any proposals that would help us respond to the global climate emergency by increasing the energy efficiency and warmth and lowering the carbon emissions of existing and new housing?

Respondents provided a wide range of very detailed responses to this question and made a series of suggestions for increasing the energy efficiency and warmth, and lowering the carbon emission of existing and new housing. 

Key issues raised included:

  • The need for greater regulation and higher standards to be applied to new build housing across all tenures.
  • The importance of ensuring that adaptations are made to existing housing stock.
  • The importance of trialling new construction methods to enhance energy efficiency and reduce carbon emissions. 
  • The need to ensure a transition from oil and gas to other energy forms.
  • The tensions between energy efficiency and heritage.
  • The need for a mix of regulation and monitoring alongside education, advice and financial support across all tenures. 

A more detailed analysis of the responses to this question is provided below.

New housing

Many respondents made suggestions relating to increasing the energy efficiency and lowering the carbon emissions of new housing. Many observed that, in relation to social housing, good progress was being made (with room for further steps to be taken), but that more needed to be done to apply the same standards more consistently in relation to privately built housing. 

Generally, respondents called for tighter regulations which required higher standards to be met. This included, for example, respondents calling for regulation to be introduced as a matter of urgency to ensure that new build dwellings do not continue to rely on natural gas as the main fuel source for heating.

Many respondents encouraged the introduction of more innovative construction methods including modular build, factory and off-site build; testing of new/alternative recycled building materials; and local sourcing of materials and labour to minimise impact to the environment (and improve affordability). Passivhaus standards were frequently cited as an example of innovative construction methods which have demonstrated energy efficiency with positive impacts on health and wellbeing.

Some of the most frequently arising proposals made by respondents in relation to new housing are described in the table below.

Table 6.1: Frequent proposals for increasing energy efficiency and lowering carbon emissions in new housing

Design & Development

  • Whole roof PV (and/or PVT (for example Consolar Solink)) (Use in 5GDHC)
  • Ensuring internal drying spaces
  • Including cycle storage in homes and other buildings
  • Work with structural engineers to step up to this challenge

Energy Efficiency

  • Installing triple glazing as standard
  • Installing Solar panels on all new builds as standard that provide power to the home or can be linked up to contribute to the National Grid
  • Installing heat pumps
  • 4GDH ULTDH heat networks with inter-seasonal storage (e.g. BTES)

Carbon Reduction

  • The use of sustainable and recycled materials as a means of reducing our carbon footprint
  • Requiring developers and builders to incorporate planting trees in new housing developments
  • The use of sunspaces and buffer zones to be included as eligible measures in developing low carbon homes and should be supported through planning and building standards
  • Target 50% reduction in embodied carbon in building design

Three innovative approaches to increasing energy efficiency and lowering carbon emissions in new housing are summarised in the table below.

Table 6.2: Innovative approaches to increase energy efficiency in new housing

Example 1: Private landowner

The Scottish Government could adopt a system similar to the Dutch ‘Madaster Platform’, a material passport within the construction process. A material passport approach could be accommodated within the existing ‘Building Information Modelling’ (BIM) process.

Example 2: Academics

Adopt a "Horizon Net Zero" approach. This can include:

  • designing for manufacture & assembly (offsite)
  • designing for future disassembly
  • designing for material recovery and reuse by future generations (given future world shortages of material resources)
  • designing towards sequestration of carbon within buildings (greater use of timber, preferably home-grown where possible)
  • designing using recycled or reused materials (such as sand and demolition waste within concrete block and concrete products)

Example 3: Registered social landlord

In all our developments Home Group pursues environmentally friendly procurement through the evaluation of the environmental impact of the contracts awarded. This focuses on the use of whole life costs in procurement decisions, adopting the principle of ‘reduce, reuse and recycle’ or selecting low energy alternatives.

As with other projects, at the Springburn Way development in Glasgow where we have created 40 high quality 2-bedroom homes for social rent, we have taken a fabric first approach and incorporated a range of sustainability initiatives which include:

  • Meeting the building regulations full silver standard 1-8 
  • High efficiency boilers with heat recovery
  • Solar panels 
  • Ducting for future electric car charging points

One respondent suggested that the opportunity for housing sites to absorb carbon should also be prioritised.

"Carbon costing and careful development avoiding development on carbon rich soils is one of the initiatives that could be taken forward. Soils are good source of storing carbon and future housing development would have a huge impact on carbon loss. A policy at the local level would help to reduce losses from soil carbon." - Local authority

A few respondents encouraged the Government to develop a national policy approach to green roofs and green walls that was "appropriate in a Scottish context and suggested there may also be a role for settings targets for green roofs in particular towns and cities where the need to manage surface water in a changing climate is a constraint on further development." A few respondents went as far as to suggest that building regulations should mandate the use of green roofs on all residential buildings with significant areas of flat roof. 

Assessment and review were also considered by many to be important. For example, some respondents suggested inspections following completion of new housing which specifically assessed energy efficiency. One respondent, for example, felt that the government should require 100% of new and refurbished homes to be subject to post-occupancy evaluation (POE) and building performance evaluation (BPE) which would be carried out within 12 months of completion of the work.

Infrastructure for electric vehicles

Some respondents emphasised the importance of ensuring that there is provision for electric vehicle charging points. In new build housing, this would mean ensuring that appropriate cabling was laid at the point of construction. Alongside this, some respondents called for grants for electric vehicle charging points to be made available to people already owning or intending to invest in an electric vehicle.

Other related ideas included electric car clubs and electric cargo bikes.

Renewable energy and alternative heating options

Many respondents made reference to the need to ensure that renewable energy and alternative heating options - including low carbon heating options and air source/ground source heat pumps - were embraced. They emphasised that models like the Home Energy Efficiency programmes need to be rolled out across the country across all tenures and quicker progress should be made on introducing low/zero carbon district heating schemes. 

"The use of green infrastructure to reduce energy demand insulating and cooling and to reduce exposure - planting around housing can help to address climate change while delivering wider co-benefits such as health and wellbeing and for biodiversity etc." - Local authority

Table 6.3: Renewable energy and alternative heating proposals 

Renewable Energy

  • Solar panels on all new builds as standard that provide power to the home or can be linked up to contribute the National Grid
  • Deployment of solar arrays on brownfield sites to promote biodiversity growth
  • If water can be used for hydrogen production, Scotland has a plentiful supply. Should keep Scottish Water as a publicly owned company but partner with Scottish Gas Network (SGN)/Centrica etc. for supply

Alternative Heating Options

  • Heat pumps central/local (both may be best: central district heating heat pump, plus micro booster HP in properties)
  • 4GDH ULTDH heat networks with inter-seasonal storage (e.g. BTES)
  • Heat from sewers to be used to heat tenements – small block by block systems (SHARK project at the Borders College in Galashiels uses sewers to heat buildings)
  • Community-based local heat and energy schemes
  • Easy to introduce hydrogen heating, especially in cities where there are apartment blocks – most properties will have access to the gas network and would not require massive disruption to convert/introduce
  • Community heating systems may be viable and have greater buy-in in rural areas. However prohibitively expensive to retrofit – should be considered for industrial/commercial builds

Some respondents highlighted the challenges posed currently – including sustainable and renewable energy options for heating homes unable to compete with the low cost of gas, making them an unviable option for many people. 

In addition, some respondents noted a need for there to be more equality around standards for energy (Energy Efficiency Standard for Social Housing[17] (EESSH), etc.) across all tenures and grants for those who cannot afford to participate.

More extensive use of timber in new-build housing

Some respondents emphasised the importance of using more wood in new build housing to reduce the impact on the environment (and respond to the global climate emergency).

They suggested that there should be more focus on reducing the whole-life carbon impact of new homes and that policies would be needed to support the increased use of timber frame construction systems. Furthermore, they felt that the construction and manufacturing sectors should explore options for offsite construction, which could significantly reduce construction site emissions.

Some respondents also felt it was important to highlight that the timber should come from certified sustainable sources. 

Existing housing

Many respondents identified the need to ensure that existing stock was also improved in relation to energy efficiency and warmth, with some emphasising the importance of accelerating the process of retro-fitting.

Many also emphasised the need for higher standards, as applied to social housing, to be applied across the wider domestic sector and for this to be appropriately regulated. Some acknowledged that this may require financial incentives, coupled with awareness raising and education to encourage compliance.

Table 6.4: Suggestions for improvements and changes to existing housing

Encouragement/ Support for Private Landlords/Owners

  • The need to incentivise owner occupiers to make improvements to energy efficiency standards by setting minimum EPC ratings and require those to be met before able to sell.
  • Put more pressure on private landlords and homeowners to comply with targets and standards to make homes energy efficient and fit for purpose, perhaps through a prohibition on re-sale of houses that have not met the energy rating standard. Financial support mechanism may be required beyond simply expecting them to take out a loan to do so.
  • Encourage more private rental co-operatives – these stand out for their ability to build up significant surpluses that can be reinvested in eco-efficiency measures. These co-operatives meet their costs (mortgage, maintenance, administrative) from the rent paid by their member-tenants. Over time these co-operatives build up operating surpluses which cannot be distributed to members and must instead be reinvested in the co-operative, held in reserve.

Changes to Standards Assessment

  • Relax restrictions on listed buildings to enable energy efficiency improvements to be made (e.g. double glazing)
  • EPC’s and SAP assessment methodology needs to change – currently more geared towards fuel poverty than sustainability

A few respondents noted the value of partnership working to address improvements to energy efficiency. One example of how this could work in practice is provided below.

"Carbon reduction and environmental sustainability is a major concern for us all. [We], in common with other landlords in the social rented sector, has invested heavily in addressing these challenges and have made great progress. As a result, we recognise that some of the most significant challenges remain in the owner occupied and the private rented sectors. However, there is a positive potential role for the collective strength of the social rented sector to provide the critical mass in local markets to sustain a contractor base to install and maintain a range of stock improvement measures. We intend to work with our new economic development agency in the South of Scotland to explore these matters further and enable the pace of delivery to be increased to meet the challenging carbon reduction targets that we face. This is another example of the future potential of the affordable housing sector to have an impact beyond simply serving the needs of our own tenants/customers, with the appropriate level of support." - Registered social landlord

Improved transport provision

Improved transport options and links were frequently cited as key to improving energy efficiency. For example, some respondents emphasised the importance of having fewer cars on the road by ensuring housing is built close to employment hubs. Others referred to the need to promote sustainable travel and active travel through housing policy that reinforces a more holistic and integrated approach which recognises that cycle routes and walking paths are essential to creating a more sustainable transport network. 

Revisions to the EPC Framework

A few respondents called for a review of the EPC framework and some questioned the efficacy of the current process of assessments. 

"I think the current moves to display the EPC on adverts and require landlords to meet certain EPC ratings are a good start, but I think more needs to be done. I think the EPC rating itself needs to be improved and modernised." - Individual

Another respondent described the EPC process as:

"no longer fit for purpose. By treating every property as individual and not replicating or cloning EPCs a better picture of current stock can be gathered and every home can be recommended appropriate measures (not just what current funding allows for). Funding can then be used wisely and for varying recommended measures which will also help stabilise the boom or bust energy efficiency and renewable trades." - Local third/community sector organisation

Another respondent raised concerns that the auditing of these surveys has reduced over time and that there is experience of like for like properties being assessed at different EPC bands. 

Funding to improve the energy efficiency of homes

Respondents made a range of comments with regards to potential funding routes for improving the energy efficiency of homes. These are summarised in the table below.

Table 6.5: Suggestions for funding routes to improve the energy efficiency of homes

Mortgages and Loans

  • The Scottish National Investment Bank to have a role in leading strategic investment not just in housing, but the required associated infrastructure and green finance
  • Home equity release schemes operated locally
  • 0% interest loans for energy efficiency upgrades repaid on sale of house with a charge on the property for repayment
  • Green mortgages offering cheaper rates for properties that achieve an EPC A or B rating (some lenders already offering this)


  • Grants for works to upgrade older properties across tenures for energy efficiency measures such as upgrading heating equipment, insulation installation and replacement window programmes


A few respondents noted the importance of increasing education and awareness raising in relation to energy efficiency and climate change with regards to housing. It was noted that this should include wider availability of clear, easily accessible information about the options open to people in different kinds of homes to reduce their emissions and tackle the climate emergency.

One described behaviour as being a significant part of the problem with regards to fuel poverty, energy efficiency and climate change, and that from an early age people needed to be encouraged to fundamentally change how they think about their environment. 

One respondent felt that education on carbon off-setting, funded by the government, should be introduced to help people understand how best to achieve this. Others felt it should have a greater emphasis within the school curriculum. Another person observed that there needed to be more information sharing with regards to options already available for upgrades.

Another respondent suggested that those engaged in the construction sector also required enhanced training around the "urgency of climate emergency and design and construction strategies to stop contribution to climate emergency."


Email: Housing2040@gov.scot

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