Building (Procedure) (Scotland) Amendment Regulations 2024: island communities impact assessment

Gathering Data and Identifying Stakeholders

24. The consultation sought general comment on principles and processes to allow changes to regulations to be confirmed and laid in December 2024. These are as an enabling action for changes to published documents and processes which will be subject to further consultation in summer 2025. Annex A of the consultation summarised proposals for potential regulatory change to support the review outcome.

25. Notification of the consultation is issued to a list of individuals and organisations previously identified as having an interest in building standards.

Context – new development in island communities

26. To provide an illustration of the level of new development taking place in island communities, reference can be made to analysis was undertaken for the previous energy standard review which concluded in 2023 and identifying development by Scottish Islands postcode areas. For this purpose, only postcode sectors specific to island communities were reported. Those which are shared with mainland areas were not.

• HS1-9: Lewis & Harris, Scalpay, North & South Uist, Benbecula, Barra
• IV41-49, 55-63: Skye, Raasay
• KA 27: Arran
• KW15-17: Orkney Islands
• PA20: Bute
• PA41-78: Gigha, Islay, Jura, Colonsay, Mull, Iona, Tiree, Coll
• PH42-44: Eigg, Rhum, Muck, Canna
• ZE1-3: Shetland Islands

27. Main heating fuels were reported to inform discussions, noting the absence of mains gas as an option in the islands, and to support the pending move away from ‘direct emissions heating systems’ from 2024.

28. Summary points from analysis are noted below:

• New dwellings – 1.9% of new development (450 units) took place on island communities.

These were fuelled 91.5% by electricity, 4.5% by oil, 2% mains gas (Bute) and less than 2% each other fuels. No units completed using district heating as a fuel but we are aware there is a network in Lerwick and connections are proposed. This compares to 80% by mains gas, 12% electricity, 6% district heating and 1% each LPG and oil in non-island communities. (Source - Scottish EPC data 2017-21)

• New non-domestic buildings - 2.2% of new development (by area) took place on island communities. This accounted for 4.2% of the number of new developments.

These were fuelled 75% by electricity, 12% by oil and 5% each by LPG or district heat; 3% other fuels. This compares to 51% by electricity, 37% mains gas, 4% biofuels, 3% by LPG, 2% district heating and 3% other fuels in non-island communities. (Source - Scottish EPC data 2021)

Context – factors affecting development on island communities.

29. Prior discussion on the impact of the proposed changes has provided an awareness (and verification during engagement) of pre-existing factors which already affect development in island communities:

• Higher construction costs (higher cost of living generally)
• Standard construction cost indices do not give the full picture – too generalised and not up-to date enough.
• Fuel poverty higher in island communities
• Reduced supply chain options; operatives, transport, sourcing of solutions
• Mains gas for heating is not an option
• Some islands have no grid connection
• Weather & climate more extreme; relevance of ‘national standards’ to more remote areas. Need for local solutions to local circumstances.
• An abundance of renewable energy but often a lack of mechanisms to utilise that for benefit at a building level?