The public consultation which ran between 28 July and 20 October 2022 was an opportunity for the Scottish Government to understand a wide variety of stakeholders' views on their proposed New Build Heat Standard (NBHS). This will prohibit the use of direct emissions heating (DEH) systems in new buildings and some conversions warranted from April 2024. The consultation contained six closed and eight open questions. In total, 112 consultation responses were received from 21 individuals and 91 organisations.
Prohibition of direct emissions heating (DEH) systems in new domestic buildings
Agreement with the proposed approach for NBHS was high. However, many who agreed raised potential unintended consequences when prompted. The most prevalent concern was the perception that Scotland's current electrical grid capacity and infrastructure is insufficient. Several highlighted their belief that the proposals could be challenging to implement in rural or island areas which may be off-grid or where capacity may be lower.
The second most prevalent theme was challenges with the supply, installation, and maintenance of zero-direct emissions heating (ZDEH) systems, due to skills and material shortages. Other possible unintended consequences included: the delay or termination of planned developments of new homes; the possibility that more expensive heating systems could exacerbate fuel poverty; a sense of consumer unease over the ZDEH technology; and an uneven impact on rural areas with more off-grid locations.
Broader considerations about the proposals included the need for consumer education on ZDEH technology, concerns about energy efficiency of houses and about energy ratings systems, and a request for government-supported fiscal support package. Mixed views were expressed about the timescales for implementing NBHS; some called for it to be introduced more slowly, while a few called for it to be implemented quickly.
Respondents were asked whether there would be a need for bioenergy under some circumstances in future new build developments; around one third felt there may be situations where this was required. The most common theme was for rural communities to be exempt from bioenergy system bans, due both to the lack of connection to the electrical grid and the robustness of the grid system. A few respondents argued that exempting bioenergy systems in off-grid locations or allowing hybrid heat pumps would provide a further choice of energy supply for rural consumers. Another reason for considering exemptions included environmental concerns, particularly the use of sustainable types of bioenergy that could offer sustainable solutions for waste material, such as biomass.
Other themes each mentioned by small numbers included: suggestions for a defined criteria to determine if a home is suitable for electrification or whether biomass may be a more suitable alternative, taking into account technological, economic and environmental factors; support for the proposed Bioenergy Policy Working Group; and a desire for an acknowledgement that biofuels are evolving and should be kept under review.
Approach to conversions
There was support for the proposal related to conversions, although unintended consequences were highlighted even by those who agreed with the approach. The most common theme was a belief that the proposed approach to conversions could have negative economic consequences for individuals and communities. For example, some noted the regulations could reduce the number of buildings being converted due to increased costs. Several respondents noted that poorly fabricated houses may require a complete renovation to elevate the home to the standard of energy efficiency needed for ZDEH systems to operate effectively. A few called for more clarity around the definitions set out in the proposals.
Respondents highlighted a range of factors they believed would make the approach to conversions reasonably practicable. These included the economic feasibility of the project, grid capacity allowances, supply chain and workforce concerns, and buildings that may prove challenging to convert entirely to ZDEH systems, such as historic and multioccupancy buildings.
When asked how the proposals could impact people with protected characteristics, the most common them was a concern based on the presumption that ZDEH could raise the cost of heating homes. Respondents suggested this increase could result from greater use of electricity, which they believe would cost more than gas, or because a conversion may not meet insulation standards. The second most common theme was a belief that the proposals would have no impact on equalities or people with protected characteristics. Some respondents mentioned positive outcomes for those with protected characteristics suggesting that costs for heating with ZDEH systems would be lower.
Of those responding to the question about the how proposals help the Scottish Government ensure the three needs of the Public Sector Equality Duty (PSED), the most common theme was that it would advance equality in housing between those who have protected characteristics and those who do not. Some respondents suggested ways in which the PSED can be considered, such as ensuring ZDEH systems are accessible and easy to use for all.
More than half anticipated some non-domestic buildings will require DEH after 2024. This was mostly due to technical factors, such as buildings with complex heat and hot water needs, concerns about grid capacity, and keeping utilities working in buildings which provide communities with emergency heat and hot water. Others noted that some buildings, such as warehouses, may be incompatible with heat pumps.
Some respondents supported the proposal in full and had no noted concerns about using ZDEH in new non-domestic buildings. Others provided recommendations for alternate energy solutions for situations where ZDEH systems may not work, such as mixed technology approaches. A few noted a concern that applying the new standard to non-domestic buildings may negatively impact Scotland's industry and economic development.
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