New Build Heat Standard: consultation - part two analysis

The New Build Heating Standard (NBHS) consultation: Part II was an opportunity for the Scottish Government to understand a wide variety of stakeholders’ views on a number of specific proposals. This independent analysis presents a report on these views both quantitively and qualitatively.

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Chapter Two: Technologies

As the NBHS focuses on prohibiting heating systems which produce direct emissions, bioenergy systems[10] would not comply with the regulations, in relation to both new domestic and non-domestic buildings. This chapter explores respondents' views on specific situations where bioenergy systems could be required in new buildings.

Q3. Are there any limited, specific situations where the use of bioenergy systems would be required in new buildings?

Very mixed views were evident among those who answered Q3. One third (35%) stated there could be situations where bioenergy systems would be required in new buildings, 23% felt there were not, and two fifths (42%) were unsure.

Property developers / builders were most likely to be unsure (80%), followed by those in the wider construction sector (60%). Local Authority responses were mixed – 42% thought there would be specific situations for bioenergy, 25% did not and 33% were unsure. Among those in the energy sector, 63% of energy trade bodies indicated there would be some requirements for bioenergy systems, compared to 22% of manufacturers and suppliers in the energy sector.

Q3. Are there any limited, specific situations where the use of bioenergy systems would be required in new buildings?





Don't know

Not answered

All respondents






All respondents (%)






All answering (%)






  • - Individuals






  • - Organisations






  • - Property developer / builder






  • - Energy – trade body






  • - Local Authority






  • - Energymanufacturer / supplier






  • - Construction






  • - Other






Q4. If 'Yes', what do you believe the criteria should be for introducing such an exemption? Please provide evidence to support your answer.

Exemptions for rural and off-grid areas

Of the 39 respondents who answered Q4, the most common theme was for rural communities to be exempt from bioenergy system bans. This was raised by a range of stakeholders, from individuals to local authorities and from those in the energy sector to manufacturers, property developers and builders. It was also mentioned in all the consultation workshops held by the Scottish Government. Although it was not explicitly noted in most responses, it is apparent from the range of references within answers that respondents were describing use in both domestic and non-domestic buildings.

Concern for those in rural areas focused on perceived concerns about both the lack of connection to the electrical grid and the robustness of the grid system, though respondents did not provide evidence of this being the case. Some cited the need for bioenergy as a back-up in case of grid failures, such as was the case with Storm Arwen, mentioned specifically by a small number of respondents.

A few noted that as well as rural communities being at risk of longer grid failures, the poor weather disrupting the grid system can make these communities more difficult to access, limiting assistance and stopping residents from seeking shelter elsewhere.

"Small secondary heating appliances such as wood burning stoves supplying a single room should be allowed in rural areas where electricity supplies are potentially at risk. The condition for the exemption would need to take into account the location and distance from an energy generation point i.e. large conurbations would not qualify as these areas are first to be reconnected after damage to power lines." – Individual

"We believe that there are some limited, specific situations where the use of bioenergy systems would either be required or would be the most appropriate option in new buildings. This would be the case off the electricity grid where there is no existing or planned local electricity grid. A bioenergy heat network or individual home systems could use sustainably sourced bioenergy with emissions abatement technology to reduce local air pollution." – Energy Saving Trust

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. One noted that photovoltaics could be used alongside heat pumps and battery storage to help off-grid locations be self-sustaining.

"Aberdeenshire Council has a significant rural population. Transportation and infrastructure may limit technology options, especially where electricity grid constraints are an issue. In these cases, our close proximity to biomass sources may make bioenergy a viable choice." – Aberdeenshire Council

Sustainable bioenergy

Some respondents highlighted other environmental concerns in responding to this question, specifically the zero-waste movement and the use of sustainable types of bioenergy. Some argued that biofuel burning stoves could offer sustainable solutions for waste material, in particular biomass, and that these options could potentially offer the only viable low-carbon option for some buildings.

"As bioenergy is a tricky area for policy a balance needs to be set between utilising fuel sources that are sustainable now or can be developed sustainably, whilst not locking ourselves into future dependencies on bioenergy fuels that could lead to increasing demand from new systems and the insufficient development of local, sustainable supply chains requiring the demand gap to be met by importing biofuels from unsustainable sources. What is really needed here are robust projections of future energy demand (from existing and new buildings, and from existing and new heat networks) set against robust projections of supply from both biological waste streams (domestic, agricultural, forestry) and from the existing and future contributions from managed forestry and woodlands" – The Energy Poverty Research initiative; Common Weal; and the Built Environment Asset Management (BEAM) Centre, Glasgow Caledonian University (joint response)

Less commonly mentioned themes

Themes each mentioned by a small number of respondents included the following:

  • Concerns about costs associated with the transition to ZDEH, particularly the running costs of ZDEH systems.
  • Requests for exemption for certain buildings that may not meet fabrication standards and where alterations would be impossible, such as buildings with asbestos or school buildings which would require extensive closure times to convert. While this was raised in answers to this question, it is not relevant to new build properties.
  • Suggestions for a defined criteria to determine if a home is suitable for electrification or whether biomass may be a more suitable alternative, taking technological, economic and environmental factors e.g. zero-waste into consideration.
  • Support for the proposed Bioenergy Policy Working Group, which could provide further research on whether bioenergy can be applied to efficiently reduce emissions, particularly in rural examples.
  • Acknowledgement that biofuels are evolving and should be kept under review.



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