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 Five: Non-Domestic Buildings

This chapter presents an analysis of the final consultation question about proposed regulations on non-domestic buildings applying for a building warrant from April 2024. As with new build domestic buildings, the Scottish Government has proposed regulations that would prohibit DEH systems for heating and hot water in all non-domestic new builds, including bioenergy. It should be noted that the approach to using biofuel to power heat networks will be assessed in a future consultation on the Heat Networks Delivery Plan.

This question asks about specific non-domestic new builds that may require DEH after 2024. While the consultation paper focussed on new non-domestic buildings, it was not always clear whether respondents were describing a need for DEH in new non-domestic buildings or in non-domestic buildings more generally.

Q11. Do you anticipate any form of heating within a non-domestic building which will require DEH after 2024? Please provide details of the factors – whether technical, economic or social – which would require DEH after 2024?

Almost three fifths (58%) of those answering Q11 anticipated some non-domestic buildings requiring DEH after 2024. Individuals were less likely to anticipate this than organisations (45% compared to 65% respectively).

Views varied among organisations. Most (70%) Local Authorities could anticipate some eventualities where this could be required. All those in the wider construction industry indicated this could be required, compared to 43% of property developers / builders – perhaps reflecting the focus on domestic buildings in the work of the latter category. Trade bodies in the energy sector were more likely to anticipate DEH in non-domestic buildings than not (67% compared to 33%).

Q11. Do you anticipate any form of heating within a non-domestic building which will require direct emissions heating (DEH) after 2024?





Not answered

All respondents





All respondents (%)





All answering (%)





  • - Individuals





  • - Organisations





  • - Property developer / builder





  • - Energy – trade body





  • - Local Authority





  • - Energymanufacturer / supplier





  • - Construction





  • - Other





Technical factors

Of the 54 open responses to Q11, the most common concern was that technical factors could require DEH systems in non-domestic buildings after 1 April 2024.

Several respondents noted that certain non-domestic buildings have complex heat and hot water needs that may mean they are unsuitable for ZDEH systems. These included buildings with specific types of heating systems, e.g., steam distribution systems or radiant heating systems, and buildings which need very hot water for sanitation purposes. Examples of types of buildings mentioned by some respondents included: hospitals, care homes, large depots, manufacturers and production facilities, hotels, leisure centres and swimming pools, and places that serve food. Participants in the Non-Domestic Building workshop also mentioned distilleries, schools with laboratories, foundries and glass blowing factories as being affected by the exclusion of bioenergy heating systems.

A few respondents mentioned concerns about the grid capacity. They questioned whether it could handle the increased load, specifically considering the addition of some non-domestic new builds that will require higher than normal electrical resources, such as manufacturing plants and data centres.

"The only area we can see that would be an issue would be where the electricity grid cannot cope with the addition of ZDEH as a result of other technologies being added such as data centres." - Federation of Environmental Trade Associations

Community centres, churches, and town halls, which provide people with heat and hot water in emergencies, were suggested by a few as needing alternate power sources in the event of grid failure. Others specifically mentioned hospitals as places that offer vital services and would need back-up DEH energy supplies as electrical grid failures could put people at serious risk.

Other technical concerns included themes not unique to non-domestic buildings and covered in the previous chapters, such as geographic and geological issues, as well as factors related to labour and the lack of the skilled workforce necessary to manage an entirely ZDEH system. Specific concerns about grid issues in rural areas, as mentioned in Chapter One, were highlighted by a few others.

"As outlined in our responses above, there are significant barriers that exist, especially in Scotland's highland and island communities, to the successful uptake of ZDEH technologies. Of paramount importance is affordability and reliability of not only individual systems but the wider energy network to which they connect." - The Chartered Institute of Building (CIOB)

Building fabrication

The quality of non-domestic buildings was mentioned by several as a barrier to using ZDEH systems. They mentioned buildings with low energy efficiency, such as warehouses and large distribution centres, as being incompatible with heat pumps, for example.

No concerns with the proposal

Some respondents supported the proposal in full and had no noted concerns about using ZDEH in new non-domestic buildings.

"We do not anticipate that DEH would be required in new non-domestic buildings after 2024. We would support non-domestic buildings being included in this standard for new buildings." – Scottish Power

"There is always a way to avoid DEH. Simple funding availability is the key" – Ground Source Heat Pumps Ltd


Recommendations for alternate energy sources for situations where it was believed that ZDEH systems would not work were provided by some respondents. These included: hydrogen, liquid petroleum gas, and biomass. A few others supported ZDEH systems like district heating and solar panels. Mixed technology approaches were preferred by a few respondents.

Economic impact

A small number of respondents noted a concern that applying the new standard to non-domestic buildings may negatively impact industry and economic development in Scotland. One argued it could prevent new investment as organisations will not want to build or maintain properties if operations are too expensive.



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