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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Conclusions and next steps

Many individuals and stakeholders with detailed knowledge took part in the consultation, providing their insight on the proposals and the impact of implementing the New Build Heat Standard. Their views will assist the Scottish Government in finalising the NBHS regulations to put to Parliament in 2023. This report provides a summary of the consultation responses; for more detail, readers are encouraged to review individual responses where permission was given for publication[12].

There was support for the proposed NBHS in relation to domestic new builds. However, many respondents provided caveats to their support. They noted concerns about the electrical grid capacity, skills, and supply chain shortages, as well as possible unintended consequences, such as a reduction in the number of new homes being built and rising energy costs associated with the increased electrification of heating.

Respondents proposed exemptions to the exclusion of bioenergy systems at point of use, covering rural and island communities with poor grid connections, and for sustainable sources of bioenergy, such as biomass, which may positively impact zero-waste goals. Respondents outlined what they considered to be reasonably practicable for conversions and noted some unintended consequences of the proposals for conversions. There was most concern about the need for, and cost of, improved building fabrication, especially in historic buildings, which led to questions about the energy efficiency and costs associated with transitioning to ZDEH.

In line with the Just Transition goals, the consultation inquired about the impact of the NBHS on people with protected characteristics. In relation to conversions particularly, some felt the increased cost of ZDEH systems in poorly fabricated homes may exacerbate fuel poverty and inequality, particularly among groups with high heat needs. Others, however, suggested a new universal building standard would ensure all tenants would have warm, efficient homes regardless of tenure.

Slightly more than half of respondents felt there may need to be exemptions for some non-domestic new builds after April 2024. Reasons included buildings with high heat and hot water needs, buildings that rely on energy to provide care such as hospitals, and places that provide heat and shelter during electrical grid failures.

Next steps

  • Reconvening of NBHS working group to present recent work and share publication details amongst our stakeholders.
  • Engage with stakeholders to address all relevant issues discovered through the consultation analysis.
  • Propose further working group and sub-working group activities to aid development and forming of the NBHS.
  • Prepare legislation in Spring 2023 for the NBHS coming into force in April 2024.



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