Publication - Consultation analysis

New Build Heat Standard - scoping consultation: analysis

Published: 7 Oct 2021

Independent analysis of the responses made to the scoping consultation into the New Build Heat Standard.

New Build Heat Standard - scoping consultation: analysis
The Standard

The Standard

Question 3

59. The consultation paper proposed that any reference to a 'new building' was aligned to that set out under existing building regulation, and would cover both a) any property built for the first time; and b) any property created by the conversion of an existing building. The next question went onto ask,

Q3: Do you agree with limiting this Standard to 'new buildings' as defined within section 2.2?'

60. As the following table demonstrates, there was widespread agreement with limiting this Standard to 'new buildings' as defined within section 2.2. Only a small number disagreed with this (68 respondents agreed compared to only 6 who disagreed).

Table 3: Q3
  Yes No Not answered
Architect / Architect trade body (4) 2 1 1
Energy sector (12) 9 2 1
Housing association (4) 3 - 1
Housing developer (3) 1 - 2
Local authority (14) 11 - 3
Manufacturer (10) 10 - -
NGO (7) 7 - -
Public sector (3) 1 - 2
Trade Body - Energy (12) 9 2 1
Trade Body – Housing (7) 5 - 2
Other (7) 5 1 1
Total organisations (83) 63 6 14
Individual (9) 5 - 4
Total respondents (92) 68 6 18

61. A total of 64 respondents provided text in support of their initial answer. The key theme emerging at this question, and cited by respondents across all sub-groups, was of a need for a similar approach for existing building stock so as to help tackle the issues of climate change and fuel poverty.

62. There was some reference to the Scottish Government's Heat in Buildings Strategy, which will provide a pathway towards the decarbonisation of existing buildings, including any anticipated requirements for retrofitting along with timescales for carrying this out.

63. For a small number of respondents, it was felt that there is a need for a co-ordinated approach for new and existing buildings, with some reference to the levels of CO2 generated by existing buildings.

64. Some respondents noted concerns over the inclusion of conversions within this definition. They felt that some conversions within existing buildings can be more complex than new build housing or that buildings created by conversion may need specialist retrofits depending on the age and fabric of the building.

65. A similar number of respondents felt this Standard might cause a disincentive to retain or re-use traditional or historic buildings. There were suggestions that there needs to be flexibility built into the Standard so that conversions of existing buildings can be considered on a case-by-case basis. Some respondents also noted that modern standards cannot always be applied on a like-for-like basis to existing properties under conversion, given that some requirements such as insulation cannot be applied equally across new build and existing properties. A small number of respondents queried whether significant extensions should be included within the scope of this Standard, particularly as implementing build requirements may make some conversions financially unviable.

66. A small number of these respondents also noted that the cost implications of compliance with the Standard for conversions could be considerable and that incentives should be offered to encourage compliance.

67. A small number of respondents also noted this could have a knock-on impact in rural areas where the potentially high cost of conversion could impact on the supply of affordable housing. There were a very small number of suggestions of a need to distinguish between rural and urban areas as not all heating solutions will be relevant in rural areas; also suggestions that individuals living in rural areas should have access to low emission alternatives.

68. Some respondents noted queries over the definition, with requests for clear guidance on which types of building will be included. As such, there were requests for renovations and conversions to be clearly defined. There were also a small number of queries as to whether the Standard would apply only to conversions that are including a new heating system or to all conversions.

69. There were a few suggestions for additional funding or incentives to be available to encourage adherence to the Standard, particularly in relation to conversions.

70. Other points raised by small numbers of respondents included:

  • A preference for a whole life carbon approach to regulate and reduce the levels of embodied energy within new buildings.
  • Issues over the use of the Energy Efficiency Rating (EER) measure rather than the Environmental Impact (EI) measure within EPCs in rating energy efficiency, particularly as it was felt that using the EER measure would also help to reduce fuel poverty.

Question 4

71. The consultation paper proposed that the focus of the Standard will be on the emissions generated within the curtilage of the building for delivering a building's space and hot water heating and cooling requirements. So, in order to comply with the Standard, any installed heating system would produce no direct greenhouse gas emissions at the point of use. Question 4 went on to ask,

Q4: 'Do you agree with a) our approach taken to require future installed heating systems to be zero direct emissions only, and b) our approach taken to focus on direct / point of use emissions that a building owner has responsibility over only?'

72. As shown in table 4, a higher number of respondents supported the approach taken to require future installed heating systems to be zero direct emissions only (41 agreed compared to 21 who disagreed). This picture was very similar in relation to the approach taken to focus on direct / point of use emissions that a building owner has responsibility over only, with 43 in agreement and 20 disagreeing. Across both these questions, higher numbers of respondents within the energy sector and trade bodies (energy) and NGOs disagreed than agreed.

Table 4: Q4a & Q4b
  Q4a Q4b
  Yes No Not answered Yes No Not answered
Architect / Architect trade body (4) 3 - 1 3 - 1
Energy sector (12) 4 6 2 4 6 2
Housing association (4) 3 - 1 2 - 2
Housing developer (3) 2 - 1 2 - 1
Local authority (14) 7 2 5 8 2 4
Manufacturer (10) 8 1 1 7 2 1
NGO (7) - 4 3 2 3 2
Public sector (3) - - 3 - - 3
Trade Body - Energy (12) 5 6 1 5 6 1
Trade Body – Housing (7) 4 - 3 4 - 3
Other (7) 2 1 4 2 1 4
Total organisations (83) 38 20 25 39 20 24
Individual (9) 3 1 5 4 - 5
Total respondents (92) 41 21 30 43 20 29

73. 76 respondents, across all sub-groups, chose to make comments at this question.

74. The largest single comment, albeit only made by a small minority of respondents was that the Standard should remain technologically agnostic and that a range of low carbon heat options would be needed to meet the demands of different building types and individuals.

75. A number of respondents also noted their support for various specific technologies including hydrogen, biogas and electricity, although the electricity grid will need to use renewables and nuclear to replace fossil fuel.

76. There were a small number of concerns that the Standard would only allow direct electric solutions to be used in heating systems and a respondent in the trade body (energy) sector commented that some heating solutions with zero direct emissions at point of use have high carbon emissions.

77. There were also a small number of comments that the suggested approach could put too much strain on the national grid and that a robust infrastructure needs to be in place.

78. Some of the respondents who disagreed with this proposal felt that this would encourage developers to use fossil fuel fired district heating systems or favour the cheapest and simplest heating solutions which could place too much reliance on upstream decarbonisation; for example, one respondent noted that new homes built from 2024 onwards may not be able to access hydrogen as a fuel for heating in the future.

79. While there was broad support for this approach, a number of respondents highlighted concerns they had. The key concern was over the feasibility of this approach in more rural settings, given the need for high density developments – which tend to be focused in larger urban or city areas – in order to maximise efficiency and minimise costs.

80. A restriction in consumer choice was also cited by a few respondents, some of whom had concerns that this could lead to consumers being tied into an energy provider in a monopolistic situation and lead to increases in energy costs.

81. There were some concerns about the embodied carbon in heating systems; for example, one respondent commented that heat pumps need more maintenance than electric storage heaters and have a shorter working life; thus not only can the energy used cost more but the actual installation also costs more over its lifetime. One respondent noted their concerns over non-direct carbon emissions and wondered how responsibility for decarbonisation will be assigned upstream. As a local authority pointed out, where emissions to achieve connection are excessive, this will negate the benefits; and that net zero connections would be preferable. Perhaps not surprisingly, there were a few comments on the need to focus on the fabric of a building, with an organisation in the energy sector pointing out that energy efficiency and a fabric first approach are both essential elements in addressing heating in new build homes.

82. There were some calls for clarity across different aspects of this proposal, with the key focus being on clarity on the terms 'curtilage', 'none generated at the point of use', 'emissions' (from what?) and 'emissions generated within the curtilage of the building'.

83. There were a small number of comments that there is a conflict between the Standard and the Draft Heat in Buildings Strategy and that a more strategic overview should be undertaken. For example, one respondent noted that this Standard would require "zero greenhouse gas emissions at point of use" for a new technology to be compliant; however, in the Draft Heat in Buildings Strategy the Scottish Government states that "It will be important that the [decarbonisation of heat] happens in a planned way so that piecemeal deployment of heat pumps and heat networks does not undermine the socio-economic case for converting parts of the gas network to 100% hydrogen in the future". Another comment was that this Consultation notes that "any indirect or upstream greenhouse gas emissions that are produced during the generation or distribution of purchased thermal … energy – which is delivered via a heat network … would be considered out of scope", which appears to allow the continued deployment of new fossil-fired heat networks after 2024; however, the Draft Heat in Buildings Strategy states that "new heat networks will need to be powered using renewables or other low or zero emissions sources of heat" from 2023 and that this will mean that gas CHP may not be used in new heat networks in Scotland.

Question 5

84. Question 5 then asked,

Q5: What evidence can you offer on ways of ensuring zero direct emissions from heating that could be compliant with this Standard?'

85. A total of 62 respondents, across all sub-groups, opted to answer this question.

86. A key theme emerging was that the Scottish Government should remain technology agnostic and that all available technology options should be considered; furthermore, that there will need to be flexibility within the Standard to allow for any emerging technologies to be adopted.

87. A large number of respondents cited specific technologies that would meet the requirements of the Standard, although most of these did not provide supporting evidence. The technologies mentioned by respondents included:

88. Heat pumps (air, ground or water source) as viable alternatives to gas boilers. A manufacturer noted this system delivers more heat capacity than they draw in electrical capacity and thus offer the best level of efficiency; they have zero direct emissions and produce three times as much heat as is needed to power it, and have the lowest impact on the grid. That said, there were some issues noted in relation to heat pumps, with one local authority commenting that air source heat pumps are not affordable at the current grant levels and that these are not effective below -5 degrees; a housing developer had concerns over the capacity of the supply chain to be able to manufacture and install heat pumps in high volumes; and a housing association noted concerns over operational issues, the lifespan of appliances and high maintenance costs. An energy company noted that heat pumps would be excluded by the Standard because of the refrigerant gases leaked by 10% of installations.

89. Heat networks were mentioned by some respondents as offering zero direct emissions, although one housing developer noted the need for high density developments in order to maximise efficiency and costs. As noted at earlier questions, these were not perceived to be effective heating systems for rural and remote areas or where there are small developments.

90. Electricity was cited by some respondents as offering zero direct emissions from heating, although this is seen to be an expensive option and one which could increase fuel poverty. Two of these respondents referred to direct electric heating specifically, while others referred to other technologies such as heat pumps.

91. Hydrogen was another option considered by respondents, although there were also comments that this is an immature market, that this is not a cost effective option, or that it is not produced in a sustainable way and that emissions are given off when hydrogen is created. Additionally, an energy company noted that hydrogen boilers would be excluded because of the ultra-low NOx emissions they produce.

92. A smaller number of respondents cited solar PV or solar thermal as options with zero direct emissions from heating.

93. A significant number of respondents, rather than offering evidence of ways of ensuring zero direct emissions from heating that would be compliant with the Standard, noted ways in which compliance with the Standard could be enforced. A key approach mentioned by respondents was for some form of certification / quality assurance scheme, with examples of Passivhaus, SAP, RdSAP or SBEM being used to measure building energy and the environmental performance of buildings.

94. A small number of respondents also suggested the use of accredited suppliers and products, or providing a list of approved products and systems that qualify as zero direct emission.

95. Another key approach cited by respondents was for monitoring and evaluation so that compliance has to be demonstrated. One local authority suggested enforcement via existing statutory duties, although additional resources would be required to undertake this additional role.

Question 6

96. The consultation paper noted that no definitive compliance methodology had been specified, although the Technical Consultation will contain proposals for a compliance methodology, taking into account input from this consultation. The consultation paper outlined two potential options that could be used to define compliance with this Standard. Option A would continue with an existing methodology and potentially change the emissions factors to reflect a 'direct emissions' rating for different technologies. Option B would be to create an easily understood and enforceable stipulation about the types of heating systems that would be permissible under the new Standard (i.e. those which, if used, would not generate greenhouse gases at point of use). Question 6 then asked,

Q6: What are your views on section 2.6, specifically regarding what mechanism the Scottish Government could use to ensure compliance with the Standard?'

97. A total of 75 respondents provided commentary to this specific question. Of those who provided a definitive response, roughly twice as many respondents supported Option B than Option A, although this support was by a minority of respondents. A higher number of respondents did not specify support for either of the two options outlined. There was support for both options across most respondent sub-groups, although no respondents in the housing developer or housing association groupings supported option A. For each of these options, a small number of respondents cited that it was the simplest approach to adopt.

Option A: continuing with an existing methodology and – potentially – change the emissions factors to reflect a 'direct emissions' rating for different technologies

98. The key advantages to option A were that it is perceived to be technology agnostic, that it ensures a level playing field, thereby encouraging investment in research and development; and allows for new technologies to be incorporated as they emerge.

99. The key disadvantage of this approach was that it would need lots of administration.

100. Some respondents commented on the need to update the SAP (Standard Assessment Procedure; the methodology for calculating the energy efficiency and carbon dioxide emissions of residential buildings and new homes), as it is no longer fit for purpose and it does not reflect the aspirations of the Standard; for example, it is seen to penalise heat pump technology. This issue was also raised by representatives from business and industry who attended a workshop event.

Option B: creating an easily understood and enforceable stipulation about the types of heating systems that would be permissible under the new Standard

101. Key advantages were that it would be easier to enforce, that it offers clarity to the supply chain, that manufacturers know what to work to and that it puts the onus on technologies to innovate and demonstrate compliance with the Standard and this can drive faster change.

102. A few respondents noted the need for a definitive list of compliant heating technologies, although concern was also noted that a technical list could create unfair exclusions and that it would need to be flexible to allow for future-proofing and inclusion of new technologies as they emerge.

103. Allied to this latter point, a small number of respondents felt this could limit the scope to include emerging technologies or that it could constrain investment and innovation. There were a small number of suggestions that Homes for Scotland could be involved in collaboration with the Scottish Government in producing and updating this list. A local authority summing up the advantages of this option noted:

"Option b) would appear to offer a simpler route to compliance, which may be easier to enforce as well as be clear to applicants and designers which options may be more suitable to them. Having a simpler approach would encourage buy in and make the process easier understood for all involved. Whilst a manufacturers appliance and model would unlikely be referred to, the type of appliance and efficiency rating could be something that demonstrates a minimum compliance point. Similar requirements of district heating systems could also be specified as minimum requirements."

Other options

104. A small number of respondents suggested there could be a mix of these two approaches as it would provide building developers and homeowners with a list of approved technologies to meet the Standard, based on their direct emissions ratings.

105. There was a degree of support for consistency across Scotland as a whole. There were some suggestions – primarily from local authorities – that there is a need to integrate the Standard within existing Planning and Building Standard arrangements; and that the Standard could sit within revised versions of the Building Regulations.

106. Regardless of their preferred option, a few respondents noted the importance of having clear guidance provided, for example, guidance for developers around different types of heating systems that would not generate greenhouse gases at point of use.

107. Allied to this, there were a small number of calls for a verified certifier scheme, for example the use of Passivhaus to quality assure buildings at design, construction and post-completion stages. There were also a small number of requests for a monitoring and compliance mechanism.

108. A recurring theme, albeit only cited by a small number of respondents, was of a need to have different options for rural areas where some types of heating system may not be suitable.

Question 7

109. Question 7 of the consultation then asked,

Q7: What steps can the Scottish Government take to support industry to deliver this Standard, and how could we make compliance with this Standard easier?'

110. A total of 75 respondents – across all sub-groups – opted to provide commentary in response to this question. A number of key themes emerged. These are covered in the following paragraphs.

Financial / fiscal support

111. This theme was cited by around half the respondents, across all sub-groups. The key issue raised by respondents was of a need for investment in the infrastructure, workforce and supply chain across the sector. It was also noted that financial support is needed to bring about the necessary training, re-training and / or upskilling of the workforce; as well as support for the deployment of energy efficiency measures, low carbon and low emission heat sources; and for innovation in emerging technologies, options and opportunities and pilot projects.

112. A few respondents – local authorities and housing associations – suggested that grant funding should be offered. For example, a housing association noted that there is a need for a Housing Association Grant (HAG) for the social housing sector to reflect what will be an increase in costs to deliver the Standard.

113. Other suggestions made by small numbers of respondents included:

  • Incentivised development to assist with the additional costs associated with providing alternative technologies.
  • Additional support and resources for local authorities, for example, for the recruitment of dedicated Building Standards Officers who could oversee compliance at a local level.
  • Heat standard weighting for rural and island housing funds where upfront capital costs are high.
  • Prioritisation of funding streams such as the National Training Transition Fund or the Green Jobs Fund.

Engagement and collaboration

114. Engagement on the part of the Scottish Government is clearly perceived to be a key element, and a significant minority of respondents referred in some way to engagement across a wide range of audiences. These audiences included:

  • Industry, including the housebuilding sector, housing developers, heat network developers, energy infrastructure providers and manufacturers.
  • Suppliers.
  • Social landlords.
  • Local authorities.
  • Housing associations.
  • Professional bodies.
  • The general public.

115. Engagement among the general public in particular was felt to be important to increase awareness of zero emissions heating systems and to help bring about cultural and behavioural change among consumers. Some respondents also suggested a need for energy literacy campaigns and / or information campaigns.

Education and training

116. This was another key theme cited by a significant minority of respondents, across all sub-groups, with some comments that a predicted skills shortage and skills gap could make it difficult for developers to be compliant with the Standard when it is introduced. In terms of targeting training and upskilling, respondents focused on all individuals involved within the building chain as recipients for training and skills development. A number of these respondents noted the need to upskill existing workers to ensure they have the necessary skills to be compliant with the Standard when it is introduced. There were also some specific references to installers, assessors and verifiers and the need to ensure they have relevant training and certification. There were also some suggestions for the introduction of apprenticeships, with a few references to the involvement of Skills Development Scotland.

Compliance with the Standard

117. There were some suggestions – mostly from local authorities – that compliance with the Standard should be linked to Building Standards and via Building Regulations. There were some recommendations that buildings should adhere to the Passivhaus or a similar standard. There were also small mentions of a need for properly trained assessors, to broaden the use of Approved Verifiers for different sections of the Building Standards.

118. There were a few comments on a need to revise the SAP mechanism, with requests for an extension or modification to SAP to recognise the efficiency benefits of Networked (Ground Source) Heat Pumps connected to shared ground loops, ambient or 5th generation heat networks; as well as allowing time for SAP software providers to develop and launch the tools required to develop and test compliant housing designs with forthcoming standards.

119. Some respondents – primarily trade bodies (housing) and housing developers – also made specific reference to the need for any system of compliance to operate alongside the rest of the UK, as SAP does at present. These respondents suggested that policies should align with the wider UK targets, and the key implementation dates should be matched with those of other UK Governments (the Future Homes Standard was cited as an example).


120. Some respondents referred specifically to the timescales for implementation of the Standard. A number of these requested a clear roadmap setting out when and how the Standard will be implemented, to include a routemap for net zero transition and changes to be made to Building Standards. This point also emerged during the workshops.

121. A number of these respondents noted concerns over the timescale and felt that more time is needed to plan for new build properties that are compliant with the Standard.

122. Allied to this, there were some queries over sites which already have consent but which could be subject to new requirements under the Standard, which would impact upon project viability. Not surprisingly, there were some requests for a longer lead-in to allow sufficient time for the industry to prepare; and some respondents felt the proposed timescale is too short. There were a small number of suggestions for a transition period and the phasing in of compliance and implementation.

The provision of guidance

123. Some respondents noted a need for clear policy guidance, with signposting to available services and support, as well as the inclusion of technical advice and / or examples of best practice in community engagement and / or ethical business practice. It was also felt that guidance needed to be provided as early as possible.

124. A number of respondents – primarily within the manufacturing sector – cited a need for the Scottish Government to produce clear guidelines defining compliant technologies and stipulating specific technologies and standards that would be suitable under the Standard. There would also need to be a mechanism by which this list could be updated to include new innovations. Once again, there were a small number of references to the need for a technologically-agnostic approach.

125. At a workshop held among representatives from business and industry, many of the above issues were raised.

Question 8

126. The consultation paper noted that, regardless of which system supplies a building's heating requirements, it is important that action is taken to limit the amount of energy that needs to be delivered to a new building to meet the heating demand to the best levels practicable. Question 8 went onto ask,

Q8: 'How do we ensure that consumers are protected from increased energy bills, while giving developers flexibility to comply with the Standard?'

127. A total of 77 respondents, across all sub-groups, commented at this question. The key theme which emerged was of a need for a fabric first approach as this allows for high energy efficiency levels and helps to ensure that homes have low energy demand, and minimise energy costs to the consumer. As noted by a manufacturer,

"Promoting thermal efficiency is essential, this will help protect consumers from increased energy bills. The Climate Change Committee has made recommendations that new homes must achieve 'ultra-high' levels of energy efficiency. We advocate for a fabric-first approach to building decarbonisation, such that the demand for heat is reduced with energy efficiency improvements, prior to or alongside, the installation of a low-carbon heating system. This has multiple benefits including lowering emissions, reducing capital investment required, helping with energy security as we move towards greater electrification of heating, cooking and transport and saving consumers money on their energy bills. Despite the benefits associated with domestic heat decarbonisation, particularly in terms of emissions reduction, if this approach is adopted without due consideration for the energy efficiency of buildings, there could be significant implications for fuel poverty and wider energy security."

128. Some respondents – often in the local authority or housing association sub-groups – noted the need to ensure consumers understand the technology options available to them and how to operate new heating systems. It was noted that new technologies are more complex to understand and operate than many that are currently available to consumers and that it is important for consumers to understand how to maximise efficiency and minimise running costs for different systems.

129. There were also some suggestions for financial incentives in the form of grants, loans or subsidies to consumers; these were seen to be beneficial in a number of different ways, including financial support to avoid fuel poverty, incentives built into tariffs for the use of zero direct emission fuel sources and incentives for using renewable energy. A few respondents suggested that a cap on costs could be implemented for consumers. That said, a few respondents commented that consumers will have to accept higher energy bills, although new build homes should have low energy demand and low bills because of higher levels of energy efficiency.

130. Allied to this, there were a few calls for underlying taxes and regulations on electricity to be addressed to make electricity affordable for consumers; or for the cost of gas and electricity to be levelled, with suggestions for a carbon tax on gas and fossil fuels which could be used to subsidise the higher cost of electricity. An added advantage is that this would help to incentivise the take up of zero direct emissions heating systems.

131. Some respondents chose to focus their comments on the responsibilities of developers, with comments that developers should be prevented from installing heating products with more expensive heating costs simply because they are cheaper to install; and that developers need to install heating systems that are best for the end user. An organisation in the energy sector suggested that developers need to focus on customer-centric solutions that consider the lifetime costs of heating as well as the capital costs of installation. A local authority suggested that developers should have a duty to highlight maintenance costs as well as running costs.

132. As at some previous questions, there were comments from a few respondents of a need for a mixed technology approach so that there is flexibility within the system; two organisations (one energy and one trade body within the energy sector) felt that government policy should not drive solutions towards a single technology.

133. There were a few suggestions to consider generation opportunities for local communities which would help to meet an increased demand for electricity; this was felt to be particularly useful for rural communities where some technology options would not be available. Additionally, there were a small number of references to encouraging consumers to utilise onsite generation and reduce their reliance on the grid.

134. Some respondents focused specifically on the Standard. Comments included that the Standard should stipulate the use of specific technologies so as to avoid expense for the end user, for example, by looking at potential energy options and costs for all new build at the planning stage. One Trade Body (energy) suggested there should be an affordability target in the Standard based on the installation, maintenance and energy costs of a heating system; an NGO that the Standard should incorporate a heating system efficiency requirement.

135. There were also references to the role of Building Standards or Building Regulations to ensure energy use is reduced, as well as a small number of suggestions for developers to provide cost appraisals for their proposed heating systems early in the planning process. Other points raised in relation to Building Standards included:

  • Introduction of a mandatory POE to ensure that 'as designed' is close to 'as built'.
  • Elimination of any option to use renewable energy as a route to offset against poorer fabric efficiency.
  • The need to ensure that quality standards are met.

136. There were a small number of comments of a need to ensure that there is alignment between the Standard and the wider policy environment, with references to the forthcoming Fuel Poverty Strategy, Building Regulations and the implementation of Scottish Technical Standards.

137. Many of the issues raised in relation to this question were also mentioned during the workshop among consumers, with a key focus being on the costs of this technology and the need not to increase levels of fuel poverty. There were comments that consumers will focus more on the cost of their heating system than benefits to the climate or environment.

138. Another key focus for workshop attendees was on the need to increase consumer awareness, provide consumer education on technologies, bring about behavioural change and provide ongoing support.

139. A number of references were also made to the need to develop skills and capacity within the supply chain, to ensure network resilience, and provide incentives and government funding both to consumers and industry.

Question 9

140. The consultation paper proposed that developers should retain as much flexibility as possible to meet the Standard. It also proposed that new buildings be required to be designed and constructed so as to connect to an existing heat network, where that development takes place within a Heat Network Zone. If a developer can demonstrate that this is not an effective solution, an alternative zero direct emissions heating system would be permissible in complying with the Standard.

141. The Heat Networks (Scotland) Act 2021 allows local authorities or the Scottish Ministers to designate an area as particularly suitable for the development of district or communal heating. The expectation that proposals should seek to connect to existing or planned networks has been in place in London and The London Model is implemented through planning policy. At present in Scotland, the Scottish Planning Policy (SPP) sets out that Planning should support the development of heat networks and should help to reduce emissions and energy use in new buildings and from new infrastructure.

142. Question 9 asked,

Q9: 'What are your views on new buildings connecting to an existing heat network, where development takes place within a heat network zone? Do you envisage any unintended consequences as a result of this proposal?'

143. A total of 70 respondents opted to provide commentary in response to this question, and showed broad support for this approach. Advantages cited by respondents included that it is sensible as this would build economies of scale, that it would provide certainly and confidence in the delivery of heat networks, and that it will help to expand district heating.

144. Some of these respondents noted that this strategy has been implemented successfully elsewhere, with most of these noting their support for the London Model. That said, a very small number of respondents felt that while the London Model has been successful in London, it might not translate well to a Scottish context. There was also a reference to Denmark which introduced the first building standards containing energy requirements in 1961, since when the energy demand of new buildings has reduced by 95%.

145. A few respondents noted their disagreement with the proposal, the key reasons being that this removes flexibility in choice of energy supplier or that developers should be given the flexibility to decide on what is the best zero carbon heat solution in each development.

146. Despite the broad support shown for this proposal, a number of respondents also provided qualifying commentary and outlined a number of concerns with this approach.

147. A key concern related to consumers, with comments that this approach is not economically viable in all situations and that it could lead to higher consumer energy costs and allied higher levels of fuel poverty. There were also a small number of references to the driving up of house prices, entailing higher heat connection costs, or having long term fixed costs with the network provider.

148. Linked to this latter point, there were some comments that this is a non-competitive approach which restricts consumer choice and provides the heat networks with effective monopolies in their area, although two NGOs commented that this could open up opportunities for community ownership which would help counter any monopolistic arguments.

149. Some respondents noted concerns that existing heat networks will need to have spare capacity or that there may be a potential lack of capacity to expand existing networks. This, in turn, could cause delays to the delivery of new build homes. Other technical issues cited by respondents included that existing heat networks may need to have increased pipe sizing or that existing networks may be designed on higher temperatures than is required by new build homes.

150. There were also some comments that there will be a need to build bigger than required heat networks in the first instance to allow for future additional connections, although this would entail higher upfront costs and might make establishing the network non-financially viable.

151. Other issues identified by respondents included the potential for disruption if there is a need to upgrade existing infrastructure to allow for new connections, a potential increase in construction costs because of necessary civil engineering works, or a potential mismatch between when access to a heat network is needed and when connection to the network is possible. A small number of respondents commented that other technologies may offer better upstream emission reductions than connection to a heat network that is powered by gas.

152. Once again, there were some references to geography, with a perception that heat networks are most suitable for city or urban areas with high density populations. These respondents felt that heat networks are not a viable option for more rural and / or remote areas where there could be high infrastructure costs; and noted the need for flexibility in these areas so that alternative technologies such as ground / air source heat pumps could be used. Linked to this, there were some calls for a full mix of technologies to be available, with a need to identify the most efficient and appropriate heat solutions on a site-by-site basis.

153. Other issues raised by small numbers of respondents included:

  • The need to promote heat networks and raise awareness and understanding of these; these comments were mostly in relation to consumers.
  • Properties should be aligned to the Passivhaus standard.
  • There is a need to prioritise efforts to decarbonise heat networks and a need to consider emissions from heat networks as well as emissions at point of use.
  • There is a need to provide advice and support to local authorities, particularly as some do not have experience of heat networks in their area.
  • Concerns that some heat networks rely on fossil fuels, and what incentives there might be to move from gas to zero emissions systems.
  • It might be necessary to offer incentives to developers and energy companies; for example, the provision of funding to support the cost of connection for low carbon heat networks.
  • Concerns that for large heat networks, there are heat losses from transmission.
  • LHEES (Local Heat and Energy Efficiency Strategies) should be considered as part of the approach; and prioritised and resourced.

Question 10

154. Question 10 then went onto ask,

Q10: 'Do you agree with the Scottish Government's proposal to introduce this Standard in 2024? What are your views on this Standard being brought into force for new buildings consented earlier than 2024?'

155. As shown in table 5, views were relatively split with slightly more respondents supporting than not supporting the Scottish Government's proposal to introduce this Standard in 2024 (40 supported this compared to 38 who did not). The types of organisation offering least support to this proposal were those in architect / architect trade bodies, manufacturers and NGOs. Of those not supporting this proposal, more respondents felt this date should be sooner than later.

Table 5: Q10
  Yes No Not answered
Architect / Architect trade body (4) 1 3 -
Energy sector (12) 5 5 2
Housing association (4) 2 1 1
Housing developer (3) 1 1 1
Local authority (14) 9 5 -
Manufacturer (10) 3 7 -
NGO (7) 2 4 1
Public sector (3) 1 - 2
Trade Body - Energy (12) 6 5 1
Trade Body – Housing (7) 4 2 1
Other (7) 2 3 2
Total organisations (83) 36 36 11
Individual (9) 4 2 3
Total respondents (92) 40 38 14

156. Eighty-five respondents opted to provide commentary in support of their initial response.

157. Of those who provided a response to this question, a small majority were supportive of the 2024 date, with comments that this allows sufficient time for the industry to adjust to the new Standard, and to ensure the supply chain and training is in place to support this. There were also some comments of a need to have time to increase awareness – both across the industry and the general public. A few respondents also commented that the date could not be earlier than 2024 because of the need to ensure the infrastructure is in place, to ensure there is a skilled workforce and suitable supply chain. A small number of respondents also noted that some planning authorities have already introduced, or plan to introduce, improved performance targets through the planning process.

158. A smaller number of respondents commented that the 2024 date is not realistically achievable, and again cited concerns over the lack of a suitably skilled workforce and supply chains not being in place by this date.

159. There were some comments about a need to encourage developers to adopt the Standard earlier, perhaps by offering some form of incentives to early adopters. A small number of these respondents suggested September 2022 as a suitable date for all homes built with public investment.

160. There were some comments that leaving it until 2024 to introduce the Standard would offer time to developers to build homes as late as 2027 which only meet the 2021 standards and will subsequently then need retrofitting.

161. Regardless of whether or not they supported a 2024 date, there were some references of a need for a phased implementation of the Standard and / or a transitional period which would allow for the development of supply chains, the provision of education and training to ensure a suitably skilled workforce, and awareness raising and information campaigns to the industry and the general public.

162. As at previous questions, there were a few comments on the need for this to align with wider UK policy, and there were some specific references to the Future Home Standard as this would encourage the development of a robust UK-wide supply chain and skills base. There was also some reference to the 2021 Building Standards Review being implemented in 2024 to sit alongside the new Standard.

163. Some respondents requested clarity in the definitions used or had issues in relation to the Standard. This included what is meant by 'commencement', 'zero emissions', and when a new build is regarded as 'consented'.

164. There were also requests for a clear roadmap that is realistic and has flexibility to enable the design, development and implementation of robust viable heating solutions. In regards to commencement specifically, it was suggested that the commencement allowance of three years should be shortened to two years to speed up the implementation of building regulation changes. It was also suggested that at the same time, a five year limit for the completion of building projects should be put in place.