Appendix 2: Summary of responses to Consultation Questions
The following paragraphs summarise the main findings from each of the consultation questions.
Main Findings: Outcomes (Q1 & Q2)
There was widespread agreement with the key outcomes as outlined in the scoping consultation. Key issues raised were for the Standard to be flexible, technology agnostic and make use of all existing (and emerging) technologies, so that heating solutions can meet varying needs.
The need for a fabric-first, or whole building approach was cited, so that heating demand and controls are not considered in isolation. This approach is perceived to help reduce fuel poverty, exposure to volatile energy prices and energy demand. There were some concerns over the cost of electricity in comparison to gas. The issue of geography was raised by some respondents in that some technologies may not be financially or logistically viable in rural areas. While electricity was seen to be a key heating source, it can be expensive and there were references of the need to reduce fuel poverty rather than increase it.
There were comments on a need for reliability of supply, a robust supply chain and training, retraining and upskilling to ensure there is a skilled workforce, with some suggestions for apprenticeships to be offered in order to attract new entrants to the sector. A number of references were also made for the need for collaboration and shared responsibilities across all relevant trade bodies, key industry groups, professional organisations and supply chains.
There was widespread agreement of a need to increase awareness, inform and educate consumers, with some suggestions for awareness campaigns about new green homes, the role of different technologies and the provision of assurances on the reliability of alternative heat sources. In turn, it was perceived that this would help to bring about the necessary behaviour change among consumers.
Main findings: The Standard (Qs3-10)
There was widespread agreement with limiting this Standard to 'new buildings' as defined within section 2.2 of the scoping consultation, although there was significant reference of a need for a similar approach to the existing building stock so as to address issues of climate change and fuel poverty.
Some respondents had concerns over the inclusion of conversions within this definition, as some can be complex and may need specialist retrofits depending on the age and fabric of a building. There was a perception from some that modern standards cannot always be applied on a like-for-like basis to existing properties under conversion. Allied to this, there were some requests on clear guidance as to which types of building will be included in the Standard or for renovations and conversions to be clearly defined.
When asked to state their agreement with the approach taken to require future installed heating systems to be zero direct emissions only and the approach taken to focus on direct / point of use emissions that a building owner has responsibility over only (Q4), higher numbers of respondents supported these approaches than did not. The key comment made was of a need for the Standard to be technology agnostic because a range of low carbon heat options would be needed to meet the demands of different building types. Some respondents noted their support for specific technologies, although there were also concerns about the embodied carbon in heating systems and the need to take this into account. A key concern was that this approach would not be suitable in rural settings, given the need for high density developments; allied to this, there were also some concerns over a lack of choice for consumers.
When asked what evidence could be offered on ways of ensuring zero direct emissions from heating that could be compliant with this Standard (Q5), a key theme was of the need to be technology agnostic and consider all available technology options. Specific support was noted for heat pumps, heat networks, electricity, hydrogen and solar PV. A significant number of respondents also focused on ways in which compliance could be enforced, with references to some form of certification or quality assurance scheme, such as Passivhaus, SAP, RdSAP or SBEM. Linked to this, there were calls for monitoring and evaluation so that compliance has to be demonstrated.
The consultation paper asked for views on two specific approaches that could be adopted to ensure compliance with the Standard (continuing with an existing methodology and – potentially – change the emissions factors to reflect a 'direct emissions' rating for different technologies; or creating an easily understood and enforceable stipulation about the types of heating systems that would be permissible under the new Standard) (Q6). Views were relatively split, with slightly more respondents supporting the latter approach as this would be the simplest option, easier to enforce and offer clarity to the supply chain. There were some requests for a definitive list of compliant technologies, albeit there would be a need for flexibility so as to include new technologies as they emerge. Regardless of preference, respondents requested clear guidance to be provided and noted a need for consistency across Scotland.
A number of steps were outlined as ways in which Scottish Government could support industry to deliver this Standard (Q7). These included; financial/fiscal support, engagement and collaboration, education and training, compliance mechanisms, timescales, the provision of guidance and the listing of compliant technologies.
When asked how the Scottish Government could ensure that consumers are protected from increased energy bills, while giving developers flexibility to comply with the Standard (Q8), the key theme that emerged was of a need for a fabric first approach as this would allow for high energy efficiency levels and ensure homes have low energy demand and thereby minimise energy costs to consumers. There were also some references of a need to ensure that consumers understand the technology options available. The option of offering financial incentives for consumers was raised by some respondents. Some respondents felt that developers need to understand their responsibilities and should be prevented from installing heating products with more expensive heating costs simply because they are cheaper to install.
There was broad support for new buildings connecting to an existing heat network, where development takes place within a heat network zone (Q9), albeit a key concern was that this approach is not economically viable in all situations and could lead to higher consumer energy costs and higher levels of fuel poverty. In relation to existing heat networks, there were some concerns that they will need to have spare capacity or there may be a potential lack of capacity to expand existing networks.
Views were split on the Scottish Government's proposal to introduce this Standard in 2024, and on being brought into force for new buildings consented earlier than 2024. A significant minority was supportive of the 2024 date, although there were some comments of a need to encourage developers to adopt the Standard earlier. A smaller number of respondents felt that 2024 is not realistically achievable, and noted concerns over a lack of a robust supply chain and skilled workforce. There were some references of a need for a phased implementation and / or the need for this to align with wider UK policy. Regardless of views on the 2024 date, there were some calls for clarity in the definitions used and for a clear roadmap.
Main Findings: Developing skills and supply chain capacity (Qs11-17)
When asked to outline ways in which opportunities can be maximised for the supply chain involved in the delivery of new homes (Q11), a large number of respondents focused on the need for skills and training for the workforce, with suggestions for investment and other forms of support being made. A large minority of respondents also asked for clarity regarding the Standard's regulations and framework and for collaboration, communication and joint working between stakeholders.
Key challenges envisaged for developers and the wider building industry in meeting the proposed Standard (Q12), were cost issues, the lack of availability of expertise and skills among the workforce, product supply and a perception of conservatism and resistance to change in the building sector culture; as well as timescales and the economic viability of work needed to reinforce the electricity network infrastructure in order to support energy growth.
Key challenges outlined for the energy networks in the deployment of zero emissions heating in new developments (Q13), included the impact of additional demand on the grid and a lack of network capacity at a local level and the capital costs rectifying this would incur. The most frequently cited type of support was the promotion of technologies to mitigate the need for network reinforcement, with a variety of potential energy sources being cited.
Ways in which the Standard could interact with wider energy system changes (Q14) focused on an increased demand for electricity, and the costs associated with upgrading the infrastructure. Once again, there were references to a need for flexibility to allow for a range of technologies to be used. The role for flexibility and smart technologies was seen to be essential to deal with the increase in electrical demand.
Education was seen as being essential to encourage greater consumer awareness and understanding (Q15), alongside effective communication campaigns and publicity. This was perceived to be a key role for the Scottish Government, albeit there was also a need to ensure a joined up approach across stakeholders. There were also some suggestions for offering financial incentives; as well as for training and upskilling of developers and tradespeople so that they can demonstrate the correct operation of new energy systems to consumers.
When asked what approach should be taken when considering non-domestic buildings, and what are the specific challenges and opportunities relating to new non-domestic buildings (Q16), respondents were split roughly equally on whether the standards and principles should be broadly similar to those for domestic buildings, or whether they need altering. The main perceived challenges were in their differing uses and the larger scale of non-domestic buildings. Opportunities identified by respondents included the potential to act as baseloads, generation modes or heat sinks for district heating systems; there were also suggestions to use non-domestic buildings as case studies.
The final question (Q17) asked what challenges or opportunities might result for households on low income and how the Scottish Government can best take account of these. Two key challenges were concerns over increased energy costs and the negative impacts of fuel poverty. A key opportunity could be lower energy use in housing. Suggestions for ways in which the Scottish Government could best take account of these were in protection of the most vulnerable via policy drivers and / or financial support or subsidies, although there were also references of a need to reduce the current imbalance in fuel pricing. Again, there were references to the need for educating consumers or for developers being allowed flexibility in the technologies used.