Building regulations - proposed changes to energy and environmental standards: SG response part 2 - onward review

5 Consultation section 5 – Call for information on current standards

Consultation question 26 asked respondents if they were currently designing buildings to the February 2023 standards and had confirmed specifications they would be willing to share with us.

This question was asked in support of the related call for evidence launched prior to the consultation on the review webpage. Limited information was provided in response to the call for evidence and to this question. Where shared, information was recorded and anonymised to support the reporting on the current energy baseline for new buildings.

The Scottish Government would welcome any further information from those developing new build specifications. Please contact bsdenergystandardsreview@gov.scot if you would like to offer additional information.

Consultation question 27 asked respondents if they had experience related to the updated approaches adopted in the February 2023 standards to target setting and overheating risk, that they considered would be useful to inform the further review of energy and environmental standards.

Limited feedback was received on the current approach to target setting. Where information was provided, our response is captured elsewhere in this document.

In response to the feedback received on the approach to overheating risk, we will review the guidance provided in support of standard 3.28 ‘Overheating risk’ to identify and develop additional information that will further inform action to achieve compliance with the standard. We will also develop draft guidance on the use of PHPP as an additional option to assess and mitigate overheating in dwellings and some non-residential buildings.

A research project will be procured in Winter 2025 to inform the drafting of updated guidance for consultation in Summer/Autumn 2026.

Consultation question 28 asked respondents if they had undertaken any projects under the post-2023 energy standards which considered connection to a new or existing heat network, both district heat network and communal heating systems. Respondents were asked to share any information they considered influenced the outcome of projects, with reference to the type of system (district or communal) and the impact of current energy targets in particular. Respondents were also asked to confirm reasons for not considering a heat network solution.

The majority of respondents did not have experience of the type of projects in question. Where responses were provided, these focussed on elements that currently sit outside the building standards system and the scope of the consultation, for example funding for heat network development.

Outwith the energy standards review, some concerns have been raised in relation to how the 2023 standards are influencing the choice of heat solution. Where possible, the 2023 standards were generally set based on a cost neutrality basis across heat solutions with the delivered energy demand target allowed to fluctuate to compensate for lower delivered energy efficiencies such as for heat networks as opposed to standalone building level heat pumps. We will continue to review where this intent may not have been realised in practice and update guidance in 2026 where needed.

Consultation question 29 asked respondents for any additional information on issues affecting development which they considered to have arisen from application of the current energy and environmental standards.

Feedback received focused on a number of areas including workforce skills and limitations with calculations and compliance assessments. The majority of concerns are picked up in response to other consultation questions, for example question 30 confirms a deferred implementation date has been set to allow industry to develop the required skills.

Additionally, concerns were raised regarding the costs and affordability of the existing and proposed new standards. As part of all reviews of energy standards, research is procured to identify uplifts in the level of challenge that could reasonably be delivered within the means of the current construction sector in Scotland. Information on associated costs are presented in the research and impact assessment published alongside the consultation.