New Build Heat Standard (amended) 2024: business and regulatory impact assessment

11. Wider impacts

40. This section sets out the wider impacts of permitting bioenergy and peat heating systems in new buildings under Option 2 (as secondary systems), and Option 3, both presented earlier in this paper.

41. We recognise that as a renewable fuel, bioenergy may represent the best option to help decarbonise some rural homes for which clean heating systems may be limited (e.g. due to grid infrastructure capacity). Bioenergy consists of a range of different fuels – these include solid biomass such as briquettes, woodchip and wood pellets; liquid biofuels such as Hydrotreated Vegetable Oil (HVO); and gaseous biofuels such as bio-LPG (Liquified Propane Gas) and biomethane. While considered a “nearly net zero” technology (as set out above), in practice bioenergy emissions will be dependent on how the fuel stock is produced, harvested and transported.

42. The use of peat for heat was also considered in the review given concerns raised around its cultural significance as well as the rights of crofters to harvest peat under the The Crofters (Scotland) Act 1993^[12]. Respondents to the Scottish Government’s consultation^[13] on ‘Ending the Sale of Peat in Scotland’ highlighted that cutting and using peat for fuel in the Highlands and Islands was part of a ‘long-standing tradition’ and ‘as per our custom and culture’. In addition to cultural preservation, the practice was considered integral to some people’s lives, e.g. as an affordable fuel source. For example, an evidence review by the James Hutton Institute found that moving from peat to another fuel could lead to fuel costs up to four times higher, when moving to a high cost fuel such as electricity^[14].

43. However, burning of both bioenergy and peat can affect air quality and can release pollutants including particulate matter (PM) which can in turn impact human health. A report on Domestic Burning in Scotland by Asthma and Lung UK states that particulate matter can exacerbate lung conditions like asthma and chronic obstructive pulmonary disease (COPD). ^[15] It has also been linked to the increased likelihood of developing heart conditions, strokes, mental health issues and dementia.

44. In Scotland in 2019, residential and other combustion sources accounted for around 38% of total PM2.5 emissions and around 22% of total PM10 emissions.^[16] However, it is considered that the proposed changes under Options 2 and 3 will have negligible impacts on overall air pollution and it is not considered that they are likely to result in air quality related health impacts.