Building regulations - energy and environmental standards: consultation on proposed changes

5 Call for information on current standards

5.1.1. Background

This section of the consultation seeks your views on a small number of more general topics, not specifically associated with the commitment to deliver ‘a Scottish equivalent to the Passivhaus standard’. But which are material to the ongoing development of energy and environmental standards set by building regulations. Including the broader context within which these changes would be developed and proposed.

5.1.2. February 2023 design specifications

Information on the energy standard review to date is published at Energy Standards Review – Scottish Passivhaus Equivalent: Working Group - gov.scot (www.gov.scot). This included a call for evidence to gather information on current newbuild specifications being proposed under the February 2023 or April 2024 standards. This information would support development of an informed baseline for the current research into review of domestic and non-domestic energy targets.

Whilst research to determine the current baseline for improvement has now commenced, we would still welcome evidence from designers and developers, particularly on solutions which do not use direct emission heating systems.

“The Building Standards Division are inviting those who are currently designing buildings to the February 2023 standards to play a key part in how a Passivhaus equivalent standard may look in Scotland. If you would like to contribute calculated energy performance data and design specifications for buildings being designed to the February 2023 energy standards then please forward these to buildingstandards@gov.scot with an email title ‘Call for evidence – February 2023 design specification’.

Any information received will be recorded and anonymised to support reporting on the current energy baseline for new buildings. No information identifying individual developers or developments will be stored or published.

Such information can, where possible, be submitted separately and in advance of any consultation response.

Consultation Question 26

Are you currently designing buildings to the February 2023 standards and have confirmed specifications which are at a stage that have been or will be used in a building warrant application, that you would be happy to share with us?

Yes

No

If you answered ‘Yes’, please send calculation output sheets which detail your building specification(s) to buildingstandards@gov.scot with the subject title ‘Call for evidence – February 2023 design specification’.

5.1.3. Topic - the current approach to target setting and overheating risk

The updated provisions in February 2023 introduced a new delivered energy metric and a simpler approach to the assignment of benefit from onsite generation. It also revised the specification of the previous notional buildings and identified targets specific to use of heat pump solutions. We would welcome any feedback you may have from applying the revised standard 6.1 for new homes and non-domestic buildings.

Please do not include comments on standard 6.11 and the April 2024 New Build Heat Standard as a commitment to review aspects of that standard is already being progressed separately.

The standards also introduce the need to assess overheating risk in dwellings and similar non-domestic buildings from the perspective of user comfort for the first time. Whilst not directly relevant to the current review, we would welcome any feedback you may have in demonstrating compliance with standard 3.28 (overheating) and the approach taken, simple or modelled route.

Consultation Question 27

With regards to the current approach to target setting and overheating risk, do you have experience related to either of these two issues you consider useful to inform review of the current published guidance or this review of current energy and environmental standards?

Yes

No

If you answered ‘Yes’, please provide information summarising your experience.

5.1.4. Topic - newbuild heat network connections

With the introduction of the New Build Heat Standard in April 2024, new buildings are required to no longer use direct emission heating systems. This will result in a significant increase in application of both electric heating solutions and, where available, heat network connections.

In February 2023, we amended the approach taken in setting building targets under standard 6.1 (energy demand). Connection to a heat network was recognised as a ‘zero direct emissions’ solution and was no longer required to meet an emissions target. Instead, the requirements for the performance of a new building were standardised, with supplied heat being deemed 100% efficient, and new building required only to demonstrate compliance against a delivered energy target (defined using a less efficient heat source).

This approach sought to enable any new building to connect to any new or existing network without the specification of the building having to respond to, or compensate for, the performance of the connecting network. With the performance of the heat network to be addressed separately through planned heat network regulations.

We are keen to hear of any projects where connection to a district heat network or a communal heating system, new or existing, has or is being considered or is now being implemented. And the extent to which the current approach to energy targets set under standard 6.1 affects consideration of such solutions. This would include any information you have on the assessment of the comparative cost of delivering a heat network building compared to other heating options.

Consultation Question 28

Have you undertaken any projects under the post-2023 energy standards which considered connection to a new or existing heat network, both district heat networks and communal heating systems?

Yes

No

If you answered ‘Yes’, please share any information you consider influenced the outcome of those projects, with reference to the type of system (district or communal) and the impact of current energy targets in particular.

If you answered ‘No’, please confirm the reason for not considering a heat network solution.

5.1.5. Any other issues relevant to this review

Consultation Question 29

Do you have experience of issues affecting development which you consider have arisen from application of current energy and environmental standards set under building regulations?

Yes

No

If you answered ‘Yes’, please provide information summarising your experience.