Heat in Buildings Bill consultation: strategic environmental assessment

6. Findings of the Assessment

6.1 Introduction

6.1.1 A staged approach to the assessment has been undertaken as set out in the Assessment methodology (See Section 4.3). Early assessment work included a review of relevant SEA environmental reports to identify known likely environmental effects. See Appendix A for further details.

6.2 What are the Key Proposals

1. Supporting the growth of heat networks

6.2.1 We have made good progress with the legislative framework surrounding heat networks, and have identified heat networks as a source of heat which could play a much greater role if grown to a scale which makes the network of heat networks economic to both create and run. To that end, the proposals suggest duties and requirements to be placed on the non-domestic sector which will, in turn, support heat networks which can then be to the benefit of domestic consumers.

2. Prohibiting the use of Direct Emissions Heating systems, including the establishment of dates for compliance (both backstop and interim triggers)

6.2.2 We know that emissions will only fall if polluting heating (e.g. gas and oil boilers) are removed, and that this will only occur at the scale necessary if a regulatory pathway is created and enforced.

6.2.3 To support the pathway to zero emissions for all properties across Scotland, the consultation is proposing to prohibit the use of polluting heating systems by 2045. It also proposes the use of backstop dates for different sectors (2038 for public authorities, 2045 for all other properties), and seeks views on the use of triggers requiring earlier action where appropriate.

6.2.4 The use of such triggers will also help to avoid the risk of property owners waiting until the 2045 backstop date and help with supply chain management.

3. Setting minimum energy efficiency standards for domestic properties

6.2.5 Improving the energy efficiency of a home means that it needs less energy to heat it to a comfortable temperature. A good level of energy efficiency helps the performance of many zero direct emissions heating systems.

6.2.6 The consultation is proposing to set a standard for all privately owned domestic properties based on either a list of measures which is simple to understand for all property owners.

6.2.7 This standard should be reached by 2033 for all privately owned properties, and by 2028 for privately rented properties, the reason for this being that tenants are least able to implement change in the properties in which they live, but are most affected by poor quality standards.

4. Providing flexibility

6.2.8 We also understand that there may be occasions when it will be necessary to vary the standard, or provide extra time to meet it. This might apply to either part (energy efficiency and clean heat) or both. The consultation therefore proposes options when a variation might be needed. It also proposes options when a property owner might need an abeyance, or extra time.

6.3 What are the environmental issues of relevance

6.3.1 Key environmental issues of relevance relate to the SEA topics of climatic factors, population and human health, air, material assets, and cultural and historic heritage.

6.3.2 Key issues for climatic factors include greenhouse gas emissions from a range of sources, with energy supply and use of homes and buildings contributing to emissions. Observed climate change trends (such as wetter winters, drier summers and extreme weather events) are likely to intensify in the future and this can negatively impact on energy infrastructure (such as through flooding). Climate change can also give rise to indirect effects arising from mitigation and adaptation measures. For example energy efficiency and heat decarbonisation of Scotland’s homes and buildings contributes to meeting statutory climate change targets. However, individual technologies can have negative impacts such as localised visual effects on cultural and historic heritage, changes in landscape and land use, and impacts on biodiversity, water and air quality, amongst others. Climate change has also been identified as a primary pressure on many of the SEA topic areas.

6.3.3 Key issues for population and human health include challenging weather, poor energy efficiency and reduced heating options (especially in rural areas) which can contribute to making fuel bills unaffordable, resulting in fuel poverty. The potential risks and benefits of climate change on population and human health will not be evenly spread. For example, areas of dense urban development will be more at risk from surface water flooding and summer heat stress. In addition the effects to human health from climate change may have the greatest impact on vulnerable people. Negative health impacts are likely to be disproportionately severe in areas of high deprivation because of the reduced ability of individuals and communities in these areas to prepare, respond and recover.

6.3.4 Key issues for air include emissions from a number of sectors leading to air pollution, with air quality contributing to a number of health problems. Air quality and GHG emissions are intrinsically linked as they both arise from broadly the same sources. Measures that seek to reduce emissions from buildings such as from improved energy efficiency and heat decarbonisation, have the potential to broadly contribute to improved air quality.

6.3.5 Key issues for material assets include those associated with development and infrastructure and pressure on land use. Energy efficiency and heat decarbonisation as a means to support emission reductions from Scotland’s homes and buildings will require new or expanding infrastructure facilities at a range of scales^[68]. Changes in land use required to meet wider climate change targets could also have environmental effects.

6.3.6 Key issues for cultural heritage include development which is a key pressure on the historic environment and cultural heritage, both directly in terms of damage to known and unknown features, and possible impacts on setting such as changes to the fabric of buildings.

6.4 What are the likely significant environmental effects of key proposals

1. Supporting the growth of Heat networks

6.4.1 Previous SEA work recognises that the installation of district heating network infrastructure such as pipes has the potential for localised environmental effects including short term negative effects on material assets from new development activities. Localised negative effects on population and human health could also arise such as, through noise linked to the operation of heat pumps. Potential localised negative effects on landscape and cultural and historic heritage could also occur as a result of at scale changes to infrastructure necessary for deployment. For example, the installation of an individual air source heat pump would require an external unit, which would require a place outside the home where it can be fitted to a wall or placed on the ground, including space around it to ensure the flow of air. The size of the unit could vary greatly depending on the building’s heat demand and the local characteristics.

6.4.2 Localised mixed/uncertain secondary effects on a range of SEA topics could occur as a result of the deployment of heat pumps and heat networks, the significance of which would be largely dependent on the scale as well as location with respect to sensitive human, natural and cultural receptors.

6.4.3 Localised positive effects on material assets and population and human health could also occur from support for more affordable and locally available supplies of heat associated with heat networks.

6.4.4 Any potential adverse impacts are considered likely to be mitigated by existing mechanisms such as the planning system as well as environmental guidance and on-site management measures and these, as well as potential strategic mitigation opportunities, are discussed further in Section 7.

6.4.5 Adverse localised effects on a number of SEA topics such as population and human health, soil, water, air and biodiversity, as a consequence of construction and infrastructure improvement works could also occur but it is recognised that these effects are likely to be temporary in nature.

6.4.6 Previous SEA work highlights that further benefits for population and human health are also likely to arise from improved security of energy supply and reduced heat demand, which may also have benefits for general health and wellbeing. The above benefits are likely to be experienced to a greater extent where support is focused towards those living in deprived areas.

6.4.7 Significant positive effects for material assets are also considered likely from the approach presented across all proposals which is technology agnostic. This is because a focus on strategically important technologies that are ready for deployment (energy efficiency measures, heat pumps and heat networks) in the short term, as well as recognition of a potential role for hydrogen for example, in the long term can enable the flexible and stable operation of the energy network at a national scale.

Considered cumulatively

6.4.8 Cumulative positive effects for material assets are also considered likely as a result of benefits associated with a greater diversity in technologies and future-proofing energy supply as a means to support greater resilience to the effects of climate change.

6.4.9 Mixed/uncertain secondary effects on a range of SEA topics could also occur as a result of the take up of strategically important energy efficiency measures and heat technologies ready for deployment. Effects could range from permanent to temporary and significance would be dependent on a number of factors, including scale, siting and design.

2. Prohibiting the use of Direct Emissions Heating systems, including the establishment of dates for compliance (both backstop and interim triggers)

6.4.10 The prohibition of fossil fuels in a phased way affecting all existing properties, will make a direct contribution to the reduction of emissions over the medium and longer term and change the contribution made by the built sector to the legally binding targets. This will contribute to broad environmental benefits for climatic factors, air, population and human health and material assets. Similarly the requirement to meet minimum energy efficiency standards will help to reduce demand for energy from that property, and in turn, reduce bills. This will then contribute positively to broad environmental benefits for population and human health. This will be further developed through the support systems which will sit alongside the standards proposed. Where outcomes recognise existing biodiversity targets this can also contribute to broad environmental benefits for biodiversity, soil and water.

6.4.11 Linked to this, there is potential for associated significant positive effects for air quality (as emissions and air pollutants often originate from the same source), as well as associated benefits for population and human health. Previous SEA work highlights that further benefits for population and human health are also likely to arise from improved security of energy supply and reduced heat demand, which may also have benefits for general health and wellbeing. The above benefits are likely to be experienced to a greater extent where support is focused towards those living in deprived areas.

6.4.12 Cumulative positive effects for climatic factors are considered likely as a result of reducing GHG emissions associated with broad support for measures that reduce the overall demand for heat (see below). Associated air quality improvements are also considered likely due to linkages between sources of GHG emissions and air pollutants such as particulate matter

6.4.13 The setting of requirements which will drive change will aid the supply chain in planning and delivering across Scotland will contribute to the broad environmental benefits of population and human health, and material assets.

6.4.14 The costs associated with changes needed to properties to remove direct emissions heating systems are likely to have a negative effect on population and human health. This can be viewed however against the supportive services which Scottish Government already offers through its various advice service third party providers (HES, BES, etc) and through its targeted delivery programmes including for those in fuel poverty.

6.4.15 Cumulative positive effects for population and human health are also considered likely where a focus is given to reducing fuel poverty. For example, individual heat pumps can be highly effective in most buildings when they are combined with appropriate energy efficiency measures.

6.4.16 Mixed effects on a range of SEA topics could occur as a result of the standard when considered with the secondary phasing, triggers and abeyances. The impact of these latter provisions will spread the impacts of standard and allow for more individualised application.

6.4.17 Any potential adverse impacts are considered likely to be mitigated by existing mechanisms such as the planning system, the provision of environmental guidance and on-site management measures and the targeting of support and advice, together with the above mentioned use of abeyances and variations to the standard. Local mitigation is discussed further in Section 7.

6.4.18 The use of phasing through property purchase will similarly make a direct contribution to the reduction of emissions over the medium and longer term and change the contribution made by the built sector to the legally binding targets. This will contribute to broad environmental benefits for climatic factors, air, population and human health and material assets. Where outcomes recognise existing biodiversity targets this can also contribute to broad environmental benefits for biodiversity, soil and water.

6.4.19 As with the domestic standard, linked to this, there is potential for associated significant positive effects for air quality (as emissions and air pollutants often originate from the same source), as well as associated benefits for population and human health. Previous SEA work highlights that further benefits for population and human health are also likely to arise from improved security of energy supply and reduced heat demand, which may also have benefits for general health and wellbeing. The above benefits are likely to be experienced to a greater extent where support is focused towards those living in deprived areas.

6.4.20 Cumulative positive effects for climatic factors are also considered likely here, as a result of reducing GHG emissions associated with broad support for measures that reduce the overall demand for heat. Associated air quality improvements are also considered likely due to linkages between sources of GHG emissions and air pollutants such as particulate matter.

6.4.21 The setting of standards which aid the supply chain in planning and delivering across Scotland will contribute to the broad environmental benefits of population and human health, and material assets.

6.4.22 As with domestic properties, installation and operation of energy efficiency measures could, in principle give rise to some localised negative effects on biodiversity (as a result of works undertaken in roof cavities/loft insulation, which may hold bat roosts, for example). These measures may also impact negatively on cultural and historic heritage (such as directly from visual impacts on properties and their environs). This could also be true for the installation of clean heating systems, such as air source heat pumps. The impacts of these measures could more broadly have a minor localised negative effect on landscapes (such as directly from visual impacts on settings). The installation works for both energy efficiency measures and clean heating systems could have localised and short term negative effects on population and human health, and air quality, occurring as a result of construction activity and development. These effects are likely to be temporary in nature.

6.4.23 Mixed effects on a range of SEA topics could occur as a result of the standard when considered with phasing as a result of property purchase, and variations. The impact of these latter provisions will spread the impacts of standard and allow for more individualised application.

6.4.24 Any potential adverse impacts are considered likely to be mitigated by existing mechanisms such as the planning system as well as environmental guidance and on-site management measures. Local mitigation is discussed further in Section 7.

3. Setting minimum energy efficiency standards for domestic properties

6.4.25 The setting of a standard to be met by all domestic properties which, by the end date, will improve the energy efficiency of those properties, thus reducing their demand for energy, is designed to make direct contribution to our commitments to climate change targets. They deliver on the commitments of other PPS including, in particular, the Heat in Buildings Strategy. Considered separately and together the measures to prohibit direct emissions heating, and improve energy efficiency will make a significant positive effects for climatic factors, population and human health, air and material assets.

6.4.26 Cumulative positive effects for climatic factors are considered likely as a result of reducing GHG emissions associated with broad support for measures that reduce the overall demand for heat (see above). Associated air quality improvements are also considered likely due to linkages between sources of GHG emissions and air pollutants such as particulate matter

6.4.27 As above, the setting of standards which aid the supply chain in planning and delivering across Scotland will contribute to the broad environmental benefits of population and human health, and material assets.

6.4.28 Installation and operation of energy efficiency measures could, in principle give rise to some localised negative effects on biodiversity (as a result of works undertaken in roof cavities/loft insulation, which may hold bat roosts, for example). These measures may also impact negatively on cultural and historic heritage (such as directly from visual impacts on properties and their environs). This could also be true for the installation of clean heating systems, such as air source heat pumps. The impacts of these measures could more broadly have a minor localised negative effect on landscapes (such as directly from visual impacts on settings). The installation works for both energy efficiency measures and clean heating systems could have localised and short term negative effects on population and human health, and air quality, occurring as a result of construction activity and development. These effects are likely to be temporary in nature. Localised positive effects on population and human health are also considered likely (as a result of reducing the cost of achieving thermal comfort).

6.4.29 As above, the costs associated with changes needed to properties to improve the energy efficiency standard are likely to have a negative effect on population and human health. This can be viewed however against the supportive services which Scottish Government already offers through its various advice service third party providers (HES, BES, etc) and through its targeted delivery programmes including for those in fuel poverty.

6.4.30 Cumulative positive effects for population and human health are also considered likely where a focus is given to reducing fuel poverty. For example, fabric first measures can help to reduce the cost of achieving thermal comfort. Individual heat pumps can also be highly effective in most buildings when they are combined with appropriate energy efficiency measures.

6.4.31 As above, Mixed effects on a range of SEA topics could occur as a result of the standard when considered with the phasing, early trigger as a result of property purchase and abeyances. The impact of these latter provisions will spread the impacts of standard and allow for more individualised application.

6.4.32 Any potential adverse impacts are considered likely to be mitigated by existing mechanisms such as the planning system, the provision of environmental guidance and on-site management measures and the targeting of support and advice, together with the above mentioned use of abeyances and variations to the standard. Local mitigation is discussed further in Section 7.

4. Providing flexibility

6.4.33 Mixed effects on a range of SEA topics could occur as a result of the standard when considered with the use of triggers and abeyances. The impact of these latter provisions will spread the impacts of the standard and allow for more individualised application.

6.4.34 As above, the setting of standards in a way which provides clarity to the supply chain and smooths out the uptake of change, and thus smooths the impact on suppliers in planning and delivering across Scotland will contribute to the broad environmental benefits of population and human health, and material assets

6.4.35 Any potential adverse impacts are considered likely to be mitigated by existing mechanisms such as the planning system, the provision of environmental guidance and on-site management measures and the targeting of support and advice, together with the above mentioned use of abeyances and variations to the standard. Local mitigation is discussed further in Section 7.

6.5 Do the key proposals address key environmental issues identified?

6.5.1 Taken together, and when considered in the round, the proposals set out in the Consultation are likely to contribute to addressing the key environmental issues identified. Significant reductions in GHG emissions associated with Scotland’s homes and buildings are likely as well as associated benefits for air and population and human health (including through measures which help mitigate fuel poverty). Further, a technology neutral position is likely to contribute to diversifying energy supply and can support the use of local energy systems, with the potential to improve the resilience of energy networks (including to the impacts of climate change).

6.5.2 The assessment recognises that there is potential for direct and indirect impacts on cultural and historic heritage and landscape associated with the development and deployment of energy efficiency measures and heat technologies and their associated infrastructure now and in the future. It is considered that existing mitigation measures as well as strategic mitigation opportunities can help ensure that potential adverse effects are avoided and positive effects enhanced. Further opportunities for mitigation and enhancement are included in Section 7.