Heat in Buildings Bill consultation: strategic environmental assessment

7. Conclusions, Mitigation and Enhancement

7.1 Conclusions

7.1.1 The assessment concludes that the proposals set out in the Consultation are likely to have significant positive effects on climatic factors, air, population and human health and material assets. This is increase over time as the backstop dates of 2033 for energy efficiency standards, and 2045 for heating are reached.

7.1.2 The potential for effects in combination with other plans, programmes and strategies has also been considered. The Consultation, and its subsequent Bill have the potential to positively and cumulatively contribute across a wide range of Scottish Government policy areas within the context in which it sits.

7.1.3 Taking into account the high-level nature of the Consultation and any subsequent Bill, which will rely on secondary legislation to provide the detail of delivery, there is some inherent uncertainty regarding the environmental impacts that may arise as a result of upscaling expected as a result of legislative requirements for all buildings.

7.1.4 The assessment identifies the potential for mixed/uncertain secondary effects on a range of SEA topics as a result of the expected deployment of energy efficiency measures and heat technologies ready for deployment (including energy efficiency measures, heat pumps and heat networks) at the local level. Existing mitigation measures can help to address these.

7.1.5 The assessment further recognises that the precise effects would be dependent on a range of factors including the scale of development and deployment of individual technologies as well as location with respect to sensitive human, natural and cultural receptors. Existing mitigation at the local level can help to address these and relevant emerging PPS also has the potential to provide mitigation at the strategic level.

7.2 Mitigation

Local mitigation measures

7.2.1 Where future development and deployment of strategically important energy efficiency measures and heat technologies have the potential to result in secondary mixed/uncertain effects consideration should be given to opportunities to mitigate any such effects at lower tiers of plan-making and at the project level. This is likely to occur only in the case of heat networks which will be the subject of specific and individual permissions.

7.2.2 There are a range of existing mitigation measures in place which may apply including EIA, environmental management plans, European protected species licencing, and through the planning system as well as best practice guidance such as that with a focus on landscape^[69] and the historic environment^[70] Sustainability management tools such as those under the Renewable Heat Incentive, which includes requirements for biomass used in renewable heat installations to meet a set of sustainability criteria that aim to guarantee that it was sustainably produced, are also relevant.

Strategic Mitigation

7.2.3 The assessment further recognises that any future upscaling of heat technologies has the potential for mixed/uncertain environmental effects across SEA topics but precise effects would be dependent on a range of factors including the scale of development and deployment of individual technologies as well as location with respect to sensitive human, natural and cultural receptors. Emerging and future PPS at the lower-tier can potentially provide for more detailed consideration of environmental effects and set out the potential for future strategic level mitigation, taking into account the findings of this SEA.

7.2.4 In addition to local mitigation measures identified above, the development of emerging and future PPS with a focus on specific technologies (such as national action plans), place-based approaches to energy efficiency and heat decarbonisation (such as lower tier plans) and national PPS that focus on planning and land use (such as NPF4, and the third Land Use Strategy) are particularly relevant as they could potentially provide mitigation at the strategic level.

7.2.5 For example, at the national level, powers contained within a future Heat in Buildings Bill will require the introduction of secondary regulations which will be the subject of further scrutiny at a more detailed level.

7.2.6 Also, the roll-out of Local Heat and Energy Efficiency Strategies will provide an important platform to consider both local community and wider national infrastructure issues and their associated potential environmental effects. These Strategies will set out the long term vision for decarbonising heat in buildings and improving their energy efficiency on a local authority area basis.

7.3 Opportunities for Enhancement

7.3.1 The SEA findings support the introduction of a 2045 backstop date and energy efficiency and heat decarbonisation aspirations of the consultation. The proposed Heat in Buildings Bill and any future secondary regulations to roll out its primary powers begin a positive journey to realise the Scottish Government policies and proposals laid out in the Heat in Buildings Strategy in relation to heat transition for buildings across Scotland. When taken together with existing PPS the proposals can contribute to significant positive environmental effects across all sectors.

7.3.2 The SEA supports the technology neutral approach proposed in the consultation regarding heat systems which might achieve zero emissions. This coupled with a focus on fabric first energy efficiency measures recognises the need for choice in achieving the behaviour change needed to achieve the targets.

7.3.3 The following specific opportunities for enhancement have been identified:

• To obtain the maximum environmental benefits, a focus could be given to actions that support opportunities for early take up of the Standard across domestic stock. This could be done through support, advice and messaging to raise the profile of the Standard and works needed to meet it.
• To obtain the maximum environmental benefits a focus could be given to people living in deprived areas and in rural areas where extreme fuel poverty rates are highest. This could be done through the existing delivery programmes where there is a focus on those in or at risk of becoming fuel poor.
• To obtain maximum environmental benefits a focus could be given to deployment of zero emissions technologies in areas which currently use high carbon heating fuels, and in areas recognised as being cost effective in the short term and in areas least likely to receive a heat network in the longer term. This could be done through focused targeting and messaging.
• To obtain maximum environmental benefits a focus could be given to working with stakeholders, such as Historic Environment Scotland, to develop more solutions to transition Scotland’s historic buildings to zero emissions heating while respecting and preserving the special characteristics of our buildings and places.