Heat and energy efficiency strategies and district heating regulation: consultation

Section A: Local Heat & Energy Efficiency Strategies To Support Delivery Of Energy Efficiency And Heat Objectives Of Seep

A1. Current Position

27. Currently local authorities are encouraged, with support from the Heat Network Partnership, on a voluntary basis to develop district heating strategies, or to include a district heating element in wider strategies or plans such as Sustainable Energy Action Plans. Additionally, the Scottish Planning Policy sets out that Local Development Plans should use heat mapping to identify the potential for co-locating developments with a high heat demand with sources of heat supply and should identify where heat networks, heat storage and energy centres exist or would be appropriate and include policies to support their implementation ^[11] .

28. Local authority Housing Strategies also generally tend to include some high-level information on the authority's approach to addressing climate change and fuel poverty for the area's housing stock.

29. This has led to a wide range of approaches from local authorities which have varied in their effectiveness with regard to district heating. Some have done little to identify opportunities and support development of district heating. Others have mapped areas of opportunity within their Local Development Plans and developed supportive policies and/or are on the verge of publishing district heating strategies setting out priority projects identified, mapped and with a delivery programme.

30. With the recommendation of the Expert Commission's SWG that each local authority is required to develop and publish a strategic plan for developing district heating, and the development of the SEEP programme, there is an opportunity to create a new regulatory framework to ensure the development of local strategies that take into account reduced future heating needs by also programming energy efficiency and other heat decarbonisation activity. This coordinated strategic approach will be key for Scotland to meet our climate change targets as set out in our draft Climate Change Plan, which shows that by the mid-2030s there will need to be almost complete decarbonisation of our buildings, requiring significant reductions in our use of natural gas, which is currently our main source of heat, and other fossil fuels.

31. In response to these recommendations, and in developing SEEP, the Scottish Government is now considering the introduction of a statutory duty for local authorities to develop Local Heat & Energy Efficiency Strategies ( LHEES). These would set a framework and delivery programme for how each local authority would both reduce the energy demand and decarbonise the heat supply of buildings in its area, across the timeframe of the strategy, to ensure progress against the national objectives of SEEP. Below, we set out our initial proposals on what these would contain, and how they could be delivered to support our heat decarbonisation and energy efficiency objectives.

A2. Key Components Of A Potential Regulatory Framework For Local Heat & Energy Efficiency Strategies

32. The Working Group discussed an approach for Local Heat & Energy Efficiency Strategies whereby:

• guidance for LHEES would be set nationally to ensure a consistent approach to them delivering the national programme objectives for SEEP, including on strategy level socio-economic assessment;
• a number of key organisations should be included in the guidance as organisations invited to provide input or that may be statutory consultees;
• some form of scrutiny of LHEES would be required centrally by ministers or another central body (to ensure that the guidance had been adhered to and that, when taken together, LHEES would achieve the changes required); and
• LHEES are updated regularly, to ensure that the LHEES remain up-to-date, should wider infrastructure changes occur. Each LHEES would include a delivery programme for its duration, setting out how the local authority would achieve its heat decarbonisation and energy efficiency objectives for buildings in its area, to ensure programme implementation. A number of alternative updating timescales have been suggested including every five years or every three years for the delivery plan and six, nine or 10 years for the rest of the LHEES.

A3. Scope And Content

33. A balance needs to be found between making the scope and content of the strategies narrow enough to allow for maximum resource to be focused on delivery, but sufficiently wide to enable the vision to be communicated to the local community without the risk that the strategy preparation becomes the main focus rather than delivery. At the same time, the legislative competence of the Scottish Parliament is a restrictive factor, if these strategies are to be a requirement upon local authorities.

34. The focus of SEEP as a national programme is on energy demand reduction and heat decarbonisation of buildings. Therefore, it is suggested that LHEES should focus on how to reduce demand for and decarbonise energy used for space and water heating and cooling in buildings, but also considering the implications for processes such as cooking. This would entail strategies that considered both how to improve the energy performance of buildings, and how to decarbonise their heat supply, and should consider availability of surplus industrial and other potential low carbon heat to provide the supply.

35. It has been suggested that LHEES should develop an area-based approach and that strategies should:

a) cover a long-term period such as 20 years;

b) reflect the national fuel poverty and climate change targets and set out how they contribute to them;

c) take into account other national targets and ambitions in respect of heat and energy efficiency as set out in the Scottish Government's policies such as the draft Energy Strategy, Climate Change Plan and SEEP, including the indicative levels of implementation and to set out how they contribute to these;

d) take into account what policies and frameworks already exist for energy efficiency and heat at a local level, such as local housing strategies or local development plans;

e) set out understanding of current energy performance and heat use of buildings within the local authority's area;

f) identify potential opportunities including for reducing the need for heat, improving energy efficiency of heat supply, increasing low carbon heat sources and low carbon heat storage;

g) set long-term targets to ensure that all buildings in the local authority's area are able to improve their energy efficiency and decarbonise their heat supply in line with national objectives set by the Scottish Government;

h) undertake an area-based socio-economic assessment that would be used to assess the energy efficiency interventions and to identify the most appropriate heat technology for an area and to designate district heating zones;

j) set out costed, phased delivery programmes for each strategy period, to ensure that a proportion of buildings in the local authority's area are improved - cumulatively ensuring that all buildings are improved across all strategy periods to meet the long-term target;

k) include the phased zoning of different parts of each local authority for:

• development of district heating networks in appropriate areas (see Section B)
• installation of new low carbon heat supplies
• area-based energy efficiency improvement programmes;

l) quantify the short-term benefits and impacts of delivery plans; and

m) consider the impact on the local economy and employment.

36. These phased delivery programmes would:

a) take account of potential support from wider programmes;

b) support the delivery of national standards;

c) for the early years of the strategy (such as the first five) set out the detail of the approach or 'offer' to properties in those prioritised areas to enable them to improve their energy efficiency and decarbonise their heat supply; and

d) set out how the local authority (and the local planning authority) will use its powers to help deliver the strategy).

37. We are considering placing a statutory duty upon local authorities to work with relevant stakeholders to develop a LHEES, and to use their powers to implement that strategy. These strategies would have a scope and content as set out above. Local authorities would be supported in developing these strategies with the provision of national guidance and data sets, such as the Scotland Heat Map.

38. It will be important for local authorities to have the skills and resource to prepare and deliver such strategies and for the appropriate parts of a local authority (and where relevant national park authorities ^[12] ) to be involved in the development and delivery of the strategy. We recognise that preparation and implementation of these strategies represents an additional burden on local authorities and seek your views on the skills, resource and support that may be needed by local authorities in section B6.

Questions

Q1. Do you agree that local authorities should have a duty to produce and implement a Local Heat & Energy Efficiency Strategy ( LHEES) as outlined above? Please explain your view.

Q1b. What are your views on the appropriate geographical scale for the preparation of LHEES? Should each local authority produce a single strategy for its area, or would it be possible for local authorities to work together to prepare strategies jointly for a wider area?

Q2. Do you agree with the proposed scope and content for LHEES? In particular do you agree LHEES should (a) set targets for energy efficiency and decarbonisation and (b) include a costed, phased delivery programme that will meet local targets? Please explain your views.

Q3. Please provide any evidence you have regarding the data available (or that could be available) to local authorities that would be useful or key to preparing and implementing such plans beyond the Scotland Heat Map and the EPC Register (including data held both within and outwith the public sector).