Social housing net zero standard consultation: island communities impact assessment

Step One – Develop a clear understanding of your objectives

7. Section 7 of the 2018 Act states that a relevant authority must have regard to island communities in carrying out its functions. Guidance states that first step should be to develop a clear understanding of the objectives and intended outcomes of a strategy and then, more specifically, identify if there are explicit island needs or any potential direct or indirect impacts for island communities.

Proposals for a new Social Housing Net Zero Standard consultation - Policy Aim

8. The aim of the policy is to review the post-2020 milestones of the Energy Efficiency Standard for Social Housing (EESSH2) to ensure they are aligned with statutory net zero targets, and ensure a just transition.^[3]

9. Net zero target: section A1 of the Climate Change (Scotland) Act 2009 requires that the net Scottish emissions account is at least 100% lower than the 1990 baseline by 2045.^[4]

10. Just transition: this means, as a minimum, that the costs of working towards meeting climate targets does not fall disproportionately on tenants, through higher rents or fuel costs, but also that we do not accept leaving some people in housing that is hard to heat.

Summary of proposal

11. The proposal seeks to introduce a new Social Housing Net Zero Standard. This will replace the post-2020 Energy Efficiency Standard for Social Housing (EESSH2). Current proposals, that have been co-developed with social housing stakeholders involved in the review of EESSH2, are as follows:

• A fabric efficiency rating (which focuses on the amount of energy for heat consumed by a property) measured in kWh/m²/year.
• A requirement to replace polluting heating systems^[5] with a clean heating system alternative by a backstop date of 2045.
• Ancillary elements of the proposed standard include measures to ensure air quality, variation of the standard in specific cases, and restrictions on re-letting property that cannot be brought up to standard.

Island needs or potential impacts for island communities

12. The proposals included in this consultation will affect social housing tenants and social landlords in Island Communities. The policy aim is to set a standard which supports net zero in line with the statutory target for 2045, and also to ensure a just transition.

13. Our island communities are not connected to the mains gas network. Islands can be connected at the periphery of electricity networks, whilst a small number of our island communities are also not connected to electricity grids and face unique challenges in their efforts to reduce emissions.

14. The potential for reduced supply chain availability, added transport requirements, limited accommodation for contractors and potential weather disruptions means that clean heating systems can cost more to install in our rural and island communities.

15. The National Islands Plan^[6] acknowledges that extreme fuel poverty rates are higher for most of the island authorities. We also know that extreme fuel poverty can be particularly difficult to eliminate in island communities where building types are harder to improve to the required energy efficiency standard and opportunities to reduce fuel costs are more limited. In addition, traditionally constructed buildings and energy efficiency challenges can vary between the islands. Such issues combined with the colder climate in the islands means that some of these homes might have the heating on throughout the whole year. Higher living costs on islands, combined with higher fuel costs, for households on low incomes, can create the conditions for extreme fuel poverty. The substantial increase in energy costs since August 2021 is likely to have exacerbated these issues further.

Beneficial impacts

16. There are, importantly, key benefits that properly installed clean heating systems can bring to island communities. Specifically, these span improved thermal comfort and health benefits and protection of the unique natural environment of Scotland's islands and rural communities through climate change mitigation

Moving Forward

17. As we take forward the development of the new Social Housing Net Zero Standard we will ensure that the issues highlighted here are considered in the design of development of further policy and regulation.