Determining the principles for a Scottish equivalent to the Passivhaus standard - Analysis of Consultation Responses

Proposed changes to energy and environmental standards within Scottish building regulations. The consultation analysis report on the responses to the proposals set out in the July 2024 consultation.


Appendix B: Consultation Questions

Q1. Do you broadly agree with the statements on what 'equivalent' should not mean, in delivery of amended building standards to address energy and environmental performance?

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Q2. Do you broadly agree with the statements on what 'equivalent' should require consideration of, in delivery of amended building standards to address energy and environmental performance.

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Q3. On the basis that HEM and SBEM are reviewed and shown to report representative outcomes, do you support the continued use of calculation tools which implement the UK methodologies?

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered, including your experience of PHPP as a calculation tool.

Q4. Do you support retention of the current approach and the setting of relative performance targets for new buildings through an approved calculation methodology?

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Q5. Do you agree with the proposal to retain delivered energy, covering only regulated energy use, as the main compliance metric for targets set under standard 6.1 (energy demand)?

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Q6. Do you support further consideration of the introduction of a prescriptive space heating demand limit for new buildings through building regulations?

Yes / No

If you answered 'Yes', please provide information on what form of prescription you would support and the potential benefits and/or risks this may create.

Q7. Do you support the move to application of regional climate data within the approved calculation methodologies and their application within compliance targets?

Yes / No

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Q8. Do you currently deliver new buildings that exceed 'backstop' values for fabric performance set under standard 6.2 or those used to define the notional building in guidance to standard 6.1?

Yes / No

If you answered 'Yes', please provide information on the solutions you apply, any challenges experience and your views on wider application of such solutions.

Q9. Do you have any particular views on limiting fabric infiltration through the building standards?

Yes / No

If you answered 'Yes', please provide your views and any supporting information on the benefits and risks arising from greater prescription on this topic.

Q10. Do you have any particular views on the means by which effective ventilation of new buildings is best achieved?

Yes / No

If you answered 'Yes', please provide your views and any supporting information on the benefits and risks identified in the delivery of your projects.

Q11. Specifically for new homes should further guidance be given on MVHR, generally, and through the Technical Handbooks?

Yes / No

If you answered 'Yes', please describe what approach to this work you consider would be most appropriate in driving forward informed, good practice on both energy and ventilation performance.

Q12. Are there areas of newbuild design and specification you would wish to highlight as potential risks to occupant comfort that should be better addressed through the building standards?

Yes / No

If you answered 'Yes', please provide examples of the issues encountered and, where available, the solutions employed to address the problem.

Q13. Do you consider that Passivhaus Certification offers a feasible alternative means of compliance with standard 6.1 (energy demand)?

Yes / No

Please provide information on why you agree or disagree and on the extents to which this alternative might be usefully applied in practice.

Q14. Are there any other comments or observations you wish to make on the proposed components of the review which relate to building design?

Yes / No

If you answered 'Yes', please provide your further comments or observations. Additional supporting information may also be provided by attaching a separate document to your response.

Q15. Do you currently apply an in-house or third-party compliance management process to your projects which specifically addresses energy and environmental project elements?

Yes / No

If you answered 'Yes', please provide information summarising your approach and the key benefits you derive from its application in practice.

Q16. From your experience of delivering very low energy buildings, what are the most common risks identified at an early design stage and how are they managed most effectively?

Q17. Do you consider there are practical limits to effective risk management at design stage alone and can you give examples of where management of risk is more effective at a later (construction) stage?

Q18. Do you currently apply a particular approach to the recording of project information during construction that can demonstrate, to a third party, that work complies with energy-related aspects of building regulations?

Yes / No

If you answered 'Yes', please provide information summarising your approach and the key benefits you derive from its application in practice.

Q19. Do you currently compile and report summary information on the completed building as part of a handover record of project information that goes beyond what is currently required by building regulations?

Yes / No

If you answered 'Yes', please provide information summarising your approach and the key benefits you derive from its application in practice.

Q20. Do you have experience of implementing methods to effectively de-risk the very low energy building aspects of design and construction and provide assurance that the compliant solutions are properly considered and delivered as intended?

Yes / No

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

Q21. Do you consider the proposals set out present a reasonable summary of why there is a need for improvement in compliance processes to deliver very low energy buildings?

Yes / No

Please provide information on why you agree or disagree and on any drivers for improvement you consider particularly important.

Q22. Do you consider the proposed scope of application and recommended actions are appropriate to address the effective delivery of very low energy buildings?

Yes / No

Please provide information on why you agree or disagree and on what other actions may be useful in driving compliance.

Q23. Do you support the application of provisions from an early (pre-warrant) design stage through to completion and handover of the building?

Yes / No

Please provide information on points in the process you consider there may be a need for particular emphasis on action to manage the risk of failures in compliance.

Q24. Do you have any views on the key areas where the verification process should focus, to be effective in responding to an enhanced compliance reporting regime?

Yes / No

If you answered 'Yes', please provide your view.

Q25. Do the recommendations presented adequately describe action to affect the key roles and responsibilities of those who contribute to building compliance?

Yes / No

Please provide information on anything else you consider to be relevant to the actions of such parties.

Q26. 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'.

Q27. 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.

Q28. 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.

Q29. 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.

Q30. Do you agree with the proposal to mandate the standard in 2028, introducing changes initially as a voluntary standard from 2026?

Yes / No / Not sure

Please provide information on why you agree or disagree or if you consider other actions need to be considered.

Contact

Email: buildingstandards@gov.scot

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