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

6. Overview of campaign responses

Twenty four respondents submitted a campaign response to the consultation. All were construction and development organisations. As noted in the introduction, three of these 24 respondents also submitted their own response via Citizen Space. While both responses have been included in the analysis, each of these organisations is only counted once in the total of 350 responses.

The campaign responses used the same wording highlighting work undertaken by Homes for Scotland related to the proposals. As the responses did not directly answer the consultation questions, it was not practical to include them in the question-by-question analysis which has been presented throughout this report. This chapter therefore summarises the key points and presents the text submitted by these respondents.

Most responses began with an introduction to the work of the organisation responding, before highlighting their concerns about the proposals. In summary, the responses outline the positive effect of existing regulation on improving the energy efficiency of new buildings in Scotland but suggests that further regulation may have limited further impact on energy efficiency, but a significant impact on the supply of new homes in Scotland.

The full text submitted follows:

"Scotland is facing a national housing emergency with all data pointing to this continuing to intensify: record numbers of households and children are in temporary accommodation; over half the population is living in local authority areas that have declared a local housing emergency; and all-tenure housing starts have plummeted to the lowest yearly start since records began.

In this context, we are deeply concerned about the consequences of introducing a directly equivalent standard to Passivhaus in Scotland. With new homes in Scotland already highly energy-efficient, we believe this would further increase the negative cumulative impact of a raft of new regulation on what is an already heavily regulated sector and make the delivery of much-needed homes of all tenures even more challenging.

We understand, respect and support the commitment that the Scottish Government has made to make Scotland a net zero society by 2045. We recognise that we all have our part to play to reduce greenhouse gas emissions (continuing the significant progress that has already been made in relation to the construction and operation of new build homes) at the earliest practicable opportunity.

This must be done in a viable way that does not compromise Scotland's ability to deliver new high-quality homes at the scale and pace required to tackle the housing emergency that is gripping the country, limiting social mobility and stifling economic growth. As such, we fully support the submission from our representative body Homes for Scotland (HFS) which includes the following points:

HFS has tabled an evidenced proposal demonstrating that homes built to the 2024 New Build Heat Standard will deliver an 80%+ reduction in annual in-use carbon levels, compared to a home built to 1990 building standards. This exceeds the Scottish Government's previously stated ambition to reduce emissions by 75% by 2030.

The reduction in in-use carbon achieved to date, including through the introduction of the New Build Heat Standard, is such that we do not believe that a further significant change of the scale envisaged by the introduction of a Scottish equivalent to Passivhaus is warranted. We are at a tipping point of diminishing returns.

If, at a time of national housing emergency, the Scottish Government intends to further regulate on this it is essential that it adopts a pragmatic approach. HFS recognises the challenges faced by both those seeking to rent or buy a home that meets their needs and is affordable to them, and companies delivering new homes to help meet this need.

The Scottish Government has been clear since 2023 that the new standard for new build housing must: improve energy efficiency, thermal performance, comfort and health in a way that is affordable. HFS is proposing a pragmatic and deliverable approach that achieves all of these objectives in a way that not only reduces operational costs and carbon emissions but can also be delivered at scale by home builders.

The work by HFS and its engagement with government has used sector data and evidence from large private home builders, RSLs and SMEs who build across all areas of Scotland and who deliver a wide variety of home types. This collective knowledge and intelligence has ensured that our response provides an accurate position of the practical realities of delivering homes of all tenures.

The HFS approach demonstrates how the new build housing sector currently performs and what more can to be done to meet the requirements set out by Government. Its sector backed model delivers homes that have:

1) All electric net zero carbon heating and hot water;

2) Photo voltaic energy generation;

3) Smart Metering and Controls Enhanced air tightness that doesn't require Mechanical

4) Ventilation with Heat Recovery (MVHR); and,

5) High standards of building fabric

As a result of its modelling, we are confident that HFS has developed a standard which:

1) Uses up to 70% less energy than a 1990 standard home

2) Produces up to 95% less carbon than a 1990 home

3) Costs the householder only between 2%-4% more to run (mortgage/rent, energy bills and maintenance) than a 1990 home.

4) Enables home builders to continue delivering more of the much-needed, highly energy efficient and sustainable homes required to address the housing emergency."

Some campaign respondents concluded their response with a short, personalised statement highlighting one or both of the following points:

• Concern about the increasing levels of regulation and additional standards being applied to the sector in Scotland, highlighting their view that this will lead to higher build costs, particularly in rural areas.
• Calling on the Scottish Government to adopt a practical, sustainable and cost-effective approach which does not limit the sector's ability to build affordable homes to tackle Scotland's housing emergency.