Heat in buildings strategy: strategic environmental assessment

Non-Technical Summary

Introduction

This is a non-technical summary of the Environmental Report of the draft Heat in Buildings Strategy (‘The draft Strategy’).

In order to meet our interim climate targets and ensure long-term delivery of our net-zero objectives, the Update to the Climate Change Plan^[1] sets out that by 2030 around 50% of homes, or over a million households will need to convert to a zero or low emissions heating system. Reducing emissions from homes will mean converting the vast majority of the 167,000 off-gas homes that currently use high emissions oil, LPG, and solid fuels, as well as at least 1 million homes currently using mains gas, to zero-emissions heating. By 2030, we will also need to convert an estimated 50,000 of Scotland’s non-domestic properties to zero emissions sources of heat. The Climate Change Plan Update was subject to a full Strategic Environmental Assessment^[2]

The draft Strategy sets out actions and proposals for transforming our buildings and the systems that supply their heat, ensuring all buildings reach zero emissions by 2045. It provides an update to the 2018 Energy Efficient Scotland Route Map^[3] and the 2015 Heat Policy Statement^[4], and brings together ambitions on energy efficiency and heat decarbonisation for Scotland into a single framework.

The draft Strategy introduces a 2045 vision and supporting energy efficiency and heat decarbonisation outcomes. It also sets out the intention, through a finalised Strategy, to set a new heat target, the purpose of which is to help monitor and track progress in delivering the deployment pathway for reducing emissions in buildings, as set out in the Update to the Climate Change Plan.

To support the delivery of the sectoral emissions envelopes set out in the Update to the Climate Change Plan, and given that there is no single technology that will work in all places for all buildings, the draft Strategy proposes a mixed technology or blended pathway as the most effective and credible means of achieving net zero. It highlights that near-term deployment should focus on those measures and technologies that are ready for deployment now (energy efficiency measures, heat pumps and heat networks) and in the short term.

The draft Strategy also recognises that other strategic heat technologies have the potential to play an important role in decarbonising our buildings but are likely only to become available at scale in the longer term, following a period of innovation and demonstration (for example, hydrogen) or will have a more limited role in decarbonising our buildings (for example, bioenergy).

Further, the draft Strategy recognises the role of a regulatory framework for zero emissions buildings. It also recognises the role of lower tier plans and strategies, such as future Local Heat and Energy Efficiency Strategies, (LHEES) in supporting the delivery of the draft Strategy’s ambitions. Where any future policies and proposals are developed, these will themselves be subject to consideration in accordance with the requirements of the Environmental Assessment (Scotland) Act (2005).

The draft Strategy’s policy context is presented below.

Flowchart showing the high level policy interaction between existing and forthcoming Scottish Government strategies, publications and legislation with the draft Heat in Buildings Strategy, including the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 and the Fuel Poverty (Targets, Definition and Strategy) (Scotland) Act 2019 and the Climate Change Plan update.

What is Strategic Environmental Assessment

Strategic Environmental Assessment (SEA) is the assessment of the likely significant environmental effects that a public plan, programme or strategy will have on the environment if implemented. Where possible, it proposes how negative effects can be avoided or reduced and identifies opportunities for positive effects to be maximised. SEA provides an opportunity for the public to express their views on the draft Strategy and on an Environmental Report setting out the assessment findings.

The Environmental Report has been prepared in accordance with the Environmental Assessment (Scotland) Act 2005. The SEA focused on the effect of the draft Strategy on climatic factors, air, population and human health, material assets, cultural heritage and landscape.

The Environmental Report sets out the assessment findings and makes recommendations for mitigation and enhancement where appropriate. Early comments from the SEA Consultation Authorities (NatureScot, SEPA and Historic Environment Scotland) have been taken into account in shaping how the assessment has been undertaken, what it covers, and the level of detail presented in the Environmental Report.

Key Environmental Issues

Climatic Factors: Summary and Key Issues

• Observed climate change trends are likely to intensify in the future – wetter winters and drier summers with an increase in the frequency of extreme
  weather events and climate change can negatively impact energy infrastructure – e.g. through flooding.
• Key issues for climate change include greenhouse gas emissions from a range of sources, with energy supply and use of homes and buildings contributing to emissions.
• Climate change can also give rise to indirect effects arising from mitigation and adaptation measures.
• Climate change has also been identified as a primary pressure on many of the SEA topic areas

Population And Human Health: Summary And Key Issues

• Scotland’s population is growing and Scotland has experienced a small increase in heat demand in recent years.
• Heat in buildings accounts for approximately a fifth of Scotland’s GHG emissions.
• Challenging weather, poor energy efficiency and reduced heating options (especially in rural areas) can make fuel bills unaffordable, resulting in fuel poverty.
• The potential impacts of climate change on population and human health will not be evenly spread. ( e.g. negative health impacts are likely to be disproportionately severe in area of high deprivation).

Air: Summary And Key Issues

• Whilst air quality has improved significantly, poor air quality in certain areas continues to affect human health and the environment
• Air pollution can contribute to a number of health problems and climate change may exacerbate these issues and alter current patterns and concentrations.
• Key issues for air include emissions from a number of sectors leading to air pollution with air quality and GHG emissions intrinsically linked as they both arise from broadly the same sources.
• Measures that seek to reduce emissions from buildings such as from improved energy efficiency and heat decarbonisation, have the potential to broadly contribute to improved air quality

Material Assets: Summary And Key Issues

• Today, heat is responsible for approximately half of Scotland’s energy use and buildings/ Infrastructure associated with the development/deployment of heat decarbonisation will play a key role in ensuring the future of its security of supply and decarbonisation.
• Key issues for material assets include those associated with development and infrastructure and pressure on land use.
• Changes in land use required to meet Climate change targets could also have environmental effects.

Landscape: Summary And Key Issues

• Scotland has numerous designated landscapes and other landscapes areas of value and quality and changes in land use and development can affect these.
• Key issues include the potential for direct and indirect impacts on landscapes associated with the development and deployment of technologies and new infrastructure associated with heat decarbonisation.

Cultural Heritage: Summary And Key Issues

• Scotland’s many and varied historical sites are unique and irreplaceable.
• Development is a key pressure on the historic environment and cultural heritage, both directly in terms of damage to known and unknown features, and possible impacts on setting.

What are the conclusions of the assessment

The assessment concludes that the draft Strategy is likely to have significant positive effects on climatic factors, air, population and human health and material assets. This is considered likely from the introduction of a proposed new 2045 vision and wide supporting energy efficiency and heat decarbonisation outcomes that draw together existing Scottish Government policies and proposals, and from the setting of a new heat target in a finalised Strategy.

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

Taking into account the high-level nature of the draft Strategy there is however an inherent degree of uncertainty regarding the environmental impacts that may arise as a result of upscaling of strategically important energy efficiency measures and heat technologies now and in the future.

The assessment identifies the potential for mixed/uncertain secondary effects on a range of SEA topics as a result of the deployment of strategically important 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.

The assessment further recognises that any future upscaling of heat technologies have 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. Existing mitigation at the local level can help to address adverse effects and relevant emerging PPS also has the potential to provide mitigation at the strategic level.

What are the proposals for mitigation and enhancement.

Where there is potential for secondary adverse effects associated with the development and deployment of strategically important energy efficiency measures and heat technologies in the short term further consideration should be given to opportunities to mitigate any such effects including at the local level. There are existing controls in place for example through the relevant consenting and licensing procedures that can help to address these. Further opportunities for strategic mitigation have also been identified.

In addition to local mitigation measures identified, 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.

The SEA findings support the introduction of a 2045 vision and supporting energy efficiency and heat decarbonisation outcomes. This approach, by providing a high level framework that draws together existing Scottish Government policies and proposals relating to energy efficiency and heat decarbonisation of homes and buildings can, when taken together with existing PPS, contribute to significant positive environmental effects across sectors.

The SEA findings also support the intention, through a finalised Strategy, to set a new heat target, the purpose of which is to help monitor and track progress in delivering the deployment pathway for reducing emissions in buildings, as set out in the Update to the Climate Change Plan.

The SEA supports the focus of the Strategy on a mixed technology or blended pathway. By focusing on energy efficiency measures and heat technologies ready for deployment now (energy efficiency measures, heat pumps and heat networks) and recognising that hydrogen and bioenergy could play a potential role in the longer term, this can support a flexible approach to delivery of the Strategy’s objectives.

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 strategically important energy efficiency measures for people living in deprived areas and in rural areas where extreme fuel poverty rates are highest.
• 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 mains hydrogen supply in the longer term.
• To obtain maximum environmental benefits a focus could be given to actions that support the co-location of infrastructure associated with deployment of measures and the reuse of existing infrastructure where possible. This approach could help to support the flexible operation of smart energy networks as well as maximise benefits including helping to reduce the need for new infrastructure and electricity network upgrades as well as potential to reduce consumer bills.
• 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.

Monitoring

Section 19 of the Environmental Assessment (Scotland) Act (2005) requires the responsible authority to monitor significant environmental effects of the implementation of the PPS. This should be done in a way to enable them to take appropriate remedial action, where applicable

A wide range of existing programmes have associated monitoring in place at the national level. Building on these existing monitoring arrangements, a monitoring and evaluation framework will also be published alongside the finalised Heat in Buildings Strategy.

It is proposed that monitoring for significant environmental effects is an integral part of this framework.

What Reasonable alternatives have been considered

The 2005 Act requires the Environmental Report to identify, describe and evaluate the likely significant effects on the environmental of reasonable alternatives to a plan, programme, or strategy taking into account its objectives and geographical scope. Doing nothing is not a reasonable alternative because as a new target is now required in order to comply with S61 of the Climate Change (Scotland) Act 2009. The setting of a new heat target for buildings is required to support the delivery and the deployment pathway for reducing emissions in buildings as set out in the Climate Change Plan Update.

The assessment considers, in broad terms, the likely significant effects of the setting of a new heat target which has the delivery of net-zero objectives at its heart, which focuses on heat in buildings, and which is compatible with statutory fuel poverty targets.

We acknowledge that, in setting a new heat target there are differing levels of ambition in delivering net zero objectives. At a minimum the setting of a new heat target would need to support the delivery and the deployment pathway for reducing emissions in buildings as set out in the Climate Change Plan Update. Wherever possible the assessment seeks to draw out the potential for differing environmental effects where a new heat target supports the accelerated delivery of emissions reductions.

In terms of consideration of alternative energy efficiency and heat technology scenarios as a means to deliver a proposed target, it is considered that there are no reasonable alternatives to a mixed or blended technology pathway as the most effective and credible means of achieving our statutory emission reduction targets in the heat in buildings sector. The assessment does however draw out, wherever possible, the potential likely significant environmental effects associated with key strategic energy efficiency measures and heat technologies identified as having a role to play within the energy mix.

Next steps and consultation

Public views and comments are invited on both this Environmental report and the draft Strategy to which it relates. Responses are invited by 30 April 2021. These can be submitted:

• Online using the Scottish Government’s consultation platform, Consultation Hub, at: https://consult.gov.scot/energy-and-climate-change-directorate/heat-in-buildings-strategy/. Consultation Hub allows you to save and return to your responses while the consultation is still open. A copy of your final response will be emailed to you.
• By Email or Post: Responses can be submitted by email, with the Respondent Information Form to heatinbuildings@gov.scot or by post to: Heat Strategy Unit at 5 Atlantic Quay, Glasgow G2 8LU

Following the consultation, a Post-Adoption Statement will be prepared. The Statement will reflect on the views provided on the findings of the assessment and the proposals in the Consultation Paper and will explain how the issues raised have been taken into account in finalising the Strategy.