New Build Heat Standard (amended) 2024: island communities impact assessment

6. Evidence and Feedback from stakeholder engagement

6.1. We have collated the feedback and evidence received from: discussions at the workshops; presentations at the roundtable and, information submitted in writing. This is set out below and covers a range of themes including (not in any order): electricity grid constraints; fuel availability and alternatives; skills; fuel poverty; island depopulation; air quality, and peat.

Electricity Grid – resilience and capacity

6.2. Stakeholders were of the view that, in general, rural and island areas remain more susceptible to electrical power cuts than mainland Scotland, with some islands experiencing significant blackouts over recent years. In addition to this, off grid islands, such as Fair Isle, Isle of Rum and Isle of Eigg, do not currently have sufficient electrical capacity for each home to switch entirely to ‘clean’ heating systems such as heat pumps which run on electricity. Stakeholders stated that Eigg’s off-grid system needs all homes to use an average of less than 1kW at any one time to ensure there is enough power for everyone. Putting this into context, an Air Source Heat Pump^[3] (ASHP) for a 3-bed 100 square metre well-insulated house will require 5kW of power.

6.3. A study^[4] looking at remote off-grid energy infrastructure found that although all mini-grids meet current demand, some had power limits installed on properties (Rum, Muck, Eigg). While some have excess capacity for future demand, which is currently unutilised (Canna, Fair Isle, Knoydart) some have limited capacity (Rum and Foula) with no additional capacity on Eigg. The study highlighted that the following appliances were noted in consumer surveys as desired but unable to be currently powered: electric shower, car charging, electric heating, freezer, tumble dryer, electric kettle, and toaster. In the surveys, some indicated that they have to be mindful of electricity use and not switch everything on at once.

6.4. Stakeholders mentioned that, on Fair Isle, any additional electric heating will need to be powered through backup diesel generators which are more polluting than oil boilers and especially wood burners or other bioenergy systems.

6.5. Furthermore, whilst Orkney is a leading renewable generation hub, even there, community feedback indicates that strategic and system-wide work needs to be done to improve the electricity grid and its resilience.

6.6. Stakeholders felt that to improve resilience there is a role for both individual combustion appliances (e.g. a wood burning stove) as a secondary heating system or as a main heating system on some of the islands, particularly ones with sustainable local supply of wood fuel.

Fuel Availability and Alternatives

6.7. Many rural and island areas are off the gas grid and have a long-standing history of limited alternative options for heating compared to mainland Scotland, particularly the smaller islands^[5].

6.8. Comments from the workshops suggested that island areas are more likely to have a sustainable supply of wood fuel which will come from sustainably managed forestry, such as on the Isle of Rum. Some island communities also may have access to waste products from the timber industry and wood fall which can contribute to the circular economy as these resources can be reused and repurposed rather than discarded. Restricting the use of locally sourced sustainable wood could have a significant impact on local wood fuel markets. For example, the wood fuel business supports two jobs as part of a circular economy on the Isle of Eigg, which includes a third job growing trees from native seed in Eigg’s tree nursery for replanting and off-island sales. This is significant within a relatively small community of approximately 110 people. The 70ha of harvestable Sitka Spruce, monoculture, planted as a crop in the 1970s, is at terminal height and needs to be harvested to fulfil Eigg’s Long Term Forest Plan^[6]. If this wood fuel cannot be used locally it will be exported and burnt as fuel elsewhere.

6.9. Stakeholders stated that wood supply doesn’t rely on ferries or weather and could be clean, affordable and accessible for residents. It is an essential winter backup for when current oil or electric supplies fail and will also be applicable in new buildings.

Skills and costs

6.10. Workshop attendees highlighted the lower relative number of clean heat engineers available to them. This is backed up by recent research^[7] which found that the remote nature of the islands can make it more difficult to access skilled people to install and maintain heating systems. That same research highlighted that the unreliability of ferries can add to costs as well as increase waiting times to obtain parts for systems requiring repair. Workshop attendees reported that the Isle of Eigg has four ferries a week in winter and six in summer, allowing only a few hours on the island. This makes maintenance difficult and very expensive as it often involves an overnight stay. Similar cost issues were also observed on other islands such as the Isle of Rum.

6.11. Stakeholders highlighted that Orkney has a higher uptake of heat pumps with 3,500 installed out of a total of 11,000 properties on the islands (similar to figures in the ICIA for the NBHS^[8]). Whilst the local workforce are skilled for the initial install of the heat pumps, there has been difficulty getting these repaired and wood burning stoves have been used as a back-up in many cases (as well as gas bottle heaters).

6.12. Stakeholders were of the opinion that while wood stoves do require maintenance the skills required to do this could be learned more easily.

Fuel Poverty

6.13. Scottish island residents are generally more likely to face fuel poverty than the average Scottish resident. Rates of fuel poverty are generally higher in the Island Local Authorities with around a third of residents experiencing fuel poverty in Argyll and Bute (32%), Highland (33%), Orkney Islands (31%) and Shetland Islands (31%) councils and as many as 40% in Na h-Eileanan Siar, while the average for Scotland is 24%^[9]. Fuel Poverty is more common amongst those with electric heating^[10] and stakeholders views were that supplementary heat from a wood burning stove, which is more affordable, can help reduce costs. For example, islanders can often purchase several months’ worth of wood or peat for a fixed fee which can protect them against fluctuating electricity prices. On the Isle of Eigg the unit price of electricity was reported by community members as currently around 20% higher than the UK average. This price is not set by the UK Government but by the operator of the mini-grid and covers the cost of the ongoing system maintenance.

6.14. Stakeholders mentioned that discussions with a number of Orkney residents had highlighted that the cost of electricity was a concern and therefore wood burning stoves and oil heaters were being used more.

Island Depopulation

6.15. Workshop attendees called for key priorities in the islands to focus on the survival and sustainability of the local community with depopulation being a central concern which requires a long-term programme of work to address^[11].

6.16. Stakeholders consider that the NBHS makes it difficult, or in Eigg’s case impossible, to progress with new house building. A proportion of the population live in unsuitable housing and they have been trying to build new homes for affordable rent for six years. The NBHS as introduced in April would mean no new private or community-led house building would be possible on Eigg in the foreseeable future unless this was done via applying for a dispensation of the Standard^[12] as no clean heating systems are compatible with Eigg Electric’s generation and distribution capacity.

6.17. The Isle of Coll has been declared as a housing emergency zone and would face similar issues. There is no community managed housing on Coll and stakeholders were concerned that a one size fits all approach would not meet the unique needs of each of the islands. They highlighted the need to focus on having viable populations, and additional costs makes this challenging.

6.18. Woodland crofts and other island communities are aiming to be self-sufficient, which is a key reason why people choose to live there – therefore allowing the use of bioenergy for heat is important.

Air Quality

6.19. Stakeholders did not view air quality as a significant issue for more rural parts of islands due to the lower density of housing compared to urban areas.

6.20. All local authorities are required to produce an annual report on air quality in their areas, which are then published by Scottish Government. These reports^[13] confirm that there have never been any exceedances of statutory air quality objectives in island authorities.

6.21. Regulations on energy related products including solid fuel boilers and heaters (i.e. stoves) already require them to be ‘Eco-design’ which means that they “make the lowest possible environmental impact throughout the product’s lifecycle.”^[14] It should be noted that policy decisions in relation to product standards are reserved to the UK Government.

6.22. The renewable liquid gases and liquid fuels industries are actively working on innovative approaches and demonstrations for the roll out of these renewable fuels to support carbon reduction targets. In their response to our Heat in Buildings consultation (which explored proposals for decarbonising heat in existing homes) Liquid Gas UK^[15] stated that “BioLPG, alternatively known as biopropane, is a versatile, ‘drop-in’ renewable solution which can provide up to 90% carbon emissions reduction compared to fossil-based LPG.” Likewise, in their response, UKIFDA and OFTEC^[16] stated that “Hydrotreated Vegetable Oil (HVO) in pure form and derived from a waste feedstock such as used cooking oil (UCO) reduces carbon emissions by up to 88% compared to kerosene.”

Peat

6.23. There is a strong cultural significance of peat on the islands. Respondents to the Scottish Government’s consultation^[17] on ‘Ending the Sale of Peat in Scotland’ highlighted that cutting and using peat for fuel in the Highlands and Islands was part of a “long-standing tradition” and “as per our custom and culture”. In addition to cultural preservation the practice was considered integral to some people’s lives, e.g. as an affordable fuel source.

6.24. On some islands peat is available where there are no woodlands, and wood fuel would have to be imported causing increased emissions. Stakeholders were of the view that guidelines on how to cut peat in a sustainable manner would be welcomed as they recognised the impact this could have.

6.25. Under The Crofters (Scotland) Act 1993^[18], crofters have the right to harvest peat within their crofting tenure (section 17, point 6). This right is essential for many crofters, particularly those in remote and island locations where access to alternative fuel sources is limited and often expensive.