New Build Heat Standard: consultation - part two

Introduction

Background

The Scottish Government is legally committed to meeting the targets set out within the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. This includes reducing emissions by 75% by 2030 and reaching net zero by 2045.

We are facing a global climate emergency, and the recent United Nations Climate Change Conference (COP26) in Glasgow provided a strong message to governments: that they must accelerate their heat decarbonisation plans (as part of a wider effort) to reduce emissions before the window of opportunity for change closes.

As the First Minister set out earlier this year at the annual All-Energy Conference in Glasgow, we must not lose sight of the underlying importance – and urgency – of the climate change emergency as the key driver for our just transition towards a decarbonised energy system.

With Scotland's buildings accounting for approximately 20% of our total greenhouse gas emissions, both the Heat in Buildings Strategy^[5] and the 2020-21 New Build Heat Standard (NBHS) Scoping Consultation (NBHS Consultation: Part I) emphasised the urgent need to tackle the emissions associated with our buildings to ensure Scotland achieves our climate change targets.

To help achieve this, the Scottish Government is proposing to prohibit the use of direct emissions heating systems (DEH) in any new building applying for a building warrant from 1 April 2024 onwards.

Following the Programme for Government (PfG) commitment in 2019-20^[6] to decarbonise Scotland's new buildings, many forerunner housing associations and developers have already embraced the shift away from DEH systems, and are now delivering buildings served by zero direct emissions heating (ZDEH) systems across the country.

As set out within NBHS Consultation: Part I, taking action on new buildings now will not only help Scotland achieve our statutory climate change targets, but it will also help to prevent the need for retrofit (post-2024) as all buildings – eventually - transition away from DEH systems.

Purpose

The NBHS Consultation: Part I set out our intention to develop regulations which would require new homes and non-domestic buildings – as well as conversions to existing buildings – consented from 2024 onwards to meet their space and hot water heating/cooling demand through systems which produce no direct greenhouse gas emissions at point of use.

The Part I consultation was a high-level precursor to this consultation document: it was an opportunity for the Scottish Government to make clear our ambitions and to give industry, developers, local authorities, housing associations, and other affected groups a strong signal of what to expect ahead of 2024.

Independent analysis of the responses received to the NBHS Consultation: Part I found them to be predominately supportive of the Scottish Government's intention to regulate the direct greenhouse gas emissions associated with heating and cooling new buildings.^[7]

The NBHS proposals have continued to evolve, based on feedback received from the NBHS Consultation: Part I, engagement with stakeholders (both formally – as part of our external working group and online workshops – and informally), through evidence-gathering exercises and independent research, altogether reflecting the wider-evolving policy context for Heat in Buildings in Scotland and beyond.

Building on this work and ahead of laying regulations in Parliament in 2023 – to come into force on 1 April 2024 – the Scottish Government is now undertaking NBHS Consultation: Part II, as committed to within the Part I consultation.

This is a further opportunity for stakeholders to input into the final development of the NBHS, and this consultation sets out how we intend to regulate to prohibit the use of DEH systems in new domestic and non-domestic buildings applying for a building warrant from 1 April 2024 onwards.

This paper also provides a concise summary response to NBHS Consultation: Part I, outlining the key actions the Scottish Government has taken to date, and what actions we plan to take to ensure the transition to ZDEH in new buildings is one which is fair, just, and leaves no one – or any business – behind.

Approach to Public Engagement

Regulations – such as those set out in this consultation – form a central part of the net zero heating pathway. However, recent research at a UK-level shows that levels of general understanding of the link between DEH systems (in this example, gas central heating) and climate change is only around 50%;^[8] and that, in Scotland, only around half of people have heard of key non-DEH systems, such as heat pumps.^[9]

This evidence highlights that proposed regulations must be accompanied by significant awareness raising, to ensure that the public understand why the heat transition – and levers such as the NBHS – are necessary, and what this may mean for them.

That is why, as committed to within our Heat in Buildings Strategy, work is now underway to develop a new Heat in Buildings Public Engagement Strategy, to be published in early 2023. This strategy will build on the principles set out in our broader approach to public engagement on climate change that we published last year.

Key to the Pubic Engagement Strategy will be:

• increasing understanding of the changes we need to see in how we heat our homes and buildings, and why;
• raising the profile of energy efficiency and zero direct emissions heating options so that people are aware of the benefits and begin to see them as a positive choice for them; and
• raising awareness of the support and advisory services available to maximise uptake of the support available.

We will use the strategy to set out a framework for public engagement, including public participation in policy and support programme design, ensuring the needs of different (domestic and non-domestic) groups are considered. This reflects our commitment to supporting a just and fair transition.

Following the analysis of responses received to the NBHS Consultation: Part I, we recognise that there is a need for leadership and co-ordination to support the acceleration of heat decarbonisation in Scotland. This is why we have committed to establishing a dedicated National Public Energy Agency by 2025 to provide this role, with an in-house virtual Agency to be established by September 2022.

As part of the work of the virtual Agency, this year, we will launch a national conversation and campaign on the transformational change in how we heat and use energy in our homes and buildings.

Working with partner organisations, we will use these complementary activities to increase awareness of the heat transition with different consumer groups, building readiness for change amongst a wide cross-section of society ahead of the introduction of proposed regulations set out as part of our Heat in Buildings Strategy (the NBHS being one part of this regulatory package).

Chapter Summary

1. Chapter 1: provides a timeline of key dates for NBHS between now and 2024.

2. Chapter 2: sets out proposals for regulating direct emissions heating and cooling within new homes, and how this will be achieved in practice.

3. Chapter 3: a summary of the key considerations for regulating heat within new commercial and non-domestic buildings.

4. Chapter 4: an overview of the Scottish Government's response to key issues raised by NBHS Consultation: Part I.