New Build Heat Standard 2024: equality impact assessment

Screening

Policy Aim

The aim of the New Build Heat Standard (NBHS) is to prohibit the use of direct emissions heating systems (DEH) in new buildings applying for a building warrant from 1 April 2024 onwards. This requirement will also apply to specific types of conversions (however, only in certain circumstances).

It is expected that the following 4 key outcomes will be delivered through the introduction of the NBHS:

1. Our new buildings no longer contribute to climate change;

2. The systems we use to heat our buildings provide us with a reliable supply of heat;

3. Opportunities for retraining and upskilling of workforce across Scotland; and

4. Our indoor and outdoor spaces are with cleaner air.

The introduction of the NBHS aligns with the National Performance Framework, meeting three of the National Outcomes:

• We value, enjoy, protect and enhance our environment;
• We have a globally competitive, entrepreneurial, inclusive and sustainable economy; and
• We have thriving and innovative businesses, with quality jobs and fair work for everyone.

Directly applicable National Indicators, which measure progress to delivering Scotland’s National Outcomes are:

• Reduce Greenhouse Gas Emissions:
• Improve Scotland’s reputation;
• Improve people’s perceptions of their neighbourhood; and
• Reduce Scotland’s carbon footprint.

Who will it affect?

The policy will directly affect developers (both domestic and non-domestic), manufacturers, installers and the wider heating supply chain.

In addition, the policy will directly impact people purchasing new homes, and will indirectly affect those either living in or using new buildings – as well as those undertaking conversions of existing buildings (however, this is only where certain criteria are met).

What might prevent the desired outcomes being achieved?

Two public consultations on the NBHS have taken place, and responses received to these have highlighted the following key areas of concern relating to the successful delivery of the NBHS (particularly around the achievement of Scottish new build housing targets):

1. Supply chain capacity - A competent and skilled workforce is crucial.

In an effort to support this, in November 2022, Scottish Government published the Heat in Buildings Supply Chains Delivery Plan^[1]. This plan sets out the steps that the Scottish Government will take to support the growth of the green heat sector to ensure the right people, skills and technology are in place.

2. Energy network capacity – the transition to zero direct emissions heating systems (such as heat pumps), will require sufficient grid capacity to accommodate this additional demand.

There have been a number of recent, positive steps at a UK-level in this regard:

• Ofgem’s RIIO-ED2 determination has confirmed allowed expenditure of £2.7 billion for the distribution network companies in Scotland and, in addition, ‘uncertainty mechanisms’ are available to support the distribution network operators to invest (should demand be greater than anticipated); and
• From April 2023, demand connections (at a distribution level) will no longer have to pay for the reinforcement elements of the cost of connection.

In developing this policy the Scottish Government is mindful of the three needs of the Public Sector Equality Duty (PSED) - eliminate unlawful discrimination, harassment and victimisation, advance equality of opportunity between people who share a protected characteristic and those who do not, and foster good relations between people who share a protected characteristic and those who do not. The purpose of this assessment is to mitigate and/ or eliminate any negative impacts identified. We are also mindful that the equality duty is not just about negating or mitigating negative impacts, as we also have a positive duty to promote equality.

Specifically, this EQIA assesses any impacts of applying a proposed new or revised policy or practice against the needs relevant to a public authority’s duty to meet the public sector equality duty.

As set out within this document, we have not identified any impacts on any of the protected characteristics listed in the Equality Act 2010.

In terms of equality considerations, it is also important to highlight that the Scottish Government does not solely hold the only levers which would affect who can access a home or the volume of new buildings delivered per annum (as, for example, this could be driven by other market factors).