New Build Heat Standard - scoping consultation: analysis

Executive Summary

Scotland has one of the most ambitious climate targets in the world, with its Climate Change Bill^[1] setting out a legally binding target of reaching net-zero emissions by 2045, and with an interim statutory reduction of 75% by 2030.

Given that homes and workplaces account for around 21%^[2] of Scotland's total greenhouse gas emissions, it is important to reduce emissions from homes and buildings so they are warmer, greener and energy efficient. To achieve the required levels of energy efficiency, Scotland (and the rest of the UK) will need to adopt zero carbon heating technologies throughout the building stock.

One element which will also contribute to Scotland's climate change targets by reducing emissions from heating systems would be to ensure that all new build homes have heating systems that produce zero direct greenhouse gas emissions. In December 2020, the Scottish Government published a scoping consultation seeking views on a proposed New Build Heat Standard (NBHS)^[3], which would mean that all new build homes given consent from 2024 must have a heating system that produces zero direct greenhouse gas emissions at the point of use.

The scoping consultation closed at the beginning of March 2021 and received a total of 92 responses. Four consultation workshops were also held with key stakeholders (Business/ Industry, Consumers, Island Communities and Non-Domestic Buildings) during the consultation period.

Respondent Profile

In total, there were 92 responses to the consultation, of which 83 were from organisations and 9 from individuals.

Key Themes

A number of key themes were evident across questions as well as across respondent groups, although each was mentioned by a minority of respondents, and these are summarised below.

• There was general support for the proposals within the scoping consultation, albeit that many respondents look forward to receiving more detail within the follow-up Technical Consultation.
• There were many calls to adopt a whole building, fabric first approach, so as to take into account all factors that can lead to emissions. This approach would also allow for consideration of the embodied carbon of a building.
• Allied to this, there were some requests for the NBHS to align with low carbon rather than zero emissions as this would allow for a range of technologies to be used to meet the demands of different building types.
• There were suggestions for a technology agnostic approach which would allow for a range of different technologies to be considered in order to meet different needs. Often cited in relation to this point were differences between rural and remote areas and cities and urban areas; with the former often cited as not being suitable for district heating systems which rely on large scale developments to make them economically viable for consumers.
• Concerns were noted over the likely additional demand on the electrical network and a lack of grid capacity to deal with the changes in heating systems being proposed. Allied to this there were concerns over the cost of changes that would be needed for the grid infrastructure.
• The need for a robust supply chain was cited, with some concerns that the current supply chain does not have the capacity to manufacture and install heat pumps in high volumes.
• Allied to the need for a robust supply chain, there were also a number of references to the need for education, training and upskilling of the existing workforce in order to meet the requirements of the Standard.
• There were some queries over operational issues, the lifespan of appliances and perceived high maintenance costs. These issues tied in with concerns over increased costs to consumers and increased levels of fuel poverty.
• As well as training for the workforce, increased consumer awareness was identified as a key issue, so that they understand proposed changes in heating systems and how these will impact on them. Ultimately, there is a perception that this change is likely to bring about reduced choice for consumers, which is very different to the present position. As such, awareness among consumers – and a positive attitude towards the changes being proposed – is seen as being imperative in bringing about behavioural change.
• The need to provide consumers with education and training on new technologies, how to operate these and how to achieve maximum efficiency was also mooted by respondents. Technologies to meet the Standard are perceived to be very different to existing technologies currently in use, and more difficult to understand and operate.
• Collaboration between all key stakeholders across the industry was cited as being important in order to ensure a smooth transition, with some respondents perceiving that the Scottish Government should be taking the lead on this.
• There were references to a need for financial incentives for both the industry and consumers, in order to ensure a robust supply chain, a skilled workforce and take-up of new technologies.
• There was a perception that some form of certification or quality assurance scheme would be beneficial, along with monitoring and evaluation for compliance with the Standard.
• Views were split on the Scottish Government's proposal to introduce this Standard in 2024, and on being brought into force for new buildings consented earlier than 2024; with requests for clear tailored guidance for various types of non-domestic builds.
• There were also requests for guidance to be provided in order to provide clarity on the Standard; along with a roadmap setting out clear timescales and targets.
• Finally, there were requests for this Standard to align with other policy areas, for example, with the Scottish Government's final Fuel Poverty Strategy or the Heat in Buildings Strategy; as well as ensuring timescales are aligned.

Appendix 2 provides a summary of the key themes emerging at each consultation question.