New Build Heat Standard - scoping consultation: analysis

Key outcomes

Question 1

11. The consultation document outlined nine key outcomes supported by transitioning to zero direct emissions heating systems, from 2024, in new buildings. These were informed by, and will contribute towards, the wider outcomes for heat in buildings, in the Heat in Buildings Strategy for Scotland. Question 1 asked,

Q1: 'Do you agree with the above key outcomes? Please explain your view'

12. As shown in table 2, of the respondents who gave a definitive response, almost all agreed with the key outcomes (72 agreed while only 1 disagreed).

Table 2: Q1

Number
	Yes	No	Not answered
Architect / Architect trade body (4)	2	-	2
Energy sector (12)	11	-	1
Housing association (4)	4	-	-
Housing developer (3)	2	-	1
Local authority (14)	11	1	2
Manufacturer (10)	9	-	1
NGO (7)	5	-	2
Public sector (3)	2	-	1
Trade Body - Energy (12)	10	-	2
Trade Body – Housing (7)	5	-	2
Other (7)	6	-	1
Total organisations (83)	67	1	15
Individual (9)	5	-	4
Total respondents (92)	72	1	19

13. Respondents were then invited to provide additional commentary in support of their initial response; and 83 opted to do so. To a large extent, comments echoed the issues outlined in the consultation paper. The following paragraphs outline the key themes emerging in response to this question.

14. Many respondents, across all sub-groups, simply noted their agreement with each of the nine outcomes. Some respondents opted to provide general comments across all the nine outcomes, which others provided comments on some of the specific outcomes. The following paragraphs provide a brief summary of the key themes emerging for each outcome.

Outcome 1: Our new buildings no longer contribute to climate change

15. While most of those who commented on this outcome supported it, a number of concerns were outlined by these respondents. The key concern related to the need for a fabric first approach; points were made that the embodied carbon of a building can account for up to 75% of total emissions over a 60 year period or that net zero emissions do not allow for a holistic approach to new homes.

16. Other comments, each made by small numbers of respondents, included:

• Zero emissions at source may be restrictive.
• There will be a need to consider the optimal orientation of buildings and window placement for energy efficiency; a focus on air tightness will lead to mechanical ventilation which will require electric power.
• The outcome overestimates what the Standard can achieve; there is a need for a more realistic assessment as the Standard will not reduce emissions to the expected extent.

17. There were a few suggestions for changes to the wording of this outcome, and these included,

• Amend this to emphasise a fabric first approach; for example, 'In addition to fabric first approaches, the use of zero direct emissions heating systems …'.
• The wording needs to be more precise, for example, 'Our new building when in use no longer …'.

Outcome 2: Reduced demand for heating and cooling

18. Once again, a few respondents noted their support for a fabric first approach as this would help to reduce fuel poverty, reduce exposure to volatile energy prices and reduce energy demand. Linked to this, there were a small number of comments on the need for a Passivhaus approach.

19. Other comments made by small numbers of respondents included the need,

• To include appropriate ventilation systems (other respondents).
• For the approach to be technology agnostic (manufacturer; Trade Body (Energy)).
• To include outcome measures to address any performance gap, for example to have a Post Occupancy Evaluation (POE) of any new system (Trade Body (Housing); Individual).
• To offer support and awareness-raising to consumers, particularly as there is an allied need for behavioural change (others).
• To refer to domestic hot water as this is likely to be the largest energy use in new build homes. A public sector organisation commented that there is a need to introduce greater water efficiency measures to support this outcome by improving the efficiency of hot water use and thereby reducing household energy demand and energy bills; other measures referred to also included water reuse technologies and a mandatory water label for all water-using products linked to building and manufacturing standards (manufacturer; Trade Body (Energy)).

Outcome 3: The cost of heating our new homes and non-residential buildings is affordable

20. The key theme emerging in response to this specific outcome – albeit only mentioned by a few respondents – related to concerns over the cost of electricity compared to gas; and some requests to address the cost of electricity, particularly as this needs to be viewed in the context of fuel poverty and Scotland's targets for fuel poverty.

21. Allied to this, there were a small number of calls to align lower energy costs with a review of energy providers' tariffs to reduce fuel poverty.

22. Other points raised by small numbers of respondents included the need,

• To consider regional differences, for example, between rural and urban areas.
• For a fabric first approach.
• To align across different policy areas, for example, with the Scottish Government's final Fuel Poverty Strategy.
• To address the refurbishment of existing buildings as a priority to reduce fuel poverty.
• To introduce greater water efficiency measures by improving the efficiency of hot water use and thereby reducing household energy demand and energy bills.
• For a good understanding of technologies being specified and / or installed, for example, to understand the limitations some technologies may have or the geographic areas to which they are best suited.
• To adopt a Passivhaus approach.

23. A small number of respondents highlighted amendments they would like to see to the text of the outcome. These included,

• Specific reference to rural energy consumers.
• Reference to the recognition of water use efficiency along the lines of 'high energy costs are a challenge for many households and, for many of our businesses and public services, energy and water inefficiency and high energy bills add unnecessary financial burdens'.
• Reword to 'The cost of heating our new homes and non-residential buildings is affordable and does not contribute to fuel poverty'.

Outcome 4: The systems we use in new buildings provide us with a reliable supply of heat

24. The two key themes emerging in response to this outcome were of a need for reliability of supply and a suitably robust supply chain; and the need for training, retraining and upskilling so as to ensure there is a skilled workforce.

25. There were also a few references to the need for regulation of installations and long term warranty schemes.

26. A small number of respondents felt there is a need for a diversified use of energy technologies so as to reduce reliance on a single technology and help to build resilience in communities.

27. One respondent suggested a change in the wording of this outcome to 'The systems we use in new buildings provide us with an adequate and reliable supply of heating, cooling and ventilation'.

Outcome 5: Opportunities for retraining and upskilling of workforce across Scotland

28. Three key themes emerged in response to this specific outcome, although each was only cited by a few respondents. These were,

• The need to encourage entrants to the sector and offer training opportunities such as apprenticeships to new entrants.
• The need to invest in provision of greatly increased training capacity.
• To include relevant trade bodies, key industry groups, professional organisations and supply chains. This point was made primarily by local authorities.

29. One respondent in the energy sector suggested the wording of the outcome needs to include reference to 'the creation of supply chains, business and employment opportunities which decarbonise heat'; and a private sector organisation felt the narrative should change from 'job losses' to 'job opportunities'.

Outcome 6: Informed, educated consumers

30. The key theme emerging in relation to this outcome was agreement of the need to inform and educate consumers in order to address consumer uncertainty, with some comments that this will be an important factor in achieving the predicted carbon reduction. Allied to this, there were some comments that consumers need to understand that they need to use zero direct emission heating systems differently from fossil fuel heating systems and will require access to advice and information on how to keep their homes warm while keeping bills as low as possible. There were a small number of comments that this will require a huge effort in a small timescale, given the need not only to educate consumers but also to bring about behavioural change.

31. Some respondents commented that in order to bring about informed, educated consumers, there is a need for the Scottish Government to run public-facing awareness campaigns about new green homes and the role of different technologies. In addition, consumers will need assurances about the reliability of alternative heat sources.

32. While most respondents focused on consumers, a small number also cited the need to educate others involved in the industry and these included valuers, mortgage lenders, surveyors and those working in other trade professions.

33. Two respondents highlighted amendments to this outcome. These were the inclusion of 'reassured' in the outcome, and an additional bullet point to highlight that consumers need to know how to use their heating systems effectively.

Outcome 7: Our indoor and outdoor spaces are filled with cleaner air

34. The key comment emerging for this outcome – albeit only cited by a few respondents – was of a need to take a holistic view of the whole building and adopt a fabric first approach. Once again, there were a few references to the need for Passivhaus metrics for energy efficiency to be mandated as this would ensure adequate levels of insulation, minimisation of heat loss and maintain good fresh air ventilation via low input heat.

35. Allied to this, the issue of ventilation was raised by a few respondents who noted that the outcome needs to be revised to reflect the impact of Covid19 on ventilation practices and that there will need to be guidance on how to manage and adapt ventilation systems and user behaviour in air-tight buildings.

36. There were a small number of requests to reword this outcome to more accurately reflect the potential opportunity the Standard has to further improve indoor and outdoor air quality specifically within the context of new build homes.

Outcome 8: Our heating systems are smart, enabling the flexible and stable operation of our energy networks

37. While there was broad support for this outcome, respondents outlined a number of concerns. The key concern, although only mentioned by a few respondents, was that smart heat needs to be understood and delivered in the context of a whole system review; with a whole building approach so that heating demand and controls are not considered in isolation.

38. There were also a few suggestions of a need for flexibility across all policy initiatives so they are agile enough to respond to more rapidly changing external forces, such as changes to primary energy costs.

39. Similarly, there were a small number of comments that heating systems will need to be flexible to keep up with technological changes; for example, as the National Grid increases its capacity for renewable energy, it is important that heating systems can mirror this change and are flexible to keep up with these changes.

40. There were a small number of references to the need for financial incentives and grant support for homeowners so they optimise energy use through smart tariffs, energy and heat storage and smart home appliances.

41. A similar number of respondents made suggestions to offer training to consumers on how to operate smart heating systems; this, in turn, would help to bring about the necessary consumer behaviour change to meet this outcome.

42. There were also a small number of references to the need for shared responsibilities across wider stakeholders and network delivery partners to enable the integration of technologies on their networks, along with Scottish Government collaboration with all stakeholders to achieve this outcome.

43. One amendment was suggested for the wording of this outcome; 'Our heating and cooling and ventilation systems are smart, enabling the flexible and stable operation of our energy network'.

Outcome 9: There is a continued supply of high quality homes and non-residential buildings in line with requirements

44. Most comments made in relation to this specific outcome simply agreed with the need for a continued supply of high quality homes. Once again, a few other points were raised by respondents and these included a need for,

• A fabric first / holistic approach to new homes.
• The Scottish Government to support the sector directly to help support the delivery of housing as per this outcome.
• A move to Passivhaus to ensure this outcome is met.

45. In relation to specific amendments to this outcome wording, there was a request for this to read 'There is a continued supply of high-quality and truly affordable homes and non-residential buildings which are in line with identified requirements'. There was also a request to reference water efficiency in the second bullet point to read 'Measures to reduce the demand for heat and hot water in new homes are essential for meeting this objective, helping to ensure that new homes are more affordable to heat'.

General comments across all nine outcomes

46. As noted earlier, some respondents provided general comments that were relevant to all nine outcomes. These included the need for a fabric first approach and comments that the key outcomes are in line with improvements that are needed for new build housing; that these are appropriate and achieve a balance between national targets and the limitations of the construction industry.

47. However, there were some concerns raised by respondents. A key concern was geographic differences between city and urban and rural areas; for example that district heating systems rely on large scale developments to make them economically viable for consumers, or that developers may not have access to particular heating technologies in all areas.

48. Views from a workshop held among island respondents included the need to offer a range of technologies such that the most economically viable can be used. There was also a perception of a lack of capacity on the islands and a lack of willingness for some existing tradespeople to adapt their existing skillset to meet the demands of this Standard. Allied to this, there were some suggestions that there might be a lack of quality control over technologies being installed on island communities.

49. There were a number of concerns over costs and the need to avoid fuel poverty; for example, there could be high costs of energy generation, upgrading the power network, increased use of electricity as a heating source could prove much more expensive to consumers who are used to using gas as their primary heating source. There were a small number of comments that changes to heating systems should not introduce additional costs for homeowners.

50. There were a few references to the need for a technology agnostic approach and for consideration to a range of different technologies which make use of all available forms of renewables.

51. The importance of collaboration was highlighted, across all stakeholders within the sector.

52. There were also a small number of perceptions from local authorities that the proposed timescale is challenging.

Question 2

53. Question 2 of the consultation paper then asked,

Q2: 'Are there any additional outcomes which should be embedded here?'

54. A total of 57 respondents, across all sub-groups, opted to answer this question. Some of these respondents provided additional outcomes they felt were necessary, while some others commented on other aspects of the proposed Standard.

55. A key comment was of a need for the Standard to remain flexible, be technologically agnostic and make use of all technologies – both existing and emerging. A few of these respondents referred to specific technologies they felt should be included in the mix and these included hydrogen boilers, wood pellet heating systems in rural areas and solar thermal energy.

56. Once again, there were some references to the need to consider the differences between rural and urban areas, with concerns that building homes in small schemes in rural areas could be unaffordable for many people. Linked to this, there were some references to the need to ensure that the Standard does not lead to increased levels of fuel poverty.

57. There were some suggestions for monitoring of buildings, the heating systems they use and the levels of energy used by each, so that developers adhere to the Standard. Alongside this, there were a small number of requests for independent verification and sign off of all new build housing.

58. Additional outcomes suggested by respondents included references to,

• The economy and economic development; Scotland maintains a successful and diverse property industry that is able to build and deliver the homes and workspaces of the future.
• Emissions; Improvements on cost efficiency measures; Design of new build homes should support low demand for heating; include a fabric first approach; Building Standards should consider the total energy use of a property; The embodied carbon emissions generated by the manufacture of energy systems should not be greater than the potential operational emissions they can save; Inclusivity of access to zero emissions; All new build housing should have an EPC rating of B or C; Mitigation and prevention of overheating.
• Buildings; New build housing should complement the character of the existing area; Encourage the reuse of existing structures where possible.
• Creating a sufficient infrastructure across all partners.
• Communities and the consumer; Consumers need to use heating systems effectively; communities should be empowered; the promotion of health and wellbeing.
• The systems installed; No heating system should cost more to run than the present benchmark (mains gas); Requirements for POE for all installations; Consider the whole life of heat systems selected, to consider the running costs and carbon savings over the lifetime and the capital cost of installing heating systems; The demands of electric heating should not overburden grid connections and efforts to decarbonise electricity generation.