The Scottish Government published the New Build Heat Standard Consultation: Part II in July 2022, setting out how it intends to regulate to prohibit direct emissions heating (DEH) systems in new buildings from 2024 onwards1. The consultation opened online at 00:01 on 28 July 2022 and closes on 20 October 20221.
Under the proposals, from 1 April 2024 new buildings applying for a building warrant will be prohibited from using direct emissions heating systems to meet their space and hot water heating and cooling demand1. New buildings not served by a heat network must meet their space heating, cooling and hot water demand using systems that produce zero direct greenhouse gas emissions at the point of use1. This applies to both new domestic and non-domestic buildings, as well as the conversion of existing buildings, and to any installed heating system within the curtilage of the building, both main and any other fixed heating system1. The standard will be monitored and enforced through the building warrant process1.
The Scottish Government states the standard will remain technology-agnostic1. Independent research by ClimateXChange found that heat pumps, heat networks, solar thermal and solar thermal storage systems, electric storage heaters, electric boilers, fuel cells and direct electric heaters produce no direct in-building greenhouse emissions from normal operation at point of use, and would therefore be compliant1. Bioenergy systems would not be considered compliant, as the research found combustion of biomass is associated with direct emissions of carbon dioxide, methane and nitrous oxide1. Findings were inconclusive for 100% hydrogen due to a lack of available real-life data1.
The consultation also sets out that the standard will require all new wet heating systems to be designed to operate at lower temperatures, to be compatible with efficient use of non-DEH solutions such as heat pumps and heat networks1. For new buildings after 1 April 2024, an EPC will be required upon completion as is the case now1.
"From 1 April 2024, new buildings applying for a building warrant will be prohibited from using direct emissions heating systems to meet their space and hot water heating and cooling demand."
Why it matters for households
The proposals concern new buildings rather than existing homes, so they do not impose requirements on householders in properties already built. For anyone buying or commissioning a new home in Scotland, the heating system installed will be a zero direct emissions system rather than a gas boiler, which changes the fuel a household uses and the running costs it faces. The consultation notes that over 80% of new build homes completed in the 12 months to the end of 2020 were served by mains gas fired boilers as their main heating system, with a further 3% using heating oil and LPG, and only around 10% served by non-DEH systems2. The Scottish Government states that direct emissions from buildings account for almost 20% of Scotland's total greenhouse gas emissions2.
For a home's energy independence, the shift means new properties will rely on electricity or a heat network rather than a fuel burned on site. The consultation states that indirect or upstream emissions from purchased thermal or electrical energy, including heat from grid electricity or delivered via a heat network, are considered out of scope2. The standard is enforced through the building warrant system, which is already familiar to developers1. The consultation also notes that only around half of people in Scotland have heard of key non-DEH systems such as heat pumps1.
What happens next
The consultation closes on 20 October 20221. Consultation workshops are scheduled for autumn 20221. Amended standards for new buildings, applying to all building warrants applied for on or after 1 December 2022, were published in June 2022 and come into force on that date, introducing improved fabric measures for new buildings with the continued use of direct emissions heating allowed1. The Scottish Government aims to pass new build standard regulations through Parliament in spring 20231. The first Local Heat and Energy Efficiency Strategies (LHEES) are due to be finalised by the end of 20231. A dedicated National Public Energy Agency is committed to be established by 2025, with an in-house virtual Agency to be established by September 20221. A Heat in Buildings Public Engagement Strategy is to be published in early 20231.