The public consultation on Scotland's New Build Heat Standard ran between 28 July and 20 October 2022, according to the Scottish Government's analysis of the responses1. In total, 112 consultation responses were received from 21 individuals and 91 organisations1. The consultation contained six closed and eight open questions, and 89% of respondents granted permission for publication of their responses1.
The proposed standard would prohibit the use of direct emissions heating (DEH) systems in new buildings and some conversions warranted from April 20241. Using its power under the Buildings (Scotland) Act 2003, the Scottish Government intends to prohibit DEH systems being installed in new domestic buildings warranted from 1 April 20241. The Building (Scotland) Amendment Regulations 2022 defined a DEH system as a system by which the building is heated or is cooled, or by which hot water is made available1.
Three fifths (62%) of those answering Q1 agreed with the proposed approach to regulate DEH systems in new buildings; three in ten (30%) disagreed and 7% were unsure1. Agreement was higher among organisations than individuals, at 66% compared to 52%1. All local authorities (100%) agreed, as did 80% of manufacturers and suppliers in the energy sector1. Views among trade bodies in the energy sector were more mixed: half (50%) agreed, while 25% disagreed and 25% were unsure1. Among property developers and builders, however, 63% disagreed with the proposed approach, with 38% agreeing1.
The analysis sets out the make-up of the organisational responses:
| Sector | Responses | Share |
|---|---|---|
| Property developer or builder | 34 | 30% |
| Energy, trade body | 15 | 13% |
| Local Authority | 12 | 11% |
| Energy, manufacturer or supplier | 11 | 10% |
| Construction related trade or membership body | 10 | 9% |
| NGO or third sector | 6 | 5% |
| Public body | 1 | 1% |
| Other | 2 | 2% |
| Individuals | 21 | 19% |
Within the property developer or builder category, 23 responses were received as part of a co-ordinated campaign by Homes for Scotland1. Of these, 16 gave a near identical email response, and each was included in the analysis as a separate response as each came from a different organisation1.
The most prevalent concern among those who agreed was the perception that Scotland's current electrical grid capacity and infrastructure is insufficient, with several highlighting that the proposals could be challenging to implement in rural or island areas which may be off-grid or where capacity may be lower1. The second most prevalent theme was challenges with the supply, installation and maintenance of zero-direct emissions heating (ZDEH) systems, due to skills and material shortages1. Other possible unintended consequences included the delay or termination of planned developments of new homes, the possibility that more expensive heating systems could exacerbate fuel poverty, consumer unease over the technology, and an uneven impact on rural areas with more off-grid locations1.
"Their views will assist the Scottish Government in finalising the NBHS regulations to put to Parliament in 2023."
Why it matters for households
The standard applies to new buildings rather than to existing homes, so its direct effect falls on people buying or commissioning a newly built house rather than on those living in the current housing stock. The practical consequence for a new home is the heating system it comes with: the proposal would rule out a direct emissions system, typically a gas or other fossil-fuelled boiler, in favour of a zero direct emissions alternative such as a heat pump. That changes how a home is heated, and how it draws its energy, from the point of construction.
The responses point to the questions that surround that shift. Grid capacity and infrastructure were the most common concern raised even by those who agreed, and rural and island areas were singled out as potentially harder to serve where properties are off-grid or capacity is lower1. Supply, installation and maintenance of zero direct emissions systems, and shortages of skills and materials, were the second most common theme1. Respondents also raised the possibility that more expensive heating systems could exacerbate fuel poverty, and called for consumer education on the technology and for a government-supported fiscal support package1. On equalities, the most common theme was a concern that zero direct emissions heating could raise the cost of heating homes, whether through greater use of electricity or because a conversion may not meet insulation standards; the second most common was a belief the proposals would have no impact on equalities1.
For a household, the standard bears on energy independence in the sense of what a new home relies on to stay warm. A home built without a direct emissions system depends on electricity and on the building's own efficiency rather than on a fuel delivered to the property. The consultation responses indicate that the capacity of the grid, the cost of running the system and the fabric of the building are the points respondents expect to determine how well that works in practice1.
What happens next
The Scottish Government's stated plan is to prepare legislation in Spring 2023 for the NBHS coming into force in April 20241. The analysis states that respondents' views will assist the Scottish Government in finalising the NBHS regulations to put to Parliament in 20231. The document was published by the Scottish Government in June 20231. The consultation is one stage in the process by which such rules are proposed, decided and changed, which is set out in Energy Consultations: How Rules Are Proposed, Decided and Changed, part of the site's regulation and policy coverage.