The National Insulation Association (NIA) published its response to the Scottish Government's consultation on proposals for a Heat in Buildings Bill on 13 March 2024. The association said it strongly supports prohibiting polluting heating systems in all buildings after 2045, and strongly supports a minimum energy efficiency standard (MEES) for private sector landlords by the end of 2028. It somewhat supports a MEES for owner occupied homes still using polluting heating by the end of 20331.
"The NIA supports the prohibition of polluting systems in all buildings after 2045"
On the landlord standard, the NIA cited the Scottish House Condition Survey published in May 2023, which found 30% of private rented sector households are fuel poor, against 9% of those with a mortgage and 14% of outright owners. It also cited a British Gas report finding 44% of landlords do not know the EPC rating of their properties, and that over half do not know enough about available grants. The association said landlords need sufficient notice before MEES come into force, warning of supply chain bottlenecks if thousands of landlords install measures at the same time1.
The NIA disagreed with the proposal that owner occupied homes which have ended their use of polluting heating by 2033 would not have to meet the MEES. It argued that a fabric first approach, in line with PAS 2035, should apply regardless of heating system, pointing to the electricity to gas price ratio of 3.86 to 1 at the January 2024 price cap level, and to an estimated £170bn to £210bn of UK grid investment needed by 20501.
On the proposed list of measures, the NIA somewhat opposed the initial list and somewhat supported the alternative of a reformed EPC fabric efficiency metric. It said solid wall insulation, both internal and external, should be added to the list, noting that nearly a quarter of Scottish homes have solid walls and only 16% of these had insulated walls as of 2022. It cited Energy Saving Trust figures that solid wall insulation could save a typical detached home £660 per year on energy bills, and said it would be open to a later compliance date for solid wall properties1.
| Proposal | NIA position |
|---|---|
| Prohibit polluting heating in all buildings after 2045 | Strongly support |
| MEES for private sector landlords by end of 2028 | Strongly support |
| MEES for owner occupied homes by end of 2033 | Somewhat support |
| MEES met by a list of measures or a reformed EPC metric | Somewhat support |
| Initial proposed list of measures | Somewhat oppose |
Why it matters for households
The standards under consultation would set the point at which a home in Scotland is considered efficient enough, whether it is rented or owned. For rented homes, the landlord standard is proposed for the end of 2028; for owner occupiers still on polluting heating, the end of 2033. The NIA's argument is that the fabric of a home, its insulation and glazing, determines how much a low carbon heating system costs to run, and that homes with solid walls could be left on a weaker standard if solid wall measures are excluded from the list. Its figures put 45% of a home's heat loss through uninsulated solid walls1. The consultation also covers how compliance is demonstrated, through either a list of measures or a reformed EPC metric, which affects how a householder or landlord shows a property meets the standard.
What happens next
The consultation closed and the NIA's response was published on 13 March 2024. The Scottish Government has not yet finalised the MEES regulations; the NIA urged it to embed them in law as quickly as possible to give landlords and the retrofit industry clarity1. No date for the Bill's introduction or for final regulations is given in the response.