The Scottish Government opened a consultation this week on energy and environmental standards for new buildings, based on the international Passivhaus standard1. The consultation covers both domestic and non-domestic properties, and follows the New Build Heat Standard (NBHS), which entered into force on 1 April1.
Solar Energy Scotland, the solar trade body, said the consultation is based on the original, or "Classic", Passivhaus standard, devised decades ago when renewables were rare and expensive1. It said solar power is not mentioned at all in the consultation, and that the proposals do not go as far on energy efficiency as Passivhaus Classic1. Passivhaus Classic has since been superseded by the "Plus" and "Premium" forms, which mandate the installation of renewable energy, potentially including solar thermal systems for hot water1.
The consultation follows a plan announced in early 2023, based on measures set out in Alex Rowley MSP's proposed Domestic Building Environmental Standards (Scotland) Bill1. The NBHS bans the burning of fuel for heat, so no new home in Scotland may have a gas boiler or fireplace, with the intention of driving mass adoption of heat pumps1. Solar Energy Scotland said heat pumps will not have to be accompanied by rooftop solar power, which it said would cut their operating costs, and that the preceding iteration of the regulations led to the vast majority of new Scottish homes having photovoltaic panels installed1.
The body contrasted the proposals with the EU Solar standard, agreed this spring, which will require solar power on all new commercial and public buildings by 2026 and all new residential buildings by 20291. It said Westminster's planned Future Homes Standard proposes banning gas boilers, with the finalised version expected to effectively mandate solar on new homes, and that the allied Future Buildings Standard would do the same for non-domestic properties1. It also said the direction is inconsistent with last year's commitment to boost solar capacity across Scotland to between four and six gigawatts by 20301.
"We welcome the Scottish Government's intentions to upgrade fabric and comfort standards and improve quality assurance for newbuild properties. However, we caution against using outdated energy calculations that undervalue on-site generation such as solar power, and the huge opportunities of battery energy storage and smart home energy management. We would encourage the Scottish Government to align with the EU and the rest of the UK on rooftop solar."
"We welcome the consultation and hope that the outcome will be much more positive towards solar power. This would assist the delivery of the Scottish Government's commitment to a deployment target of 4-6GW of solar energy and provide a long-term stable policy for solar-powered homes and buildings. Doing otherwise could come at the cost of jobs, higher bills and higher carbon emissions."
Why it matters for households
The standards under consultation would shape what is installed in new homes in Scotland, and therefore what running costs their occupants face. A home built to a fabric-first standard with a heat pump but no on-site generation buys all its energy from the grid, so its bills track electricity prices rather than being offset by its own output. Solar Energy Scotland's argument is that omitting solar from the standard leaves that operating cost unaddressed1. For a household, on-site generation and storage are the main routes to generating rather than only consuming energy, which is the practical meaning of energy independence at home. The consultation's treatment of solar is not reported beyond the trade body's account; the Scottish Government's own reasoning on the omission has not been reported.
What happens next
The consultation is open. The Future Homes Standard for England is expected to be finalised in the coming months, with the allied Future Buildings Standard to follow1. The EU Solar standard's requirements take effect for new commercial and public buildings in 2026 and for all new residential buildings in 20291. No date has been reported for the Scottish Government's response to its consultation.