Consultation: New Build Heat Standard consultation – Part 2 (Scotland only) (closing date – 3 October 2022)

Your views invited.

This consultation paper builds on the 2020-21 New Build Heat Standard (NBHS) Scoping Consultation (NBHS Consultation: Part 1) by setting out how the Scottish Government intends to regulate to prohibit the use of direct emissions heating (DEH) systems in new buildings from 2024 onwards. A DEH system is one which produces greenhouse gas emissions at the point of use.

The Scottish Government is seeking your views on the key areas relating to these proposals, which will help to ensure that the regulations enforced from 2024 onwards are achievable and effective.

Scottish Government’s proposals to develop the NBHS have coincided with the recent conclusion of the Building Standards Energy Review. The improved energy efficiency standards for new buildings, set under the revised building regulations, will pave the way for the implementation of the NBHS in 2024.

Key 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 demand.
  • Instead, the use of zero direct emissions heating (ZDEH) technologies will be required.
  • This will mean an increase in the deployment of ZDEH systems, such as heat pumps and heat networks, in new buildings across Scotland.
  • Bioenergy is not considered to be a ZDEH technology.

This will apply to: 

  • both new domestic and non-domestic buildings, as well as the conversion of existing buildings.
  • any installed heating system within the curtilage of the building (both main and any other fixed heating system)

The full consultation paper can be found here.

If you would like to contribute to CIAT's response to the consultation, please complete your answers to the below questions and return to Joanne Rowlands at [email protected] by Monday 3 October 2022

Questions

  1. Do you agree with the approach set out in 2.1 to regulate direct emissions heating systems in new buildings?
  2. Do you envisage any unintended consequences as a result of this approach? Please provide reasons for your answer.
  3. Are there any limited, specific situations where the use of bioenergy systems would be required in new buildings?
  4. If 'Yes', what do you believe the criteria should be for introducing such an exemption? Please provide evidence to support your answer.
  5. Do you agree with the proposed approach to conversions as set out in section 2.3?
  6. Do you envisage any unintended consequences as a result of this? Please provide reasons for your answer.
  7. What criteria would you use to define the replacement of a direct emissions heating (DEH) system as being 'reasonably practicable'?
  8. What criteria would you use to define it as being 'not reasonably practicable'?
  9. How might these proposals impact upon people with one or more of the protected characteristics listed in the Equality Act 2010 (for example: a positive, negative or neutral impact)?
  10. How might these proposals help the Scottish Government ensure due regard of the three needs of the public sector equality duty(PSED)?
  11. Do you anticipate any form of heating within a non-domestic building which will require DEH after 2024? Please provide details of the factors – whether technical, economic or social – which would require DEH after 2024?

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