Scotland’s heating Strategy is officially a mess

After today's announcements on Scotland's home heating strategy (the Heat in Buildings legislation is to be postponed for the second time), Scotland's approach to decarbonising heating is officially a mess. It is increasingly had not to feel that this is a commitment which rises and falls according to prevailing political expediency.

At the heart of this are a series of announcements which all have their genesis round about CoP26 in Glasgow. For a brief period, the climate-concerned eyes of the world were on Scotland and in the run-up we undertook a lot of activity to live up to the expectations we set politically.

Prime among these were ambitious targets, but targets need some sort of action plan and that is where the problems begin, not because of lack of actions plans but because of a surfeit of them. Or, perhaps more accurately, there were too many of them but they amounted to less than the sum of their parts.

The heating aspect had four main components. One was about how we heated our buildings, one about how we stopped heat leaking from our buildings, one was 'about heat networks' and one was about standards for landlords. Each had its own parliamentary legislative process. But to understand their progress you need to understand their content.

The Heat Networks Act was passed in 2023 and it has almost no effect on anyone. It does little more than regulate district heating systems. These heat less then two per cent of Scotland's homes and it is not at all clear that the legislation change conditions for any of those two per cent anyway. It might be considered 'necessary housekeeping' or it could just be seen as a way of passing legislation so it can be said 'something' had been done about heat networks.

The Heat in Buildings Strategy on the other hand has direct impacts on people. This is the legislation which drew ire because it initially planned a blanket ban on wood-burning stoves irrespective of context (a correct step in urban areas with air pollution; not in rural areas with unreliable electricity supplies).

It would have mandated a shift to heat pumps over time. This is not currently politically popular and is the subject of a 'culture wars' backlash, net zero sitting along with immigration as a target for right-wing media.

But there are also legitimate concerns about seeing heat pumps as the solution to decarbonising heating. Common Weal does not believe these are the best solution. We are very concerned that these are a short-term solution which will impose significant hidden capital costs on households. A heat pump costs about £15,000 to install but has a lifespan of about 15 years.

That means a £1,000 a year capital replacement cost – forever. It is also a major issue in terms of embedded climate harm during the manufacture of the heat pumps themselves. We do not have anything like enough engineers to maintain and repair a heat pump system at scale and we are not training them.

The Heat and Energy Efficiency Technical Suitability Assessment Bill (known as Heetsa) is the one about assessing house performance. Common Weal has worked closely with civil servants in the development of this legislation. This is about reforming the way we assess buildings for their thermal efficiency to guide retrofitting.

Put simply, the existing Energy Performance Certificate model is something Common Weal has criticised for a long time as out of date, inaccurate, misleading and not based on real world data. It leads people to misunderstand where and why their house is leaking heat and actually harms retrofitting.

The impact of this legislation will have some negative cost implications for households, but it is much more technical and is unlikely to have the backlash qualities of the Heat in Buildings strategy.

The final strand is the snappily-titled Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, generally known as Private Rental Property Minimum Energy Efficiency Standards or PRS MEES, or just MEES. It is about making landlords make rental housing liveable in terms of energy efficiency. It sets targets for 2028.

Here is the point; Heat Networks has almost no effect on anyone so it passed. The Heat in Buildings legislation has consequences for a lot of people so it has been dropped. Heetsa has some consequences for people but only where they would otherwise need an EPC so it is currently still scheduled to go ahead before the end of this parliament. And PRS MEES would impact landlords and so is only at consultation stage anyway.

Which is to say the Scottish Government has been bold at setting targets, reticent about spending any political capital to meet them, particularly according to the degree of difficulty each effected group can bring to the Scottish Government (landlords at the top), sheepish in therefore abandoning those targets then opaque in its reasoning for also abandoning the legislation.

Which is, in turn, to say that on this cold morning, the Scottish Government approach is a fragmented mess which demonstrates political will to be seen to do good things but no political will to actually do good things. This is precisely why Common Weal has been fighting for a Scottish Energy Development Agency to create some kind of coherent strategy to make sense of this mess.