Scottish Building Regulations: Review of Energy Standards – Common Weal Consultation Response

Consultation Response

Credits — Linda Pearson

Overview

This report forms Common Weal’s response to the first stage of the Scottish government’s review of building energy standards and is part of our ongoing work on energy and housing policy.

We argue that the Scottish government should introduce passive standards for new buildings in Scotland while existing buildings should be retrofitted to the maximum technically feasible energy standard. A comparison of the heating requirements of existing buildings with buildings built to passive standards demonstrates how these measures could lead to a significant reduction in energy use and energy costs, helping to lower greenhouse gas emissions and alleviate fuel poverty.

The Scottish Government is currently undertaking a review of the energy standards in the Scottish Building Regulations. The review will consider how the energy performance of buildings in Scotland can be improved and how new energy standards could contribute to the greenhouse gas abatement targets in the Climate Change (Scotland) Act 2009. This report forms Common Weal’s response to the first stage of the review, which is a call for evidence on the effectiveness of the 2015 building energy standards, and is part of our ongoing work on energy and housing policy.

As Common Weal has previously argued, buildings are a major contributor to greenhouse gas emissions in Scotland so improvements to the energy standards of existing and new buildings should play a prominent role in Scotland’s environmental policy. Heat makes up over half of Scotland’s total energy use budget, therefore measures to reduce overall demand will make it easier for Scotland to complete the transition to a nation powered only by renewable energy sources. Improvements to the energy standards of homes are also key to tackling fuel poverty, which currently affects one third of Scottish households.

Here we argue that legislation should mandate the best energy standard possible for new and existing buildings, rather than continuing the Scottish government’s current incremental approach towards improving standards. Passive or net-zero energy standards should be mandated for new buildings, while the maximum technically feasible energy standard should be applied to all existing buildings. This would achieve dramatic reductions in the space heating requirements of Scottish buildings, as demonstrated by our examples.

This submission also draws on our response to the Scottish government’s call for views on the objectives of the proposed Scottish publicly owned energy company (POEC), which argues that the POEC should facilitate the deployment of solar thermal and solar photovoltaics panels to Scottish homes. This could help achieve net-zero energy standards for existing homes and would make a significant contribution towards tackling fuel poverty.

Key Points

1. According to the latest figures, 26.5% (or around 649,000) of Scottish households live in fuel poverty while 7.5% of households (183,000) live in extreme fuel poverty. This is unacceptable in contemporary Scotland.

2. The Scottish Government should abandon its staged approach to housing energy efficiency improves as it creates ongoing (rather than one-time) upheaval for construction companies and adds to the problem of retrofitting existing buildings to the most efficient standards.

3. Instead, all new buildings in Scotland should be constructed to passive and zero-carbon standards.

4. Existing buildings are currently scheduled to be retrofitted in stages guided by their EPC rating. Any building retrofitted to meet the EPC C target will need to be retrofitted again at a future date to meet the EPC A target.

5. Instead, all buildings should be surveyed immediately and assessed on their maximum feasible retrofitting potential. They should then be scheduled to be retrofitted to that potential in a single project.

6. Where it is not possible for buildings to be retrofitted to passive standards, zero carbon abatements such as solar thermal or solar PV should be installed to ensure an adequate level of zero-carbon heating.

7. Passive standards such as PassivHaus and Enerphit are well established but other standards should be explored which can produce similar efficiency standards but make more use of locally sourced materials such as Scottish timber and timber products.