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Elmhurst publishes draft response to Scottish Government's Heat in Buildings Strategy Consultation


The Scottish Government are seeking consultation for their latest heat in buildings strategy, which attempts to achieve net zero emissions for Scotland’s homes and buildings by 2045. The draft strategy does not cover heat used in industrial processes, however it does focus on energy demand for space and water heating in domestic homes, workplaces and community buildings.

View Elmhurst’s consultation response

To meet their net zero target, by 2045 all homes and buildings in Scotland must have significantly reduced their energy use, and almost all buildings must be using a zero emissions heating system. The proposal reports that today there are around 2.5 million occupied dwellings in Scotland and they account for 15% of Scotland’s total greenhouse gas emissions. The vast majority of these homes use mains gas as their primary heating fuel (approx. 2 million). Only around 11% (approx. 278,000) of households have a renewable or very low emissions heating system, such as a heat pump, biomass boiler or electric storage heating.

Clearly there is scope for improvement, and the Government strategy sets out a framework for doing so. In light of the proposals, we believe there are 3 overriding points to focus on to realise these targets effectively and efficiently.

3 points to focus on

Development and investment

Firstly, we believe development and investment in the current models and tools is essential. The national calculation methodologies of SBEM and SAP must receive investment to ensure upmost accuracy and consistency of the information we are providing within the industry. They must be fit for purpose whilst being mindful not to stifle proven innovation.

To improve the accuracy and effectiveness of an EPC, trigger points and validity periods could be revised. By increasing the number of trigger points for an EPC, for example when a material change has occurred in the building that will impact its energy efficiency, property owners can maintain accurate and measured reporting of their buildings efficiency with contemporaneous improvement recommendations. In addition, reducing the EPC validity to 3 years provokes more proactive actions from homeowners to improve their buildings as they cannot rely on complacency of the EPC being valid for 10 years at a certain rating, despite how inaccurate this could be due to changes over the years.

New tools must be developed

As well as improving existing tools, new tools need to be developed to highlight and illustrate real opportunities for energy efficiency improvements. The capacity and facility to produce occupancy reports, which provides a prediction of energy consumption based on the current occupants lifestyle and usage of their dwelling, ensures recommendations for measures and the benefits of such are realistic and measured. Leading on from this, an ‘in-use’ performance metric would allow occupiers to compare their performance with a predicted performance, providing a greater understanding of how occupant behaviour impacts energy consumption. In regards to the current EPC itself, we suggest a re-formatting is proposed to ensure equal exposure is given to cost, energy and carbon impact. This would allow a more holistic and useful result to be provided by an EPC, and perhaps an alignment of the metric used at the core of EPCs could be reviewed.

Deep retrofit improvement

Finally, we believe the Scottish heat strategy will require a consideration for deep Retrofit improvement. Establishing a buildings need for efficiency improvement is only half of the battle; for effective improvements to follow as a result, a systemic approach based upon the needs of the building and occupants needs to be undertaken. Measures should be installed at a time and sequence that maximises improvement and reduces unintended consequences, such as damp and poor air quality. Funding models must be consistent with the principles of PAS2035 which means a break away from a measure lead approach, to a focus on the improvement that has been delivered instead.

Have your say

Elmhurst welcome the proposed heat strategy and will be responding to the consultation paper in due course. If any Elmhurst member wishes to let us know their thoughts we would welcome their input to our official response, please let us know.

Deadline for submissions: 30th April 2021

View Elmhurst’s consultation response