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Elmhurst issues final response to key Scotland Buildings Standards Consultation


Elmhurst has issued its final response to the Scottish Government’s consultation on energy efficiency in Building Standards (Section 6), which covers proposals for energy, ventilation overheating and EV charging standards to be implemented in 2022 for new and existing domestic and non-domestic buildings.

You can read Elmhurst’s Final consultation response here.


The consultation follows the New Build Heat Standard consultation which was released in December 2020, and sets out a roadmap towards creating homes and buildings that are fit for the future, a built environment with lower carbon emissions and homes which are adapted to the overheating risks caused by a warming climate.

The consultation document was split into six parts. A summary follows below:

Energy, new buildings

This section included a proposal to introduce an energy target for all buildings either in the form of Primary Energy or Delivered Energy. For new homes either a 32% or 57% reduction in the carbon target was proposed, and for new non domestic buildings either a 16% or 25% reduction was proposed. Changes to the notional buildings for both new homes and non-domestic buildings to facilitate the move away from fossil fuel heating and special treatment for heat networks were also covered. Finally a limit to the benefit of on site electricity generation was put forward. An improvement to the fabric standards for domestic and non-domestic buildings was suggested, including mandatory air tightness testing for all new buildings and the introduction of the Pulse air tightness testing method.

Key messages from Elmhurst’s Response

We support the 57% and 25% carbon reduction uplifts proposed for new homes and non-domestic buildings respectively

The new energy metric should be based on Primary Energy in line with the rest of the UK to prevent unintended consequences in building specification between regions

We do not support the proposed treatment for heat networks as this is overly complicated and based on future policies that are not yet implemented

We do not support the limiting of on site renewable energy in SAP as there are other uses for on site electricity that are not currently part of the methodology but in reality could benefit from this generation

The proposed fabric standards and mandatory air tightness testing are sensible and should be introduced

Energy, all buildings.

This section introduced the term Major Renovation into the standards, but has not yet defined the standards required for this type of work. Improved fabric standards for work to all types of existing buildings was proposed as well as clarifications to the Building Services Compliance Guides. Improved minimum efficiency values for building services are proposed in line with the rest of the UK and proposals for future proofing heating circuits to accept low carbon heat in the future were put forward.

Key messages from Elmhurst’s Response

  • We support the introduction of the term Major Renovation into standards.
  • We support the improvement and clarifications for fabric standards where work is undertaken on existing buildings.
  • We support the alignment of standards for building services with the rest of the UK.
  • We support the proposal to futureproof heating circuits for low and zero direct emission heat but must be mindful of unintended consequences such as poor siting of large radiators.

Overheating Risk

In a similar manner to England and Wales it is proposed to remove the overheating compliance check from SAP, and introduce a simplified and detailed method for assessment of overheating risk.

Key messages from Elmhurst’s Response

We support the greater emphasis placed on mitigating overheating risk in new homes. We recommend extending this requirement to high risk non domestic buildings such as care homes.

We advocate that only members of a competent persons scheme should be able to produce overheating risk assessments in line with the TM59 method.


Elmhurst’s Managing Director, Stuart Fairlie, comments: “It is fantastic to see that, in spite of the pandemic, the government are still keen to make buildings fit for the future, and this consultation provides a vital next step in this process. The government has indicated that the results of the consultation will appear in legislation in Spring 2022 for adoption in the Autumn of 2022, so we hope that it won’t be too long until we see the direction that government are taking with this”.