Scottish Building Regulations: Review of Energy Standards ‘Call for Evidence’

Elmhurst has reviewed and submitted an official response to the Scottish Government's 'Review of Energy Standards call for evidence'.

The Scottish Government states:

“This consultation is seeking the views of stakeholders on the impact the 2015 energy standards had, or continues to have, on Industry in designing and constructing buildings to meet the Scottish building regulations. Feedback received will be considered in the development of the next set of energy standards programmed to be introduced in 2021.”

It also notes that:

"It is anticipated that the next set of standards and supporting guidance will be introduced in October 2021 with the changes being published 1 year in advance. Versions of the national calculation methodologies (SAP & SBEM) will be available before the revised standards and guidance take effect."

Stuart Fairlie – Technical Director at Elmhurst Energy said “We welcome the chance to provide feedback to Scottish Government when it concerns the future direction of Section 6. There were some issues encountered during the previous update in 2015 and we hope that these areas can be addressed moving forward. The suggestions provided within our response to this call for evidence, should hopefully enable warmer and more energy efficient buildings to be constructed in Scotland. Moreover, we believe that those involved in Industry must endeavour to educate and advise all stakeholders of the importance of building more energy efficient homes and commercial premises.”

We liaised with industry and members and have broken down our response into a number of sections as summarised below. You can view our full response here. 

Summary of Elmhurst's response:

Improve the quality of design stage assessments.

Elmhurst suggests that the Scottish Government should look to improve the standard of reports used to demonstrate compliance with Section 6, issued at ‘design stage’. We believe that such compliance reports, that are required before building commences, should only be undertaken by accredited energy assessors under the control of an EPBD Approved Organisation, in the same way as the current requirements for individuals who wish to produce EPCs. Assessment's should be submitted to the Approved Organisation and be subject to independent quality control activities.

Regulatory Compliance

The Scottish government should consider ways of ensuring that the Building Standards process strictly applies the rule that an EPC is required before a building is signed off. 

The Scottish government should create more publicity surrounding the need for building standards to be correctly enforced throughout the build process e.g. site visits to be used to verify the ‘as designed’ calculations and finally a visit to ensure the completed dwelling is as per ‘as built’ calculations.

As previously stated, a solution is to enable accredited SAP/SBEM Assessors to verify the Compliance Report before creating the EPC.

Design Consequences following the change to 2015 building standards

We asked members what areas they have focused on to achieve compliance following the uplift in standards introduced in 2015. Regarding the building envelope, the feedback we received included; insulation levels within walls, roofs and floors have increased, air tightness test scores have decreased, and a greater emphasis is placed on reducing the heat loss through building junctions.

In regards to building services our members stated that generally oil or electric powered systems are used, with a move towards electric ground and air source heat pumps. An alternative is the use of biomass boilers which achieve very low CO2 emission rates thus making compliance much simpler.

Due to the tightening of the notional building used for standard 6.1, the use of renewable energy has also increased; usually photovoltaic panels are recommended to aid compliance with the standards. 

Domestic Conversions:

The Scottish government should consider ways of ensuring that a SAP based EPC is required before a converted building is signed off.

It is quite usual for domestic energy assessors to be asked to undertake RdSAP assessments on a converted building to produce an EPC. This effectively gives the homeowner/tenant an inaccurate EPC for the property. This EPC will use conservative defaults and as such will make the home appear worse than it likely is.  It would make sense to undertake a SAP calculation during the conversion process to ensure that an accurate EPC can be created.

Call for Evidence Document:

Deadline for Responses: 14th Sept 2018

Article Published: 14th September 2018

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