Changeworks’ response to the Heat in Buildings Bill consultation

Changeworks has submitted its response to the Scottish Government’s Heat in Buildings Bill consultation.

With over 35 years’ experience in home decarbonisation, Changeworks has used its expertise to provide detailed analysis on the link between decarbonisation and fuel poverty, and how best to improve the energy efficiency of Scotland’s homes.

Read on for our response to the consultation.

What is the Heat in Buildings Bill?

The Heat in Buildings Bill will set out laws for how we heat Scotland’s buildings, as well as how energy efficient the buildings need to be. This will include timescales. For example, the use of polluting heating – such as gas boilers – is proposed to be prohibited in all buildings from 2045 onwards.

Responses to the consultation will be used by the Government to adapt their proposals before taking the Bill to Parliament.

Find out more about what’s in the Heat in Buildings Bill consultation here.

Our response 

Changeworks welcomes the Heat in Buildings Bill and the Scottish Government’s commitment to consult on new heating and energy efficiency regulations.

Buildings in Scotland account for 20% of the country’s greenhouse gas emissions (13% from the home), so it’s impossible to reach our net zero target without decarbonising them.

This bill is vital if Scotland is to alleviate the current fuel poverty crisis, as leaky homes and a reliance on volatile fossil fuel markets for home heating systems have caused thousands to fall into fuel poverty. Around 35% of Scottish households are in fuel poverty, and over 50% of homes have an Energy Performance rating of D or below. 

Changeworks supports the proposals to prohibit the use of polluting heating systems in all buildings after 2045 if not earlier. However, an exact deadline needs to be implemented to the proposed changes

We also call for the same minimum energy efficiency standard to be applied to all tenures, whether private-rented, owner-occupied, vacant or short term let.

Minimum energy efficiency standards should be set and varied by property archetype and based upon space heating demand in the range of 71-120 kWh/m2year, which presents realistic targets across all housing stock.

We need to see the Bill progress urgently to provide certainty to supply chains and clarity on timelines. This certainty is needed for the wider supply chain to adequately prepare, invest and upskill to respond to the scale of installations, connections and measures that will be required to implement the Bill and meet net zero targets.

Supporting householders: affordability and capability

While Changeworks welcomes the commitment to consult on new heating and energy efficiency regulations, amendments need to be made to ensure a fair transition to decarbonisation.

Installations of low-carbon energy efficiency measures and heating systems need to comply with regulations, and the cost of transition and future energy bills must be affordable. Householders must also be supported along this journey. This means ensuring they understand the need for a low-carbon transition, have information about what they need to do their home, and have access to funding to enable them to decarbonise their home.

Alongside the existing Home Energy Scotland Grant and Loan scheme and the Warmer Homes Scotland scheme, the Government should develop alternative financing mechanisms for householder support to ensure they’re not left behind.

The opportunity to tackle fuel poverty

Changeworks is concerned that the bill focuses exclusively on decarbonising heating. The proposals are at risk of missing the opportunity to lift people out of fuel poverty. To avoid this, it remains critical that a just transition takes place, to maximise the opportunities for reducing fuel poverty as we collectively tackle the climate emergency.

Increased energy efficiency alongside decarbonisation is vital if we’re to reduce household energy costs. It will also minimise pressure on the electricity system as we shift away from natural gas.

Read our full response to the Heat in Buildings Bill consultation.