Changeworks has submitted its response to the Scottish Government’s consultation on the Social Housing Net Zero Standard.
On this page we’ll take a look at the Scottish Government’s current proposals for the Standard. It’s important to remember that these are only proposals. They could change before the Standard becomes law.
You can read Changeworks’ full response to the consultation here.
What is the Social Housing Net Zero Standard?
The Social Housing Net Zero Standard will set out the regulations for how local authorities and housing associations heat residential properties, as well as how energy efficient the buildings need to be.
This new regulatory standard will replace the current Energy Efficiency Standard for Social Housing post-2020 and provide the timescales for social housing providers to meet the new requirements.
For example, it’s proposed that the use of polluting heating – such as gas boilers – will 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.
Our response
Changeworks welcomes the Social Housing Net Zero Standard 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.
The bill will also be crucial for tackling Scotland’s fuel poverty crisis. The poor energy efficiency of Scottish homes, coupled with high energy costs, has pushed thousands into fuel poverty.
Social housing tenants are at greatest risk, with around 48% of households in fuel poverty.
To address this, Changeworks urges that a whole building approach should be taken. This means that overall building health should be taken into consideration, and that ventilation and energy efficiency measures (such as insulation) should be installed depending on the needs of the building, followed by replacement clean heating systems.
Transition to clean heating
Changeworks supports the proposals to prohibit the use of polluting heating systems in all buildings after 2045.
We urge the Scottish Government to implement interim targets (such as: 20% by 2030, 70% by 2040, 100% by 2045), to relieve pressure on the supply chain between 2030 and 2045.
An exact timeline should be clarified and communicated early to provide certainty to social landlords and the supply chain. 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.
Energy efficiency targets
The consultation proposed the following measures be installed, where feasible, to reach a minimum energy efficiency standard by 2028:
- 270 mm loft insulation
- Cavity wall insulation
- Draught proofing
- Heating controls
- 80 mm hot water cylinder insulation
- Suspended floor insulation.
Changeworks’ has responded that this simplistic ‘list of measures’ approach is not ambitious enough.
As some of the measures do not apply to many housing types (such as those with solid walls), this approach would likely result in continued heat loss in already leaky and inefficient properties.
In these cases, the minimum energy efficiency standard would not reduce energy usage and may worsen fuel poverty for tenants.
Changeworks recommends that 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.
Clear and detailed guidance should be set for social landlords to follow, based upon property type and construction. Similar guidance should be provided to landlords about which clean heating systems are most appropriate and efficient, to ensure that end-use fuel costs are affordable for tenants.