New build heat standard consultation: part II

1/ It is correct approach to phase out DEH systems. It is imperative that this is
achieved through the Building Standards rather than the Planning System. If
individual planning authorities introduce their own requirements it will make the
elimination of DEH systems significantly more difficult to achieve. The Scottish new
build sector is smaller than the UK by an order of magnitude. This presents a
challenge to the UK supply chain to react to the smaller Scottish market. If this
market is then subdivided yet again with individual planning authorities having their
own specific requirements, the challenge only becomes greater.

2/ There is a real danger that the elimination of DEH systems will lead to a reduction in
the number of new homes being delivered unless the Government recognises that
the homebuilding sector cannot deliver this change in isolation and prepares
accordingly. It is accepted that air source heat pumps (ASHP) will be the preferred
alternative to DEH resulting in a material increase in electrical demand. Without
sufficient electricity grid reinforcement, particularly in rural areas, there will be a
problem. This will require investment by SSE & SPEN with support from government.
Marginal housing sites will become unviable without this support. Rather than
introduce a blanket ban an alternative would be to permit exceptions if grid capacity
is unavailable beyond a set reinforcement cost per unit. Such an approach is not
dissimilar to the current requirement for residential landlords to upgrade rental
properties to a set EPC standard unless it is deemed to be beyond a reasonable
cost. Such an exception policy could be phased out as grid capacity becomes
available.
There is also a physical constraint on the number of ASHP which can be installed
due to the lack of capacity in the ASHP supply chain. This constraint must be
addressed. Failure to do so will lead to a reduction both in the number of houses
being delivered and in the number of SME builders. The SME sector will be impacted
disproportionally due to the ability of the PLC housebuilders to grab the limited ASHP
supply chain capacity. The number of SME housebuilders operating in Scotland has
been falling for many years. This is a trend the government needs to reverse, not
inadvertently accelerate. The range and choice of new homes available in the
Scottish market will inevitably reduce as the SME sector diminishes. In addition the
reduction in numbers of homes being delivered will be more acute in rural areas of
Scotland where the proportion of homes delivered by the remaining SMEs is higher.

3/ No Comment

4/ No Comment

5/ No Comment

6/ No Comment

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