New build heat standard consultation: part II

1/ Kingspan agrees that in order to decarbonise new buildings there is a need to prohibit the use of
direct emissions heating systems (DEH) in any new building applying for a building warrant from 1
April 2024 onwards. Kingspan note that whilst technologies, such as heat pumps are zero emissions
at the point of use, scope 2 emissions (from purchased electricity and heat) will remain until the
grid and heat networks are fully decarbonised. However, regulation of direct emissions will help to
enable buildings to be future proofed and ultimately carbon neutral, as the grid and heat networks
are decarbonised.
In order for heat pumps to deliver high efficiency and contribute to a decarbonised future, it is
important that strong thermal performance is exhibited in new build properties. This means that the
heating demand of the property is lower, and heat pumps can be run at lower temperatures
meeting heating requirements, and will also prevent loss of heat and higher energy bills.
Kingspan are supportive of how the Scottish Government intend to regulate to prohibit the use of
direct emissions heating (DEH) systems in new buildings from 2024, however according to UK FIRES,
if we electrified every sector of the UK economy, aside from those that are notoriously difficult to
decarbonise, such as shipping, and continued to expand non-emitting electricity generation at
current rates, there would be a significant energy gap (1)
.
This indicates the importance of minimum fabric standards, ensuring that buildings are well
insulated, prior to, or alongside, the installation of low carbon heat as part of a fabric first
approach.
Despite recognition that there is a need to reduce demands, we were concerned that insulation
was not mentioned within the consultation. However we understand that fabric first is highlighted
in the upcoming changes to the Scottish Building Regulations that will be put in place this year (2)
, which Kingspan welcome.

(1) UK FIRES. Absolute Zero. Available At:
https://www.repository.cam.ac.uk/bitstream/handle/1810/299414/REP_Absolute_Zero_V3_202005
05.pdf?sequence=9&isAllowed=y
(2)Scottish Government. Scottish Building Regulations. Available at: https://consult.gov.scot/local-government-andcommunities/building-regulations-energy-standards-review/

2/ Whilst Kingspan recognise the importance of heat pumps in the road to net zero, with the Climate
Change Committee’s (CCC’s) Sixth Carbon Budget advising that heat pumps and heat networks form a core part of the Net Zero Balanced Pathway (3), it is paramount that the ‘fabric first’ message
set out by government is maintained a priority. Renewable heating reduces carbon emissions,
however if a building is not properly insulated, leaky buildings will waste heat and energy. This will
lead to unintended consequences such as higher energy bills and could result in energy insecurity
due to high demand. This will, in turn have further implications such as failing to address fuel poverty
issues and occupant wellbeing. Although building regulations are in place to address these issues,
it is important that standards in place are upheld and verified to ensure maximum benefit from
ZDEH technologies and for the consumer.

(3) CCC. The Sixth Carbon Budget. Available At: https://www.theccc.org.uk/wp-content/uploads/2020/12/The-SixthCarbon-Budget-The-UKs-path-to-Net-Zero.pdf

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Kingspan stress the importance of a ‘fabric first’ approach. During the conversion of a property, it
will be important that the fabric of the property is considered before the heating systems are
installed. This will ensure that the heating system will perform optimally which maximises efficiency
and delivers savings.

We believe that there are limited circumstances which would prevent the transition to a zero
emission heating system. However, there are situations where further renovation may be needed to
accommodate these. It some circumstances, it may not be cost effective, or practical to install
low carbon heating systems and therefore it is important that a criteria is developed to exempt
these properties.

It is important that all options are considered, and the right solution is installed. We are concerned
that reasonably practical is ill-defined and could be used as a means of justifying non-compliance.
As the practicality of installing a system varies depending on property characteristics, it will not be
possible to develop a single metric to assess what constitutes reasonably practical. However an
expert must be consulted and a formal report provided as evidence. A retrofit co-ordinator should
be consulted on the suitability of a replacement system and a clear justification is provided if it is
not reasonably practical to install a zero emission system.

The exemption should also be time limited as the practicability to transition and replace DEH
systems to ZDEH systems will evolve and increase over time.

Replacing DEH to ZDEH is therefore more practicable when conversions consider a fabric first
approach and are built to allow for low flow temperatures, enabling a high performing low carbon
heating system.

Kingspan support the transition of DEH systems to ZDEH systems.
It is important that all options are considered, and the right solution is installed. We are concerned
that reasonably practical is ill-defined and could be used as a means of justifying non-compliance.
As the practicality of installing a system varies depending on property characteristics, it will not be
possible to develop a single metric to assess what constitutes reasonably practical. However, an
expert must be involved and a formal report provided as evidence. A retrofit co-ordinator should
be consulted on the suitability of a replacement system and a clear justification is provided if it is
not reasonably practical to install a zero emission system. The barriers to adoption are varied, they
could include:
- Insufficient insulation or low thermal performance, however this may only prevent the
installation of certain solutions and with investment in the building fabric could be overcome
- Excessive cost to improve the thermal performance to the necessary level, however all
heating systems should be considered including high grade heat from biomass in inefficient
properties
- Limited access or space for the new heating system
- Cost of converting heat emitters
- Access to a low carbon heat source
Innovative and high performance insulation measures should be considered as a means to reduce
energy demand and thus increase the efficiency of heating systems. They should be considered
and promoted as part of this policy. As such, a poor thermal performance rating in isolation should
not be a reason for inaction as solutions exist to enhance the efficiency of all properties.

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