Social Housing Net Zero Standard in Scotland

We strongly support the use of a fabric efficiency rating, based on heat demand only. We see this an accurate measure of a buildings fabric performance and is also in line with the Zero Energy Social Housing Taskforce (ZEST) recommendations. It puts the housing stock on an even footing with all properties assessed based on their fabric performance and not the cost of fuel they are using (as is the case with the current EPC’s) The rating, however, must be location neutral to provide an even playing field for all landlords and to ensure those operating in remote and rural locations are not penalised and have to do, and spend more to achieve the rating.

We support Option 1, the use of a target range (71-120) which measures performance against the space heating demand only. A range provides a target is achievable to the majority of the housing stock and will incentivise investment in stock. Alternatively, moving to a fixed target of 71 by 2040 will see much of the stock that cannot meet the standard, at a reasonable cost, will disincentivise investment and could lead to the disposal of housing that cannot meet the social housing target, but could meet the less onerous target for other tenures.

No

We agree that the metric must be on modelled demand, which enables modelling of different options for compliance. It is well established that the current SAP/EPC models are not particularly accurate in terms or modelling energy use, particularly when ventilation systems are installed, or when meters are changed by tenants. For example, if a Mechanical Ventilation System with Heat Recovery (MVHR) is installed in a property it drops 7-8 SAP points which will not only act as a disincentive to ensuring good air quality, but it will also have an unrealistic negative impact on the modelled energy use. Likewise, if a tenant decides to change their tariff, and meter, the property can drop 2 SAP points for something the landlord has no control over. The modelled performance should therefore allow for the exclusion of these anomalies to provide a more accurate assessment of energy use. Modelling must be based on a single version of SAP/RdSAP to ensure continuity throughout the compliance period.

We do believe that 'actual measured performance' is highly valuable, but this can only work if set of measurements can be agreed. In addition, such an approach would have to ensure that a level of uncertainty around project outcomes was not created thereby making landlords nervous of committing the large sums of tenant’s monies for projects.

What could be clearer is how this new standard can fit in with a PAS 2035 approach. PAS 2035 would appear to allow for proper detailed planning of effective measures to stock considering that works may need to be phased but increasing the opportunity for the desired end target is met, even if works are to be done on a phased basis

We agree with this as an alternative route to compliance when a property is 'as energy efficient as reasonably practicable'. It would provide confidence to invest in fabric improvements when the modelled improvement fall just short, and would reduce the chances of stock disposals. However, any minimum standards must be qualified with the phrase ‘where feasible’ as suggested, because some measures, in certain areas, can have unintended consequences, such as cavity fill insulation in exposed areas has the potential to enable water ingress due to the cavity being bridged. The exemptions section needs to be updated to allow for practical limitations such as funding availability and technically feasible.

There is currently a national housing crisis, and the sector is already struggling to deal with what the Scottish Housing Regulator calls, a systemic failure in homelessness services, the removal of any more housing stock from the market must be avoided at all costs. While we understand the reason for having a target date, and minimum standard, the timeframe allowed for having this standard met is very tight given the supply chain issues being faced across Scotland, the readiness of the electricity grid, and the availability of skilled labour, particularly in the island and rural communities. This challenge needs to be recognised by either extending the deadline for all to 2040 or, at the very least, extending the deadline for rural and islands communities. Alternatively, more focus could be placed on a strategic approach for full compliance by 2045.

Some landlords have found the use of MVHR in homes is the best option to improving air quality and reducing the risk of damp and mould. The requirement to have a ventilation strategy generally is a reasonable expectation where fabric improvements have been carried out and no MVHR has been installed, to avoid unintended consequences such as increased humidity, damp, and mould.

We support the use of Option 1. We believe Option 2 does not represent an equitable option for our rural and island communities which will proportionately be required to meet the standard earlier than an area with access to the gas network. Supply chain issues and access to sufficient contractors to carry out the works in rural and island communities will be a challenge by 2030. Many rural and island communities are already struggling with a chronic labour shortage with few, if any, accredited energy efficiency installers operating in these areas to carry out the necessary works by 2030. The deadline for remote, rural and island communities should be extended beyond that of urban areas to accommodate this shortage, not brought further forward.

The metric should be measured against each individual landlord rather than on an area basis. This ensure that all landlords take shared responsibility for achieving the target and that the cost pressure and burden is not met by the few proactive landlords. Each landlord should be measured against targets within their control.

No

Locally owned, locally managed heat networks are a better option for our towns and cities across Scotland than the installation of individual heat pumps. While this will be seen as a major infrastructure project, it is no more a challenge than the work required to upgrade the electricity grid network to cope with the move away from gas to individual heat pumps installed in homes - this network issue will only be made worse with the introduction of EV charging points in the future. Local ownership and control, such as Shetland Heat Energy and Power, allows for the tariff to be set locally to cover cost, on a not-for-profit basis, without the need for shareholder profit. For heat networks to reach their potential the current moratorium on building new incinerators must be reconsidered. The use of the waste heat from these Energy from Waste (EfW) plants should be utilised and used to provide affordable heat to homes. A Zero Waste Scotland report from 2021 (https://cdn.zerowastescotland.org.uk/managed-downloads/mf-xmnre2ta-1678196511d) highlights that the carbon impact of Energy from Waste was 27% lower than waste going to landfill, making the current moratorium bad policy, and bad for the environment. This should also be considered alongside the ban on landfilling Biodegradable Municipal Waste in Scotland from 2025. The report shows that heat only incinerators, rather than combined heat and power plants, are almost as efficient, from a carbon intensity point of view as natural gas plants.
In terms of the mandatory connection, we note this is caveated by accepting that this needs to be where it can be provided at a reasonable cost, but it would be useful to have some mechanism set out to frame that decision making. The other point we would make is that the consultation seems clear that if the heat network does not then proceed the landlord will still be liable for the deadline on that stock being met. It should be noted that the network may not proceed for lots of reasons outwith the control of the landlord and that could happen very near the deadline. Landlords need to be given sufficient time to seek an alternative and funding.

We strongly support the need for landlords to have an element of discretion about which measures to install to ensure they are cost effective and in the interests of the tenant. A just transition from polluting to non-polluting heating is key, we must not make the mistakes of the past and push more people into fuel poverty as we move to zero carbon heating systems.

Having variable targets creates uncertainty and will cause distraction and confusion. Set firm targets and give the sector sufficient time and resources to meet those targets.

Somewhat agree. While understanding that the cost of carrying out the necessary works may be beyond the means of some, having different standards in mixed tenure blocks will create complications for works and inequity in outcome.

A phased approach is the only sensible option to provide time to deal with the complications, and probable legal challenges, that arise when dealing with a mixed tenure block.

Even with the extended timeline it will be a challenge to achieve the standards sought due to a shrinking labour market, struggling supply chain, particularly in remote, rural and island communities, and the planning and modelling that will be required to the whole stock before any of this work starts. We also have a significant mountain to climb in terms of the adoption rate by tenants. There continues to be feedback on low uptake levels to existing programmes of ASHP by tenants. Having the new SHNZS introduced in 2025 is as late as it can be. The sector needs as much notice and time as possible but there is a high level of commitment to reducing carbon; we just need the correct tools for the task.