Response 178581086

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2. The Heat in Buildings Standard - covering heating and energy efficiency

1. To what extent do you support our proposal to prohibit the use of polluting heating systems in all buildings after 2045?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don't know
Please include any additional comments below
This is a very poorly thought out proposal until such times as there is a cost effective way of heating houses with solid stone walls and suspended wooden floors. To implement these proposals would mean those living in older houses wouldn't be able to sell their house or would lose a significant amount of money in doing so. The cost of retrofitting insulation is prohibitive and many people living in such houses already accept that they are cold. Heat pumps would make them colder.

I also wonder about standards, sliding older houses are retrofitted with poorly performing heating systems.

2. To what extent do you agree that we should introduce a minimum energy efficiency standard to be met by private sector landlords by the end of 2028 (even if they are already using clean heating)?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know.
Please include any additional comments below
It depends on the standard and how suitable it is for old buildings. We've already seen buildings damaged by previous ill thought out insulation schemes. However, improving living standards for renters is a positive move in principle.

3. To what extent do you agree that we should introduce a minimum energy efficiency standard to be met in owner occupied homes (which still have a polluting heating system) by the end of 2033?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
As before, it depends on the standard and whether it is suited to older buildings.

4. Do you agree with our proposal to set a minimum energy efficiency standard that can be met by either installing a straightforward list of measures, or showing a good level of energy efficiency based on a reformed EPC fabric efficiency metric?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
As before, depends on the proposed measures

5. What is your view on the initial proposed list of measures to meet the minimum energy efficiency standard?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
Retrofitting these measures is not possible in all cases, is very expensive in old stone buildings and makes very little difference to the overall performance of the building, whilst preventing the house from breathing which is how the integrity of the building is protected.

6. Do you think that properties for which most or all of the measures on the initial proposed list are not relevant should be required to meet an equivalent minimum energy efficiency standard?

Please select one item
A. No – these properties should be considered compliant once they have installed all the measures that are appropriate for their building type, even if this is few or no measures
B. Yes – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), and they should be required to install all of these where feasible
C. Yes – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible and cost effective
D. Yes – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible, and they should be allowed additional time to do so.
Please include any additional comments below
These measures are extremely disruptive to a home and require renovation of the interior, therefore it is unrealistic to expect homeowners to undertake these works. However, it would also not be appropriate to say that the building meets the standard.

7. Do you think that an alternative approach to setting the minimum energy efficiency standard is required?

Please select one item
Yes
No
Don't know

8. Do you agree that the use of bioenergy should continue to be permitted in certain circumstances?

Please select all that apply
No, it should be prohibited in all cases
Yes, it should be permitted for those buildings already using it
Yes, it should be permitted for those buildings who have no other clean heating system available
Yes, it should be permitted for those buildings already using it and for those buildings who have no other clean heating system available
Yes, it should be used in wider circumstances (please describe these)

3. Property Purchases

9. To what extent do you support the requirement to end the use of polluting heating following a property purchase?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
This will bring the housing market to a halt. Older buildings will be unsellable and so the onus will be on the seller to upgrade prior to sale, even if that is not the intention. In older buildings that effectively means complete renovation of the building at considerable cost.

10. We are proposing to give those purchasing a property a ‘grace period’ to end their use of polluting heating. Do you agree with this proposal?

Please select one item
Yes - the grace period should be two years .
Yes – the grace period should be three years.
Yes- the grace period should be four years
Yes – the grace period should be five years
No, please provide reasons for your view.
Please include any additional comments below
I don't think there should be a requirement in law. Home owners should be supported and encouraged to change their heating system at such times as they need to, not just because they bought a house. Has there been an assessment of the environmental impact of all the new heating systems and materials that will be needed?

11. To what extent do you support our proposal to apply a cost-cap where people are required to end their use of polluting heating following a property purchase?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
I do support capping the cost but who will pay for this and will it cover all works? The cost of retrofitting my own building is in the tens of thousands of pounds. That seems unrealistic to do for all the buildings like mine in Scotland.

12. Which of the following methods of applying a cost-cap do you support?

Please select one item
A flat cost-cap.
A size-based cost-cap.
A purchase price-based cost-cap.
None.
Another.

13. To what extent do you support the proposal that the Scottish Ministers should be given powers to extend the circumstances in future (beyond a property purchase) in which people could be required to end their use of polluting heating? This could be, for example, preventing the installation of new fossil fuel boilers when replacing the heating in your home or business premises?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
This feels rather punitive in cases where a homeowner is already facing, as you say, a crisis. People don't generally replace heating systems unless they're broken beyond repair.

4. Connecting to Heat Networks

14. To what extent do you support our proposal to provide local authorities (and Scottish Ministers) with powers to require buildings within a Heat Network Zone to end their use of polluting heating systems by a given date?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know

15. To what extent do you support our proposal to provide powers to local authorities (or Scottish Ministers) that require developers to connect new buildings within Heat Network Zones to a heat network?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
It seems much more sensible to initially ensure that all new housing stock is compliant before asking existing and second hand home owners to retrofit.

16. To what extent do you support our proposal to require occupiers of non-domestic properties to provide information about unused heat on their premises?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
Perhaps businesses could be encouraged to do so through incentives.

17. To what extent do you support our proposal to potentially require buildings with unused heat to provide this to a local heat network?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
As above

5. Monitoring and Enforcement

18. We will need to have a way to monitor if people are meeting the Heat in Buildings Standard, and discussed two options for this. Which do you support?

Please select one item
Submitting EPCs alone.
Sampling a percentage of buildings.
A combination of the two
None, there should be no monitoring.
Another method, please suggest below or explain your selected answer

19. We will need to have a way to enforce the Heat in Buildings Standard. We discussed possible options to help achieve compliance. What are your views on these ideas?

Please select one item
I support relying on market and financial product mechanisms such as mortgages or home/ building insurance.
I support extra Council Tax and Non-domestic Rates charges, in future, for those who don’t comply.
I support the introduction of civil penalties, in future, if compliance is not achieved.
I support a mixture of the above options.
I do not support the suggested enforcement tools, but have another suggestion (please provide below).
I do not support any form of enforcement

20. To what extent do you support our proposals to modify the Standard or exempt certain people from the need to meet the Heat in Buildings Standard?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know

21. Which people, businesses, or types of buildings, if any, should be eligible for a modified standard or exemptions?

Please include any additional comments below
Owners of older buildings that are not easy to retrofit and would be colder as a result.

22. To what extent do you support our proposals to give certain people extra time to meet the Heat in Buildings Standard?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
Please include those homes with solid walls and suspended wooden floors

6. Public Sector Buildings

24. To what extent do you support our proposal to require all buildings owned by a Scottish public authority to be using clean heating systems by 2038?

Please select one item
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Please include any additional comments below
This feels like a significant burden on the public purse when we have more pressing priorities in Scotland and a growing budget deficit.

25. We are considering the following further duties on public sector organisations to support planning for the transition by 2038. Please tell us which option(s) you would support.

Please select all that apply
Placing a new duty on public sector organisations which would, from 2025, prevent them from replacing a polluting heating system with another (unless impractical);
Creating a new duty for each public body to develop and implement a plan to decarbonise their buildings;
Placing a new statutory reporting duty on public sector organisations to demonstrate progress towards their 2038 objective (with the potential for the 2038 then to be non-statutory); and/or
Placing no further statutory requirements on public sector organisations (instead relying on their ability to plan alongside our delivery and funding programmes to meet the 2038 objective).

7. Amendments to existing legislation

26. Do you agree with our proposals to include powers in the proposed Heat in Buildings Bill to change the current requirement in legislation for a narrowly-defined renewable heat target?

Please select one item
Yes
No
Don't know

27. Do you agree that the Heat Networks (Scotland) Act 2021 should be amended in light of the passage of the Energy Act 2023?

Please select one item
Yes
No
Don't know

About you

31. Are you responding as an individual or an organisation?

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(Required)
Individual
Organisation