Response 651207848 to Proposals for a Heat in Buildings Bill: Consultation - Scottish Government consultations

Response 651207848

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

Better than the earlier plan but it lacks detailed analysis of pros and cons of plans

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

Why should tenants be considered above any other sector. Some are poor but many are not.
Why should council owned property be exempted while privately owned not? Many more landlords will simply sell up and tenants will suffer. Also any improvement costs will mean higher rents

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

It is up to the owner and any future owner to decide on heating system.

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

This avoids the problem of different assessors reaching a different value for the EPC rating.

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

WWhy no double glazing and why not allow a fitted carpet on a suspended floor rather than having to face disruption and expense of insulation below the floorboards

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

Older buildings have solid walls and flats usually have neighbours above, below and on most sides. Means heat flow from the property is greatly reduced without any additional measures. Also shutters and heavy curtains are very helpful. Listed buildings cannot retrofit .

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

Please select one item

Yes

Don't know

Please include any additional comments below

See comments after question 6

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 is too much interference with private matters. If people need legislation to make a change in heating method it is likely because the new method is less good than the existing. If alternatives are better [because of advances in design for example] then people will change heating systems. Wait for such progress please.

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

Five years at least.

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

This is the case in England. Obviously very unfair if the owner of an inexpensive property is required to make expensive changes.

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

Too much interference what about Human Rights?

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

Please include any additional comments below

Great if there is a heating network available and connecting to it is done easily by using existing pipes and radiators in the property.

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

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

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

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

Absolutely, listed buildings and traditional cottages must be given special treatment. Giving longer will not suffice.

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

Impossible to fit heat pumps to every flat in town centres without creating eyesores . what about World Heritage Status of Edinburgh City centre, heat pumps hung on external walls.

23. Which people, businesses or types of buildings, if any, should be eligible for extra time?

Please include any additional comments below

See answer to above question.

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

If owners of private property have to do this, why not the Public Sector?

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

Don't know

Please include any additional comments below

Certainly make it clearer

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

Don't know

Please include any additional comments below

Before more legislation, please study how Heat pumps work in our climate where there is often high humidity causing icing on the pipes of a heat pump which takes energy to thaw and evaporate. Nordic countries are cold but the cold is fairly constant which means the air is very dry and icing up of the heat pump does not occur. That is why heat pumps will be much less efficient in the Scottish climate.

28. Are there any further amendments to the Heat Networks (Scotland) Act 2021 that the Scottish Government should consider?

Please include any additional comments below

Plenty which avoid trying to be different from Westminster legislation. Look at what is best, not what is different.

About you

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

Please select one item

(Required)

Individual

Organisation

32. What is your organisation?

N/A