This standard is aimed at reducing carbon emissions from the Scottish building stock which currently creates 20% of Scottish carbon emissions. The focus of this consultation is to collect opinions on the impacts of the removal of direct emission heating (DEH) systems from our new building stock. DEH systems are classed as heating systems used for space and water heating that produce carbon emissions at the point of use, and/or are sited within the building or within the curtilage of the building. The ambition is to switch DEH systems for zero direct emission heating (ZDEH) systems in all new buildings and building conversions from April 2024. In 2020 it was determined through EPC certificates that 80% of new buildings were heated using gas, 3% being oil or LPG and 10% being ZDEH.
The pathway to 2024 will be paved through the use of the Building(Scotland)Regulations 2004 with the new build heating standards being implemented through the building standards. This means the prohibiting DEH systems being installed in any new building applying for a building warrant from 1 April 2024. The foundations have already been laid to support the ambitions of net zero with the update of the building standards to be introduced in December 2022. This puts emphasis on all heating systems in new buildings to be capable of operating at lower temperatures to accommodate ZDEH systems in the future through retrofit. This applies to any new building or conversion applying for a building warrant after 01 December 2022.
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The technology in scope
The Scottish government have determined the technology that falls within scope through the findings of independent research carried out by ClimateXChange (CXC). However the NBHS will take a technology agnostic approach. The following technology falls within scope:
• heat pumps;
• heat networks;
• solar thermal and solar thermal storage systems;
• electric storage heaters;
• electric boilers;
• fuel cells; and
• direct electric heaters (including electric panel heaters, electric fan heaters, thermal fluid-filled radiators, and electric radiant heaters).
As set out within our Heat in Buildings Strategy, heat pumps and heat networks are the two technologies (other than improvements to the energy efficiency of buildings) which have been identified as being no/low-regret options for existing buildings.
The following systems are not considered to be within scope:
• Bioenergy
• Hydrogen
• Direct emissions heating systems
The decisions and responsibilities will lie with the building warrant applicant. However, the Scottish government are consulting on the NBHS to ensure they have considered all the impacts of this regulation. As plumbing businesses are key players in the heating industry and experts in this topic this is an opportunity to voice your concerns or support over the impacts of such a move to the supply chain and to the end users.
To summarise the questions being asked are as follows:
1. Do you agree with the stance and approach to removing direct emissions heating systems from new buildings?
2. Are there any specific situations where direct emission heating systems or bioenergy systems would be required in new buildings?
3. Are there any unintended impacts from this approach that may have been missed? For example, impacts to the supply chain, impacts to particular groups of people.
Please read the full consultation for the full range of questions
