Scottish Government launches consultation on the Heat in Buildings Bill

The Scottish Government launched a formal public consultation on 28 November on proposals for the Heat in Buildings Bill which would require changes to the heating and energy efficiency of most domestic and non-domestic properties across Scotland. Consultations on this proposed bill will take place over the next 3 months.

Last week the First Minister stated that:

“Our 2021 Heat and Building strategy committed to introducing legislation to phase out the need to instal new or replacement fossil fuel boilers. Moving to clean heating systems well tackle climate change, reduce the exposure of homes and businesses to volatile fossil fuel prices. But our 2021 strategy also set out the need for the UK Government to take urgent action that includes rebalancing gas and electricity prices and making sure that energy companies themselves are playing their part and delivering this vital transition. We simply cannot meet our legal targets and tackling climate change if we do not end our use of gas boilers”.

We are concerned that this announcement by the Scottish Government and the proposed Heat in Buildings Bill is not considering the total cost to those rural communities, a large portion of which are not on the gas grid and will therefore be asked to invest in potentially expensive, renewable systems to heat their homes. No consideration has been given to the infrastructure required to fit and then maintain these systems. Do we have the skilled engineers living in rural areas of Scotland that will be available at short notice if a heat pump or boiler system fails?

A short search on the internet suggests that we will need to up-skill our workforce very quickly to provide adequate engineers for the new green heating systems proposed. If you look at the Installer Finder on the Energy Saving Trust website, it shows a distinct lack of installers in rural areas like Durness, where the nearest company is located in either Thurso (70 miles away, 4 hours 40-minute round trip) or Ullapool (68 miles away, 2 hours 36-minute round trip). In fact, north of Inverness there are only 4 companies in the Highlands available to install and maintain a renewable energy heating system. This area has approximately 120,000 properties, 72% of which are off the gas grid.

Ground source heat pumps (GSHP) can typically cost between £12k-£30K for a householder. The cost of a new ground source heat pump, including installation costs comes to between £12,000 – £30,000. Including additional digging costs, homeowners can expect the final total costs to reach £14,500 – £34,000 for a horizontal heat pump, and between £17,000 – £45,000 for a vertical heat pump. The installation type will depend on how much land is available around the building for groundwork operations.

To be eligible for funding under the Warmer Homes Scotland programme you need to either be the owner-occupier of the home, the tenant of a private sector landlord, or have a Life Rent agreement in place, and live in council tax bands A-F. You also need to have lived in the home for at least 6 months or be in receipt of a medical exemption form.

Figures taken from the Scottish Fuel Poverty Index created in the summer of 2023 show the stark reality facing rural communities in Scotland. Dumfries and Galloway scores 0.691 on the fuel poverty index, meaning this area is at a high risk of fuel poverty. It also has the highest population of residents over 65 years old and the lowest annual median pay of £24,663. 66% of dwellings in this area also have an EPC rating below C, meaning that improvement is required on these properties to increase their energy efficiency. Upgrades need to take place to the current housing stock in rural areas, which is far below the expected energy efficiency ratings. Local council areas such as the Orkney Islands, Highland and Islands, Argyll and Bute, and the Scottish Borders have the highest percentage of properties with an EPC rating lower than C (58-69%).

We agree that something needs to be done to meet the net zero targets - we are not climate deniers, merely realists who wish to see solid data from the Scottish Government on how they are proposing to fund and roll out the new legislation. We will be closely monitoring the consultations taking place for the Heat in Buildings Bill as it progresses through the Scottish Parliament in 2024, and we urge you to respond to the consultation. 

You can read the full consultation paper here.

Additional Sources

• Microsoft Word - Heat in Buildings Strategy update - letter from Minister to Convenor of NZET committee - October 2022 (parliament.scot): “To meet the buildings sector emissions envelope in the recent Climate Change Plan Update, we estimate that over 1 million existing homes need to switch to a zero emissions heat supply by 2030, and the remainder by 2045 if we are to reach net zero.”
• Minister for Green Skills, Circular Economy and Biodiversity (parliament.scot)

• Written question and answer: S6W-14736 | Scottish Parliament Website: “Due to the recent rise in energy prices and lack of recent SHCS data on fuel poverty, we have published scenario modelling of national fuel poverty rates under the Energy Price Guarantee, at both the current £2,500 level from October 2022 as well as the £3,000 level from April 2023. This modelling estimates that from October 2022 there are around 860,000 households (35%) in fuel poverty in Scotland. This is an increase of 247,000 households or around 10 percentage points from the latest available 2019 SHCS statistics, which showed 613,000 households in fuel poverty (25%). With the increase in the Energy Price Guarantee to £3,000 in April 2023 we estimate that around 980,000 households (39%) in Scotland will be in fuel poverty. While these modelled estimates are not available at Local Authority level, the large increases in the fuel poverty rate will be reflected across each Local Authority in Scotland.”