Scottish Government – Proposals for a Heat in Buildings Bill Consultation
The Institution of Gas Engineers & Managers (IGEM) is the UK’s Professional Engineering
Institution, supporting individuals and businesses working in the global gas industry. IGEM
was founded in 1863 with the purpose of advancing the science and relevant knowledge of gas
engineering for the benefit of the public.
As a not-for-profit, independent organisation IGEM acts as a trusted source of technical information, guidance and services for the gas sector. In today’s net zero context, IGEM is focused on engineering a sustainable gas future – we do this by:
- Helping our members achieve and uphold the highest standards of professional competence to ensure the safety of the public
- Supporting our members in achieving their career goals by providing high quality products, services and personal and professional development opportunities
- Acting as the voice of the gas industry when working with stakeholders to develop and improve gas policy.
Our role across various industry and governmental groups sees us working directly with gas network companies, manufacturers, consultants, contractors, safety experts, academia, regulators, policy advisors and policy makers, to assess the evidence base and develop informed recommendations on the future of the gas grid.
We welcome the opportunity to respond to this consultation and aim to represent the collective views of IGEM Members and our gas industry stakeholders. Please find our responses below to the questions most relevant to IGEM:
- To what extent do you support our proposal to prohibit the use of polluting heating systems in all buildings after 2045?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
IGEM is broadly in support of the proposal and 2045 target date, provided that the practical means of achieving this transition takes into account the range of energy vectors and technologies available in each area of the country.
Which heating decarbonisation plan is adopted should be based on local assessments, looking at factors such as local infrastructure/supply, electricity grid constraints, building type and fabric, carbon savings potential, consumer preferences and costs – ensuring that the needs of local communities are at the heart of this transition.
IGEM encourages the Scottish Government to fully harness the potential of Biomethane to reduce carbon emissions across the gas network. SGN currently have 35 Biomethane plants connected to the gas network, delivering clean heat to 258,000 homes. There is enormous unrealised potential for organic farm waste across Scotland to be used as a feedstock for local Biomethane production, to serve the needs of local communities, in particular for industries where electrification is not fit for purpose. As such, it is important to clarify whether boilers utilising sustainably sourced Biomethane would qualify as a ‘clean heating system’ within the Bill.
We also see Hybrid heating systems playing a key role and should be encouraged as part of the uptake of low carbon technologies in homes. The Boiler Upgrade Scheme should (BUS) be expanded to cover hybrids with a 50% grant. From a consumer perspective, hybrid heating systems have the benefit of incorporating a technology and a system which people know and understand (the traditional boiler part) and the heat pump which they can get used to over time, allowing for a full heat pump installation in the future.
We support the emphasis on consumers being given choices over their heating solutions – we believe this is a critical factor in ensuring buy-in from the public.
It is very positive to see the consideration given to properties that are harder to heat, such as traditional housing stock, and that special dispensation will be put in place to accommodate properties with additional needs.
- 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)?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
IGEM is in support of the Minimum Energy Efficiency Standard (MEES). It is essential that energy efficiency measures within a property are upgraded at the same time as installation of a clean heating system. The same upgrades should be required even if the property already uses a clean heating system. Current electric technologies (i.e. heat pumps and electric storage heaters) supply heat at much lower temperatures than gas boilers, therefore if the fabric of the building is not designed to adequately maintain the ambient air temperature at healthy levels, this has serious implications for the occupant’s health and financial well-being.
- 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?
Strongly support
Somewhat support X
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
As detailed in our response to question 2, energy efficiency measures must be upgraded in tandem with a new clean heating system. However, we have serious concerns over the affordability for homeowners to cover the cost of these upgrades.
To ensure a Just Transition, homeowners will require significant financial support, time and guidance to meet the requirements. Particularly for vulnerable groups and low-income households. But also for certain types of housing stock that is more challenging to decarbonise, due to the thermal properties of the buildings and space constraints.
- 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?
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose X
Strongly oppose
Don’t know
Manufacturers have expressed concerns that this or any list of requirements may be to0 specific to apply across all homes. There is concern with the proposed inclusion of a requirement for 80 mm of hot water cylinder insulation. The hot water cylinders which currently exist on the market tend to have circa 50-60 mm of insulation. The requirement for 80 mm will force manufacturers to develop new cylinders at a cost to them.
There is a concern which manufacturers have express that these proposed changes could drive up costs which would be passed to consumers. The OEMs suggest as written, the proposals, are out of kilter with Europe including the Republic of Ireland and, will be different from the rest of England and Wales too. This makes it incredibly difficult for manufacturers who will essentially have to develop different product lines depending on which country the cylinder is being installed in.
- What is your view on the initial proposed list of measures to meet the minimum energy efficiency standard?
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose X
Manufacturers strongly oppose, see 4
- 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?
No response.
- Do you think that an alternative approach to setting the minimum energy efficiency standard is required?
No response.
- Do you agree that the use of bioenergy should continue to be permitted in certain circumstances?
1. No, it should be prohibited in all cases.
2. Yes, it should be permitted for those buildings already using it.
3. Yes, it should be permitted for those buildings who have no other clean heating system available.
4. Yes, it should be permitted for those buildings already using it and for those buildings who have no other clean heating system available.
5. Yes, it should be used in wider circumstances (please describe these). Please include any additional comments below. X
Biomethane has the potential to play a significant role in Scotland's strategy for reducing carbon emissions from heating. The potential of green gases, particularly biomethane, in reducing carbon emissions from both communal heating systems and isolated communities, is substantial. Such remote areas which often have easy access to sources of fuel, such as agricultural waste and by-products from distilleries, face greater challenges in terms of energy resilience, and may encounter high costs associated with upgrading the electricity grid.
We understand that SGN is heavily invested in increasing biomethane content in the gas grid to reduce the carbon intensity of the network. We advocate for the continued use of appliances powered by sustainably sourced biomethane or other biofuels capable of achieving net zero, beyond the year 2045.
- To what extent do you support the requirement to end the use of polluting heating following a property purchase?
Strongly support
Somewhat support X
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
Although IGEM is broadly supportive of this idea, there is concern over how this measure may impact housing inequity. Without adequate financial support and a realistic grace period, house buyers on lower incomes may struggle to meet the requirements. There may also be unintended consequences on the ability of would-be buyers to meet mortgage affordability criteria where large loans are required.
- 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?
1. Yes – the grace period should be two years.
2. Yes – the grace period should be three years.
3. Yes – the grace period should be four years.
4. Yes – the grace period should be five years. X
5. No, please provide reasons for your view.
IGEM supports the use of a grace period for purchasers to end the use of polluting heating systems. However, in the absence of widely available interest-free loans, allowing the maximum practical grace period possible is an appropriate choice. The current costs associated with installing a heat pump, for example, upgrading internal system and improving building thermal efficiency, can be anywhere between £10-£20K depending on the complexity of the building.
This is a mechanism where higher income homeowners will be able to save to fund these costs, and lower income homeowners will have to get into debt – this must be considered as part of the Just Transition principles.
In the early years of this Bill coming into action, a longer grace period is favourable. This can be adjusted and reduced over time as the financial mechanisms become more abundant and the clean heating supply chain can adequately meet demand. It should also be considered whether a tiered approach to the grace periods could be adopted to allow for individuals with differing circumstances – whether that be financial circumstances or a more challenging building type.
However, Manufacturers have highlighted there are a lot of unknowns on exactly how the proposals would be implemented and regulated. They have suggested the ‘grace period’ to be five years minimum, especially at the beginning when/if these proposals are first implemented and for first-time buyers. Any shorter and it could put people off from moving house or turn people against the net zero transition. More information is required before industry could agree to the above proposal.
- 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?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
IGEM is broadly supportive of a cost-cap model, to provide assurances to house buyers and financial organisations when making affordability assessments.
However, more information is required to understand exactly how this approach would be implemented and regulated. A level of consumer protection against increasing costs is most likely required, but unless regulated within specific criteria, this could become an expensive policy in the long-term for the taxpayer. Therefore, it would probably make more sense to offer the cost-cap based on household income level, with wealthier households not offered any/as much financial support compared to those who are less well-off or in fuel poverty.
- Which of the following methods of applying a cost-cap do you support?
1. A flat cost-cap.
2. A size-based cost-cap.
3. A purchase price-based cost-cap.
4. None.
5. Another, please suggest below. X
Of the specific options presented, IGEM considers the size-based cost-cap to be the most appropriate, however a cost-cap that is based both on size of the property AND a variable that considers the type and age of the property, would be more appropriate. Albeit more complex, a calculator tool could be designed that modelled the different key scenarios to provide a more accurate cap. A size-based only price cap would not appropriately reflect the cost of upgrading a pre-1900 home when compared to a modern home of the same size.
Consideration should also be given to what is required to achieve healthy ambient temperature levels. An unintended consequence of a cost-cap could be to disincentivise homeowners to adopt the full extent of measures needed for their health and wellbeing (i.e. which may be over and above the MEES), in order to keep their costs to an absolute minimum.
- 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?
Strongly support
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose X
Don’t know
IGEM recognises the need for the requirements to change over time to address polluting heating systems within properties that do not come up for sale. However, there are serious concerns over sweeping powers to introduce new rules without appropriate further public consultation and detailed analysis of the impact and unintended consequences.
The example provided, preventing the installation of new fossil fuel boilers when replacing broken heating systems, is of great concern, as this will likely be a distress purchase. The house owner will unlikely have adequate time to research their clean heating system options, seek out potential appliance and energy efficiency upgrade suppliers and financing options, secure those services and get the work done, and live comfortably in their homes for that duration. IGEM propose that an entirely different mechanism is adopted for distress purchases.
The unintended consequence of this may be households attempting to retain boilers that are not working properly, as they cannot replace like for like.
For the net zero transition to be successful, constant engagement with industry and consumers is vital. If it seen to be that things are being imposed onto people without consent or choice, this is more likely to lead to a strong backlash against net zero policies generally.
The recent controversy in Germany offers valuable insights for all countries transitioning to decarbonised heating. It has highlighted the complexities and political sensitivities involved in transitioning to low carbon heating systems, especially regarding public acceptance and the financial burden on consumers
Described as ‘one of the greatest political dramas in recent German history’, the new legislation
caused unprecedented public backlash which saw coalition in-fighting, public protests, and consumers rushing out to buy new fossil fuel heating systems to replace their old systems ahead of the ban. A move reflective of the fact that 40% of all boilers in Germany are more than 20 years old and will require replacing in the near future.
The move would have banned the sale of almost all new conventional gas and oil-fired boilers by 2024, effectively forcing homeowners to install a lower carbon alternative. However, the ban faced considerable pushback due to concerns over its implementation and financial implications for homeowner.
The new heating Bill was dubbed the ‘heat hammer’ due to the perception that it would ‘hammer’ consumers’ finances if they were forced to replace their gas or oil boilers with expensive alternative systems. The upfront cost for homeowners of installing a heat pump in Germany can range from €9,430 to as high as €53,000. This wide range accounts for variations in heat pump systems and the costs associated with optimising the building’s internal systems and thermal properties. Even with subsidies, typically ranging from €3,000 to €10,000, the costs have been deemed prohibitively expensive, when comparatively, the cost of installing a gas boiler in Germany ranges between €1,500 to €3,000.
The German government's struggles, including decreased popularity among voters and criticisms from environmental groups, underline the challenges in balancing environmental goals with public sentiment and economic realities.
- 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?
Strongly support
Somewhat support X
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
While there is some support to the proposal to require buildings within a Heat Network Zone to end their use of polluting heating systems by a given date, there are concerns. In particular more work and consultation is needed to fully appreciate the practical elements such as the minimum notice period so that property owners in the Heat Network Zone have the time to prepare for the change.
- 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?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
This is seen as a sensible proposal which will help to develop heat network supply chains and give clarity and certainty to industry.
- To what extent do you support our proposal to require occupiers of non-domestic properties to provide information about unused heat on their premises?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
- To what extent do you support our proposal to potentially require buildings with unused heat to provide this to a local heat network?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
- 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
1. Submitting EPCs alone.
2. Sampling a percentage of buildings.
3. A combination of the two. X
4. None, there should be no monitoring.
5. Another method, please suggest below or explain your selected answer.
A combination of monitoring methods would be appropriate to get a better understanding of compliance levels across the country.
However, OEMs have suggested EPCs would most likely be the easiest route to monitoring whether people are meeting the requirements under the Heat in Buildings Standards. The use of EPCs would also provide a clearer and more complete picture as opposed to random sampling which could be an unrepresentative set of statistics. EPCs should be updated with every property sale which would help to identity those properties which do not have low carbon heating appliances or high levels of energy efficiency.
Consideration may be given to mandating that EPCs should be updated periodically such as 5 or 10 years.
The Heating and Hot Water Industry Council ( HHIC), in partnership with major boiler manufacturers, installers and representatives from across the supply chain operate a Benchmark scheme. Since its launch in 1999, the Benchmark scheme has been promoting quality installations, commissioning and servicing of domestic heating and hot water systems. Completing the Benchmark Checklist is a means of meeting the commissioning requirements within Part L of the Building Regulations, helping to safeguard the home owner but also the installer as well. Use of the data collected by the Benchmark system would support the transition to net zero.
- 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?
1. I support relying on market and financial product mechanisms such as mortgages or home/ building insurance.
2. I support extra Council Tax and Non-domestic Rates charges, in future, for those who don’t comply.
3. I support the introduction of civil penalties, in future, if compliance is not achieved.
4. I support a mixture of the above options. X
5. I do not support the suggested enforcement tools, but have another suggestion (please provide below).
6. I do not support any form of enforcement.
Please explain your answer:
IGEM would support a range of options to enforce the Heat in Buildings Standard, however the emphasis must be on ensuring that homeowners who genuinely cannot afford to comply with the Standard, due to for example, the inability to secure finance or experience complications with their installation or building upgrade requirements. Homeowners may also struggle to secure a supplier if supply chain capacity does not meet the level of demand.
Civil penalties should only be used for cases where flagrant avoidance is proven.
- 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?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
IGEM commends the Scottish Government for carefully considering it’s Just Transition principles throughout the proposal. We agree that exemptions must be put in place and we support the idea of providing extra time to those that genuinely require it and ensuring an appeals process is in place.
IGEM supports the concept of an assessment tool, which will help consumers navigate through complicated information and options. It is very encouraging to see the emphasis made in your proposals, on the careful assessment of what types of clean heating systems and energy efficiency measures will be the most technically suitable for different types of buildings.
It is assumed that a household’s inability to pay due to low income/affordability issues, will be addressed through the financial support mechanisms put in place. However, there may be households who are unable to obtain appropriate financing at all e.g. due to credit levels and therefore exemptions or other mechanisms may need to be put in place.
DESNZ have previously stated that around 20% of homes are unsuitable for a heat pump and could be exempt, instead installing air to air heat pumps, infrared heating and storage heating. Alignment between the UK Government and the Scottish Government would be helpful so as to provide clarity to industry.
- Which people, businesses, or types of buildings, if any, should be eligible for a modified standard or exemptions?
Those properties that are using sustainably produced biomethane and, in the future, those properties where renewable hydrogen is preferred as an alternative to electric appliances.
IGEM endorses a whole systems approach to heating decarbonisation, where a range of energy vectors are utilised based on local needs, energy supplies and environmental characteristics.
Hydrogen for heat trials being led by SGN, including the H100 Fife neighbourhood project, are showing great promise. If a positive policy decision on hydrogen for heat is made in 2026, the Standard should be adapted to allow for the installation of hydrogen boilers, particularly in those regions where hydrogen production is or will be in close proximity. Crucially, this offers consumers in those areas the option of a less costly and less disruptive transition to clean heat.
It is also important to note that some businesses requiring high intensity heat for industrial processes will require a hydrogen supply to the building – this presents a potential use case for heating those same industrial buildings with hydrogen.
- To what extent do you support our proposals to give certain people extra time to meet the Heat in Buildings Standard?
Strongly support X
Somewhat support
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
- Which people, businesses or types of buildings, if any, should be eligible for extra time?
Those types of buildings where no realistic clean heating solutions are considered effective/appropriate, until such time as alternative clean fuels or technologies are made available. This is particularly relevant for properties with space constraints e.g. flats and mid-terrace buildings. As well as heritage properties, and those with protected characteristics where clean heat solutions are not viable.
- 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?
Strongly support
Somewhat support X
Neither support nor oppose
Somewhat oppose
Strongly oppose
Don’t know
IGEM is supportive of this proposal, however there are concerns around the electricity system capacity to meet the high levels of demand associated with public sector buildings, such as schools, hospitals and leisure centres. System resilience is essential, it would therefore be prudent to adopt a realistic and practical approach that allows for flexibility in timeline and hybrid technology solutions that provide security of supply, until such time as the local electricity network can accommodate demand.
- We are considering the following further duties on public sector organisations to support planning for the transition by 2038:
a) Placing a new duty on public sector organisations which would, from 2025, prevent them from replacing a polluting heating system with another (unless impractical);
b) Creating a new duty for each public body to develop and implement a plan to decarbonise their buildings;
c) 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 nonstatutory); and/or
d) 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).
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?
Yes
No X
Don’t Know
- Do you agree that the Heat Networks (Scotland) Act 2021 should be amended in light of the passage of the Energy Act 2023?
No response.
- Are there any further amendments to the Heat Networks (Scotland) Act 2021 that the Scottish Government should consider?
No response.