This blog looks at recently passed legislation that will affect the type of heating system that new build homes will be allowed to use.
What is the New Build Heat Standard (NBHS)?
In April 2024, building regulations will change to prevent the use of ‘direct emission heating (DEH)’ systems in new buildings, and some conversions. These are systems which use more than a ‘negligible’ level of greenhouse gas emissions.
In practice, this means that new buildings can’t use gas or oil boilers.
Instead, heating and cooling systems will need to be supplied from other zero DEH systems like a heat pump, solar thermal storage system or electric storage heaters. A zero DEH system connected to a heat network will also be allowed.
Bioenergy, where electricity or heat is generated from organic matter such as wood, is not considered to be a zero DEH system and therefore won’t be allowed to heat new buildings.
There are some exceptions to the NBHS. It won’t apply to:
- alterations to, or extension of, a pre-2024 building
- emergency heating – a direct emission heating system could only be used when the heating or hot water service system normally used fails
- heating provided solely for the purpose of frost protection, for example heating to stop water pipes from bursting in cold weather or damage to equipment in commercial buildings.
Relatively few new homes are currently built with zero DEH systems, although their use has been increasing. Over the last five years (2018 to 2022), around 80% of new homes built used mains gas boilers as their primary heating fuel and system, and a further 2.5% used either oil or liquid gas petroleum. Only around 10% were served by zero DEH systems.
The Scottish Government argues therefore that a ‘business as usual’ approach is no longer viable and intervention is necessary to stimulate the use of zero DEH systems. As Patrick Harvie MSP, Minister for Zero Carbon Buildings, Active Travel and Tenants’ Rights, has stated:
“By legislating now, we are sending a strong signal to industry that the Scottish Government is serious in moving to a more sustainable net zero future and providing confidence for business to invest in zero-emissions alternatives. “
Local Government, Housing and Planning Committee, 12 September 2023
When will the NBHS apply?
The NBHS will apply to building warrants applied for from 1 April 2024 onwards.
A building warrant lasts for three years unless an extension is applied for.
This means that not all new buildings completed from 1 April 2024 onwards will meet the NBHS as developments will be at different stages of the building process. Some new developments could continue to install DEH systems until April 2027.
Why is the NBHS being introduced?
The Scottish Government says that the NBHS will contribute to its targets to reduce Scotland’s greenhouse gas emissions to net zero by 2045, and its interim target for a reduction in emissions of 75% by 2030.
In 2020, direct emissions from buildings accounted for almost 22% of Scotland’s total greenhouse gas emissions. To meet the targets therefore, emissions from buildings must be reduced.
The NBHS is part of the Scottish Government’s wider Heat in Buildings Strategy, which includes plans to introduce a regulatory framework that will, subject to technological developments and decisions by the UK Government in reserved areas, prohibit the use of DEH systems in all buildings by 2045.
Other developments to support the reduction of greenhouse gas emissions from buildings include:
- improved energy efficiency requirements in building regulations
- planned energy efficiency requirements for existing homes
- support for heat networks through a Heat Network Fund and a regulatory regime for heat networks.
There are also plans to introduce a minimum environmental design standard for new buildings, equivalent to a ‘Passivhaus’ standard, to improve energy efficiency and thermal performance.
What has been the reaction to the NBHS?
To inform the NBHS, the Scottish Government carried out two consultations, commissioned research and met with expert groups.
In response to the second consultation, 62% of respondents supported the general approach to the introduction of the NBHS. However, many respondents who agreed raised potential unintended consequences (see more below).
The Local Government, Housing and Planning Committee considered, and approved, the regulations at its meeting of 12 September 2023. As with the consultation responses, the Committee heard some organisations expressing their support for the proposals, although there were some concerns about their implementation.
One of the main areas of debate was the electrical grid infrastructure capacity – the move away from DEH will result in a greater electrification of heat. There was some concern that the current electrical grid capacity and infrastructure is insufficient.
The Minister told the Committee:
Although the regulations are technology neutral, it is likely that we will experience a significant increase in the use of electrified heating systems such as heat pumps. We continue to work with industry and Scotland’s electricity networks to identify and address the issues that can frustrate or prevent the connection of low-carbon technologies. The Office of Gas and Electricity Markets charging and access review decision and the RIIO-ED2 outcome have provided welcome support for developments that seek to electrify.
Local Government, Housing and Planning Committee, 12 September 2023
Another concern centred around the availability of a skilled workforce to install and maintain zero DEH systems, particularly in rural areas. Associated with this was the impact on small and medium sized companies who might need to retrain staff.
The Minister referred to the Scottish Government’s ongoing work in this area, including its work with Skills Development Scotland on an apprenticeship programme with funding, delivered via the Energy Savings Trust, to support apprentices through the programme and mobile heat pump training unit. The Minister also outlined that existing gas engineers can convert to the skills required to install heat pumps in a relatively short time.
Will new homes cost more to buy?
It can currently cost more to install a zero DEH system compared to a DEH. The Scottish Government estimates that the cost difference between a heat pump and a gas boiler could be around £8,400 depending on design and specification of the system used and the market conditions. This is around 3% of the average cost of a new build home.
The additional installation costs may be passed on to the customer.
However, the Scottish Government argues that by providing certainty to the industry about what is required the standard will support investment in supply chains potentially driving cost reductions. Furthermore, the Scottish Government argues that people buying a new home with a zero DEH system will not have to spend any money retrofitting their home in the future.
What’s happening in England and Wales?
The UK’s Future Homes or Future Buildings Standard is due to be implemented in England from 2025 and would mean:
- ‘Buildings built to the Future Buildings Standard will be zero carbon ready, with the ability to decarbonise over time alongside the national grid’
This policy has been subject to one consultation, but the final details have not been released with consultation on these delayed by several months but still expected by the end of 2023.
Recent UK Government announcements on net zero policy changes made no reference to the Future Homes Standard, but at present, judging by the latest UK Government statement in this area, it is still policy to prohibit the installation of fossil fuel heating in new homes consented from 2025. ‘Zero carbon ready’ means that once the electricity supply is zero carbon, so the related heating will be.
In 2013, the UK coalition Government committed to zero carbon homes by 2016, but this policy was scrapped shortly after the 2015 general election.
In Wales, the Welsh Government published a draft Heat Strategy for Wales for consultation in September 2023, which stated:
We will consult on introducing planning policy that restricts fossil fuel heating in new developments with a firm date communicated as a ban – we’ll explore other mechanisms such as through building regulations to assist in this goal as required, and also engage with UK Government.
Welsh Government, Heat Strategy for Wales, 2023
What’s happening in other European countries?
In the EU, plans have recently been approved for all new buildings to be zero emission from 2028. Zero emission new buildings regulations have already been adopted in various European countries. In the Netherlands, the Gas Act was amended in 2018 to ban the connection of new homes to the gas network and by 2021 90% of new builds were off gas. In France no buildings consented from 2023 can have a gas boiler.
In some countries, such as Norway and Sweden, heat pumps are already the largest source of heating for buildings. The International Energy Agency has argued that, “Heat pumps, powered by low-emissions electricity, are the central technology in the global transition to secure and sustainable heating.”
Kate Berry and Niall Kerr. Senior Researchers, SPICe