Scottish Ministers acknowledge that new buildings constructed to current building standards already achieve a good level of energy efficiency. However, they wish to explore options to build upon the progress made to date in providing energy efficient buildings with reduced carbon emissions. They have called for a review of the building regulations and the energy standards that apply to both domestic and non-domestic buildings.
Objectives of the consultation
The review is considering the next steps to further enhance the energy performance of buildings and contribute to greenhouse gas abatement targets set under the Climate Change (Scotland) Act 2009. It will consider the following topics:
- Achieving further carbon abatement from new buildings;
- Setting of performance standards in terms of energy rather than emissions;
- Achieving further carbon abatement from existing buildings;
- Improvements to heating systems when replacing boilers;
- Designed versus as-built performance;
- Alignment of change with broader Scottish Government policy objectives;
- Investigate current constraints affecting further emissions reduction;
- Action on EU requirements for 'nearly zero energy' new buildings from 2019/21.
The first stage of the review is looking at the effectiveness and impact that the 2015 energy standards, and the supporting guidance, had, or continues to have, on Industry in delivering energy efficient buildings. Its purpose is to gather views, supported by robust evidence, on the construction or alteration of buildings under the current energy standards, introduced in October 2015. This information will assist in finalising the scope of the review and will help identify any potential barriers to constructing buildings that are both energy efficient and reduce carbon emissions.
This call for evidence closed on 17 September 2018.
To download the consultation document, please follow the link below.
- Scottish Building Regulations: Review of Energy Standards - Call for Evidence
- Original Consultation Page
CIBSE responded to this call for evidence making a number of recommendations, as outlined below.
- Scottish Building Standards should use updated carbon emissions values for grid electricity, such as the ones proposed in the recent update to SAP i.e. 0.233 kg CO2/kWh.
- To significantly improve the quality and performance of new and refurbished buildings and to close the so called “performance gap” incorporation of some form of post occupancy assessment and improvement is needed e.g. some elements from the “Soft Landings” Framework.
- Changes should be made to the Scottish Building Standards to make fabric energy efficiency targets mandatory for non-domestic buildings. To make sure that the building fabric has been constructed correctly the use of thermal imaging should be mandatory within building standards and there should also be a requirement for the contractor to rectify any defects found.
- CIBSE agrees with the proposal to set performance targets in terms of energy rather than just emissions, but believes that perhaps both energy and carbon emission targets should be set.
- The Scottish Building Standards update should incentivise the use of energy storage, such as electric battery storage and heat storage systems, to align with the new Scottish Government Climate Change Plan and to help address the growing issue of demand management within the national grid.
- CIBSE agrees with proposals to investigate provision of Electric Vehicle (EV) charging points or enabling infrastructure within new buildings, however, Section 6 might not be the best place to cover this. If included within Section 6 then the modelling implications would need to be clearly thought through to ensure EV charging is incentivised and not penalised.
- Upskilling and training of installers is required to ensure that complex and new renewable technologies e.g. heat pumps, are installed correctly to maximise the savings achieved.
- Scottish Building Standards could also be more ambitious in terms of sustainability. It would be helpful if Section 7 incorporated some of the themes within BREEAM.
To read the full CIBSE response, please follow the link below.