On 8 March, two key government consultations for Scotland’s housing sector closed. The Social Housing Net Zero Standards paper and the proposed Heat in Buildings Bill could put considerable pressure on Scotland’s existing housing stock, and the construction sector as it grapples with the widescale retrofit and energy efficiency upgrades that will be required to meet new standards.

While the Chartered Institute of Building (CIOB) supports, in principle, the net zero ambitions contained within each consultation, we have raised serious concerns. In general, and bearing in mind the remaining barriers to widescale uptake of retrofit works in Scotland, implementing these standards, without concurrently considering the full breadth of Scotland’s housing challenges and the resources required to overcome them will have unintended consequences.

In particular, our consultation responses highlight the risks that prioritising clean heating systems, and their mandatory installation, in the absence of requirements to address – and initiatives to fund – building fabric could pose to homeowners and tenants. Instead, the CIOB, and the construction sector, backs a ‘fabric first’ approach, which ensures that heat generated is not lost through poorly insulated buildings.

Given the cost of electricity, installing clean heating systems in the absence of fabric upgrades could leave vulnerable households facing higher energy bills and worsening the fuel poverty crisis.

As the Scottish Government’s 2021 Scottish House Condition survey highlights, the rate of fuel poverty among households using electricity as primary heating fuel was 41%, higher than for households using gas (16%), oil (23%) and other fuel (22%).

As such, there must be adequate, accessible funding in place to address issues with building fabric. Otherwise, we risk putting vulnerable households in a position where they are paying more to heat, effectively, the air outside their homes.

Including all tenures and ensuring that the costs of meeting our net zero targets are not paid by the most vulnerable households in Scotland will not be easy. Ultimately, we need to be working across the entire housing system – and government portfolios – to take an all-hands-on-deck approach to increasing the supply of good quality, energy efficient, affordable housing.

It is critical that we maintain the quality of the existing stock, so we do not haemorrhage housing in a context in which local authorities are declaring a housing emergency. This is particularly true for the social rented sector, as units become ‘unlettable’ under current, or proposed, regulations.

However, plans to simply bolster supply will not be sufficient. The location, size, and accessibility of development must also be carefully considered to ensure that we are creating a housing system that meets Scotland’s needs now and into the future.

These homes aren’t going to build (or renovate) themselves. We also need to consider the skills, people and resources needed to realise these goals.

As anyone who is working in the housing policy space in Scotland can attest, this is a challenging portfolio that is at the intersection of many different, but related, policy challenges from cladding, to RAAC, to energy efficiency, to homelessness and public health, and the ongoing skills gap.

We need a systems-wide approach that brings together the relevant ministers, organisations and experts to facilitate the bold, joined-up, cross-portfolio action that is desperately needed to ensure that everyone in Scotland has a warm, affordable, good quality home.