The proposed standard, which is set to come into force in 2024, will prohibit any new building applying for a building warrant to make use of a direct emissions heating system. Zero direct emissions heating systems, such as heat pumps and heat networks, will therefore be required both domestic and non-domestic buildings.

The response supports the need to improve the energy performance of new buildings and minimise the negative environmental impacts associated with heating homes. However, concerns remain around the wider barriers to delivery and unintended consequences, including a potential slowdown in the Affordable Housing Supply Programme and the financial and technological risks to tenants, which must be addressed alongside the introduction of the standard.

A range of supporting policies will therefore need to be implemented in parallel with the New Build Heat Standard to ensure this is deliverable and affordable for members and their tenants, including:

• Ensuring that housing associations are able to set rents in consultation with tenants to balance affordability with the need for investment in new and existing homes.
• A significant increase investment in the Affordable Housing Supply Programme to reflect the higher cost of building to the proposed standard.
• Support for the wider supply chain and a clear route map to implementation of new standards.
• An updated Fuel Poverty Strategy which ensure a comprehensive approach to improving energy affordability in Scotland, including further action in reserved policy areas.
• Increased investment in local advice services and wider public engagement to support the roll out of new technologies.