25 February 2021: Draft Heat in Buildings Strategy


To build on policies and actions established in their 2020 Climate Change Plan, 2018 Energy Efficient Scotland Route Map and 2015 Heat Policy Statement, the Scottish Government have released their Draft Heat in Buildings Strategy. This sets out the Government’s proposed pathway towards achieving zero carbon emissions from buildings by 2045, and the steps that will be put in place for this to be achieved. It aims to achieve the following outcomes:

  1. The cost of heating homes and businesses is affordable and those occupying them have a high comfort level.
  2. There is reduced demand for heat and poor energy efficiency is no longer a driver of fuel poverty.
  3. The systems used are smart and resilient and provide a reliable source of heat.
  4. There is a secure supply chain with high value, local, sustainable jobs across Scotland and people have been helped to transition to new, secure jobs as part of a just transition.
  5. Indoor and outdoor spaces are filled with cleaner air.
  6. Heating systems enable and efficiently use Scotland’s renewable energy resources.
  7. Electricity and non-electrical fuels are produced from sustainable sources in a way which is consistent with net zero emissions and biodiversity targets.
  8. Heating systems enable flexible and stable operation of energy networks.


Key notes from Strategy

In their Strategy, the Government acknowledges that the methodology used to create Energy Performance Certificates (EPCs) needs to be reformed so that they can be used effectively as a basis of regulation.

In addition, they recognise that the Energy Efficiency Rating, the primary rating used as the basis of energy efficient standards, can sometimes penalise a homeowner for installing a zero-emissions heating system instead of one fueled by fossil fuels. It is therefore incompatible with the Government’s zero emissions objectives, as set out in the 2020 Climate Change Plan.

These are both issues that SLE and its members have raised with the Government in the past, so we are grateful to see that have been addressed in this Strategy.

However, SLE is concerned to see that the Government is proposing bringing forward the implementation of regulations requiring properties within the Private Rented Sector to meet a minimum standard equivalent to EPC C by 2028. Given the impact Covid-19 has had on the ability for landlords to undertake works to their properties, and the acknowledgement that the EPC methodology needs to be reviewed, we believe that the implementation of such regulations should be halted. This would give the Government time to provide further clarity on the reformation of the EPC methodology and would prevent landlords from undertaking works to their properties which may be penalized when the new methodology comes into force.

Likewise, SLE believes the implementation of energy efficiency legislation relating to owner-occupied properties should also be halted until further clarity regarding the EPC methodology is provided by the Government.

Key questions from Strategy

The Strategy poses the following questions which are of particular relevance to our members:

  1. To what extent do you support the pathway set out for achieving the 2045 net zero target and the interim 2030 target?
  2. What are your views on any risks of unintended consequences from this pathway?
  3. What are your views on the regulatory actions set out in the proposed regulatory framework?
  4. What are your views on the timeframes set out for the application of the regulation set out above?
  5. What are your views on how our Delivery Programmes could support compliance with regulation?
  6. What other mechanisms/support may be required to ensure that regulation is fair and equitable for all?


We would welcome responses to these questions, and the others set out in the Strategy, from our members. Any comments or feedback on this consultation should be forwarded no later than Friday 9 April 2021 to:- Lindsay.duncan@scottishlandandestates.co.uk.

If you would like to respond to the consultation personally, it can be found here

If you respond directly, please save and send a copy of your response to Scottish Land & Estates.