Launch of Scottish Passivhaus equivalent consultation

The Passivhaus Trust welcomes the launch of the Scottish Government’s consultation on the Scottish Passivhaus equivalent. The Trust will be providing a detailed response to the consultation in mid August and will be encouraging its members and supporters to respond during the consultation period.

Initial feedback

The Passivhaus Trust believes that, while there are some positive options towards a Scottish Passivhaus equivalent outlined in the consultation proposals, what is being proposed could still fall significantly short of the intended aspirations. In response to the consultation, the Passivhaus Trust will put forward suggestions to help inform the choices so that the standard can be seen as genuinely moving towards a Scottish Passivhaus equivalent.

 Jon Bootland, Chief Executive, Passivhaus Trust

The Passivhaus Trust welcomes the inclusion of a proposal for certified Passivhaus homes to be considered ‘deemed to satisfy’ Scottish building standards within the consultation questions (Section 3.6); the Trust also welcomes the consultation’s exploration of quality assurance processes (Section 4). However, the Trust believes that the proposals for modelling tools (Section 3.2) and targets (Section 3.3) are not sufficient to achieve a genuine Passivhaus equivalent. 

To achieve what could be considered a Scottish Passivhaus equivalent, the Passivhaus Trust believes that there are three minimum requirements:

1. Accurate modelling tools: The consultation puts forward (Section 3.2) an as-yet undeveloped/ untested 'Scottish wrapper' for the Home Energy Model (HEM) software developed for the Future Home Standard (England). The Passivhaus Planning Package (PHPP) is a tried and tested modelling  and design tool that the Passivhaus Trust believes should be accepted as a modelling methodology until such time as the Scottish wrapper for HEM can be shown to produce energy forecasts with the same accuracy as PHPP.
2. Effective targets: The Passivhaus Trust strongly recommends the use of absolute targets based on heating demand, peak heating load and EUI (energy use intensity). It argues that the use of relative ‘notional building’ energy targets, as put forward in the consultation document (Section 3.3), will not deliver the performance required to achieve Passivhaus equivalent levels of comfort, indoor air quality and low energy bills.   Absolute targets are one of the key recommendations in LETI's Climate Emergency Design Guide, and have been chosen for RIBA’s 2030 Climate Challenge targets and for many Local Plans developed by many local authorities around the UK; they are also likely to be fundamental to the new UK Net Zero Carbon Building Standard.
3. Quality assurance: The Passivhaus Trust welcomes the fact that alternative compliance and assurance processes, including monitoring and reporting regimes, are explored within Section 4 of the consultation document.

Regarding implementation timescales. the Passivhaus Trust is in favour of a stepped approach to bringing in the Scottish Passivhaus equivalent, with voluntary targets implemented in 2026 and mandatory targets from 2028. This transition period would allow for upskilling and training during a realistic timeframe once the industry has clarity on the exact policy requirements.

Respond to the SPE consultation

The Passivhaus Trust has developed guidance to help with consultation responses.  The Trust is running a webinar on Wednesday 25 September, to support members to respond to the consultation.

 

Further information

Building regulations - energy and environmental standards: consultation on proposed changes

Scottish Passivhaus Equivalent: FAQs

1st August 2024

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Get involved with the UK Passivhaus community

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