Leading housing organisations have cautioned that Scottish Government plans to introduce an equivalent to the Passivhaus Energy Standard would significantly worsen Scotland's housing emergency by inflating construction costs while achieving only marginal carbon savings.
The Scottish Federation of Housing Associations (SFHA), Homes for Scotland (HFS) and the Glasgow West of Scotland Forum of Housing Associations (GWSF) said the proposals would add substantial expense to new-build homes. They also criticised the Government's impact assessment as deficient, arguing it fails to fully consider wider effects at a time when housebuilding has fallen to multi-year lows.
The groups warned that pressing ahead would result in fewer homes being delivered and higher prices for buyers and renters. Although Scotland already leads the UK on energy standards for new homes, ministers have been consulting since 2023 on an equivalent to the Passivhaus Energy Standard, with the second-stage consultation closing earlier this month. Sector leaders are urging the Government to retain current performance standards, noting that average emissions from new builds are already down 80% since 1990.
The Government declared a national housing emergency in May 2024. Recent data show private new-build completions are at their lowest since 2018, while new social homes are at their lowest since 2007. Research by the Fraser of Allander Institute indicates Scotland is likely to fall 35,000 homes short of its target to deliver 110,000 social and affordable homes by 2032. Rising costs are a key factor, with housing associations reporting average build costs of around £250,000 per home in urban areas and up to £300,000 in rural areas. Industry bodies fear the proposed rules would further suppress supply across all tenures and push up costs for tenants and purchasers.
SFHA Chief Executive Richard Meade said: "Proposals for a new energy standard risk deepening Scotland's housing emergency at the worst possible time, all for a negligible reduction in carbon emissions.
"Housing associations and their partners have already made significant progress in reducing carbon emissions: homes built today emit 80% less carbon than in 1990.
"Scotland must build 15,693 social and affordable homes each year of this parliament to meet current housing need. The Government is nowhere near this target, and we know part of the reason for this is the cost of building new homes. Adding additional expense to the cost in a time of a housing emergency is unacceptable and will simply lead to more people waiting longer for the homes they need.
"The Scottish Government should maintain existing performance standards which provide a high-level of energy efficiency and give housing associations the confidence to build the safe, warm and affordable homes we desperately need."
Jane Wood, Chief Executive of Homes for Scotland said: "Scotland's housing emergency has deepened over the last three years, with consecutive falls in supply compounding the shortfall of more than 100,000 homes that has accumulated since 2008.
"At the same time, the regulatory burden being imposed by government is continuing to grow, with evidence from our members putting the cost of this since 2021 at circa £37,000 per home.
"It is counterintuitive to want to build more homes but keep making it more difficult and expensive to do so. This makes the need to ensure that any new regulation is proportionate, evidence-based and practical to deliver all the more critical.
"This consultation fails on all counts. Home builders have not been able to fully assess the substantial impacts of the proposals against their pipelines. The consultation launched with incomplete software and cost information which the sector has not been able to rely on, fundamentally undermining the process. We now believe the proposals should be withdrawn."
David Bookbinder, Director of GWSF said: "On top of the increased building costs, there are real concerns over the health implications of creating airtight homes which rely heavily on mechanical ventilation systems.
"As well as these systems needing costly annual maintenance, we know there's a risk of occupants switching them off if they're worried about noise or how much electricity is being used. This obviously affects comfort but is also a significant threat to respiratory health."
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