13 Jan 2025
CIH Scotland response to LGHP Committee on Building (Procedure) (Scotland) Amendment Regulations 2024
The Scottish government introduced regulations in 2024 which would amend building standards to facilitate the introduction of a Scottish equivalent to Passivhaus Standard for all new build homes. The Local Government Housing and Planning (LGHP) committee has invited evidence on how effective the regulations would be and whether new requirements could slow down housing delivery.
The details of what the Scottish equivalent of Passivhaus Standard would mean in practice are still under consultation.
While we do not have specific comments on the regulations, we raised concerns with the introduction of a Passivhaus Standard equivalent in response to the Scottish government consultation in 2024. We repeat these concerns in our response to the LGHP committee.
We fully support the drive towards improving building standards for new homes, ensuring that our housing stock is modern, energy efficient and fit for the future. While we don’t have specific comments on the regulations, we would like to take this opportunity to raise more general concerns with plans to introduce a Scottish equivalent to Passivhaus Standard. These comments reflect our response to the Scottish government consultation in October 2024.
The Scottish government has recognised that there is a national housing emergency and there is widespread agreement that a significant increase in the supply of affordable housing is needed to tackle homelessness and ensure that everyone has a safe, affordable place to live.
The latest homelessness statistics have shown further increases in open cases, up eight per cent, and households in temporary accommodation, an increase of nine per cent. The latest house building statistics show newbuild starts and completions across all tenures fell by 17 per cent. In the social housing sector starts were down by five per cent and completions by 25 per cent.
A delay in the Affordable Housing Supply Programme outturn reports for 2022/23 and 2023/24 make it more difficult to track the costs of delivering new affordable homes and the balance between Scottish government grant and borrowing. However, it is clear that inflation, shortages of tradespeople and access to supplies are all pushing up the cost of delivering new homes. A report published in 2023 suggested that in some areas a single affordable home costs up to £300,000. A new Passivhaus equivalent could add thousands to the cost of delivering new homes in the social and private sectors.
We have serious concerns that new standards could undermine the Scottish government’s target to deliver 110,000 affordable homes by 2032 if additional funding is not made available to support implementation. This could worsen the homelessness situation in Scotland and have a negative impact on poverty and equalities. We do not believe that these concerns have been addressed by the Scottish government’s consultation and would like to see a full impact assessment before any changes are introduced. It is also unclear how new standards would align with other policy areas such as the review of accessibility standards for new homes.
Visit the Scottish Parliament's website for more information.
For more information on our response please contact Ashley Campbell, policy and practice manager on ashley.campbell@cih.org.
