THE SOLAR SECTOR is urging the Scottish government to rethink its plan to implement the classic Passivhaus standard in Scottish building regulations.

The Scottish Government’s proposed energy efficiency standard for buildings would be obsolete before it comes into force, according to Scotland’s solar energy trade body.

What is more, going ahead as intended could leave solar power absent from new rooftops. This is even after the EU mandated solar technology for newbuild properties – and England is expected to follow similarly.

‘Outdated’ Scottish Building Regulations Plan

The Scottish Government opened a consultation on implementing rules inspired by the international Passivhaus standard this week. In summary, Passivhaus buildings have very high levels of insulation and air tightness, leading to exceedingly low energy demand. It also sets an overall energy performance target, covering space heating, cooking and appliances.

As the paper states, “There is increasing recognition and application of the standard, which contributes positively to overall energy and net zero objectives.” A plan to implement it was announced in early 2023, based on measures set out in Alex Rowley MSP’s proposed Domestic Building Environmental Standards (Scotland) Bill.

The consultation is based on the original, or ‘classic’ Passivhaus standard, which was devised decades ago, when renewables were rare and expensive.

With solar power and smart energy systems now cheap and common, time-of-use tariffs available and road transport becoming increasingly electrified, it is no longer appropriate to look to a standard from a profoundly different time.

Passivhaus Classic has long been superseded by the more ambitious ‘Plus’ and ‘Premium’ forms, which mandate mandating the installation of renewable energy – which could also include solar thermal systems for producing hot water.

But solar power is not mentioned at all in the consultation, which covers both domestic and non-domestic properties alike, nor does it go as far on energy efficiency as the Passivhaus Classic.

Solar Sector Urges Rethink

“We welcome the Scottish Government’s intentions to upgrade fabric and comfort standards and improve quality assurance for newbuild properties. However, we caution against using outdated energy calculations that undervalue on-site generation such as solar power, and the huge opportunities of battery energy storage and smart home energy management,” said Josh King, Chair of trade group Solar Energy Scotland and Director of sustainable energy services company Gensource.

“We would encourage the Scottish Government to align with the EU and the rest of the UK on rooftop solar.”

Current Rules

The consultation follows hot on the heels of the New Build Heat Standard (NBHS), which entered into force on 1 April. Its main effect is to proscribe the burning of fuel for heat, so that no new home in Scotland may have a gas boiler or fireplace. This is intended to lead to the mass adoption of heat pumps.

However, the fundamental problem with NBHS is that heat pumps will not have to be accompanied by rooftop solar power, which would slash operating costs. In contrast, the preceding iteration of the regulations led to the vast majority of new Scottish homes having photovoltaic panels installed, driving down emissions and fuel poverty alike.

The Scottish Government’s latest proposals appear to repeat the very same mistake as the NBHS, only specifying a standard for energy delivered, rather than produced on-site.

England and the EU

The Scottish Government’s direction is misaligned with the EU and England, according to Solar Energy Scotland. It is also inconsistent with last year’s commitment to boost solar capacity across Scotland to between four and six gigawatts by 2030, not to mention the new Labour Government’s enthusiasm for the technology.

The whole of the EU has seen the light and is committed to building solar powered buildings. Agreed this spring, the EU Solar standard will require solar power on all new and commercial and public buildings by 2026 and all new residential buildings by 2029.

Meanwhile, Westminster’s planned Future Homes Standard proposes to completely change the way that energy performance is designed and modelled in new English buildings. The consultation proposes banning gas boilers (following Scotland’s lead), The finalised version is expected to effectively mandate solar on new homes. To be confirmed in the coming months, the allied Future Buildings Standard would do the same for non-domestic properties.

“We welcome the consultation and hope that the outcome will be much more positive towards solar power,” said Solar Energy Scotland Vice-Chair George Baxter, Director of Development at Greenpower. “This would assist the delivery of the Scottish Government’s commitment to a deployment target of 4-6GW of solar energy and provide a long-term stable policy for solar-powered homes and buildings. Doing otherwise could come at the cost of jobs, higher bills and higher carbon emissions.”

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