The Scottish Government's consultation on the Social Housing Net Zero Standard (SHNZS) closed on Friday 8 March. While we all want to see progress towards tackling the climate emergency, SFHA has set out that the SHNZS must be realistic and support RSLs to make decisions in the best interests of tenants. 

On energy efficiency proposals, SFHA has supported the introduction of new target for space heating demand. With homes of different archetypes, of different ages, spread across a wide geography, the SHNZS needs to accommodate a diversity of housing stock. That's why we are supporting the option for the energy efficiency target to be set as a range - a one-size-fits-all target would unfairly penalise RSLs with older, more rural, or non-traditional homes. 

The consultation proposes that a minimum energy efficiency standard - defined by a list of measures - should be introduced by 2028 and that properties that do not meet this should not be re-let. Again, we have cautioned against one-size-fits-all approach and have suggested the use of different lists for different archetypes, or for the options on the list to be extended. In the context of rising development costs and constrained budgets, no one wants to see stock fail against an unfair standard. 

On the move to clean heating, we support the introduction of milestones leading up to 2045 that will require a transition to the use of electric heating or heat networks. But we also need to look at wider issues that may result in unintended consequences. With electricity prices still much higher than gas, this proposal could have an impact on tenant energy bills if adequate support is not available.  

We have also called for RSLs to be given discretion to make the right decisions for their tenants and their stock. The use of exemptions will be crucial in ensuring fairness and we have also made clear the financial cost of both energy efficiency measures and clean heating for RSLs. For the SHNZS to be part of a just transition, clarity is needed on the support that will be available to the sector. We know that members are having to make tough investment decisions and we need to avoid a situation where new requirements may necessitate unavoidable rent rises for tenants. 

SFHA's response to the SHNZS consultation (which you can read in full here) followed discussions with members through the Energy and Net Zero Forum, with RIHAF (the Rural and Islands Housing Association Forum), as part of a standalone webinar with Scottish Government officials, and through individual discussions with a range of RSLs. Thank you to everyone who shared their comments and feedback. 

It is expected that the proposals will next be reviewed by the EESSH2 Review Group, ahead of Scottish Government publishing its final response. SFHA will continue to represent the views of members and will provide updates as the process to finalising the SHNZS progresses.