SFHA has submitted evidence to the Scottish Parliament’s Local Government, Housing and Planning Committee which is currently scrutinising proposed amendments to the Building (Procedure)(Scotland) Regulations 2004.

MSPS are considering amendments which would introduce a requirement for developers to provide an “energy and environmental design statement” with building warrant applications and an “energy and environmental construction statement with each completion certificate.

The intention is that requiring submission of these statements will help to address the performance gap between homes ‘as designed’ and ‘as built’.

Any new requirement would commence from March 2028, with the technical standards to which the statements apply, being consulted on in 2025.

SFHA’s submission makes the point that there is a need to better understand the extent to which new build homes are meeting current energy and environmental requirements, and that this should be done in advance of increasing standards further.  The introduction of these statements may drive up compliance with existing buildings regulations, but consideration should be given to the resource implications for local authority building standards teams.

The submission echoes the response to last year’s Passivhaus equivalent consultation – emphasising the need for any amendments to be seen within the context of the housing emergency, and giving due consideration to implications for new supply of affordable homes.  It calls on any future changes to buildings standards to be affordable, achievable and liveable.

You can read the full submission here.