On 31 July 2024, the Scottish Government published a consultation on the Energy Standards – Scottish Passivhaus Equivalent. The consultation closes today, Wednesday 23 October, and Elmhurst are pleased to have responded on behalf of its members.

Consultation Overview

The consultation seeks views on the form and approach that a Scottish equivalent to the Passivhaus standard, implemented through building regulations, should adopt.

The areas covered in the consultation include:

• Definition of Passivhaus Equivalent
• Energy rating methodologies used to demonstrate compliance
• Metrics used in the energy efficiency standards
• Actual versus relative performance targets
• Allowing Passivhaus Certification as an alternative route to compliance

Elmhurst’s Response Summary

A summary of the key responses that Elmhurst has submitted to the consultation are as follows:

• Elmhurst agrees with the Scottish Government’s statements on what a Passivhaus Equivalent could mean.
• In regard to the methodology used to demonstrate compliance with Standard 6.1, Elmhurst fully agrees that only the National Calculation Methodologies (NCM), Home Energy Model (HEM) and Simplified Building Energy Model (SBEM) should be used. To allow alternative energy modelling tools to demonstrate compliance could result in a two-tier compliance industry, where one tool may produce more favourable results than the other.
• Elmhurst supports the proposal for the HEM methodology with a Scottish wrapper to be used to demonstrate compliance with Standard 6.1. Whilst Passive House Planning Package (PHPP) has been shown to produce accurate energy modelling results, HEM is being validated against PHPP and shows good correlation. With this in mind, we do not see a need to allow PHPP to also be used.
• Elmhurst supports the use of relative performance targets, rather than absolute ones, for new buildings. This option gives flexibility in design and form whilst still ensuring that an ambitious level of energy efficiency can be achieved.
• Elmhurst supports the use of regional climate data to set performance targets.
• Elmhurst advocates that all new ventilation systems installed must only be designed and commissioned by members of a competent person’s scheme.
• Elmhurst advocates that all work against the Overheating requirements must be completed by members of a competent persons scheme.
• Elmhurst believes that by retaining the use of the NCM, compliance metrics and relative performance targets for the next revision to the energy standards could be implemented as early as 2026.

Following communication with Elmhurst members on 7 October, linking to our draft consultation response, we have now collated the feedback and have submitted our final response to the consultation.

Further Resources:

To view the consultation, please click the following link: https://www.gov.scot/groups/energy-standards-review-scottish-passivhaus-equivalent-working-group/#passivhausequivalent

For more information on what the consultation covers, please view our recent article on the following link: https://www.elmhurstenergy.co.uk/blog/2024/09/12/scottish-government-consults-on-equivalent-passivhaus-standard/