Scotland Net Zero Consultation – 8 March

There are 135,000 homes in Scotland that use heating oil as their main source of heat.

Whilst we fully support the drive to reduce carbon emissions, we are concerned about the plans put forward by the Scottish government and the impact they will have on households.

Firstly, the proposal sets out to prohibit what are termed as polluting heating systems in all buildings after 2045, and this includes systems using renewable liquid fuels. We believe that systems that use biofuels such as HVO should be permitted, and indeed supported.

Secondly, whilst we support the aim of improving energy efficiency, we do not agree with the plans to introduce a minimum energy efficiency standard to be met in owner occupied homes (which still have a polluting heating system) by the end of 2033, unless they are redesigned in a way that avoids imposing unreasonable cost or disruption on owners of homes that are difficult to improve – for example due to constraints such as solid walls.

Finally, however, we do strongly agree that the use of bioenergy should continue to be permitted in certain circumstances as, for many properties, switching to the government’s preferred choice of a heat pump will be very expensive and disruptive.

According to the government’s online calculator, for many rural properties the cost of installing a heat pump and making all the necessary changes to make it work effectively could exceed £20,000. This is because new radiators are often required, alongside insulation improvements, new piping and the introduction of a new hot water tank. There is also a cost associated with the disposal of the old heating system and storage tank.

Instead, the Scottish government could actively support oil-heated homes to switch to a renewable liquid fuel such as HVO. The fuel works well in all existing oil heating systems following a simple, cost-effective conversion process and delivers a near 90% drop in emissions.

We believe this is a practical and realistic alternative solution for harder-to-treat properties. Fundamentally, it’s about giving households a choice so they can decide whether a heat pump or renewable liquid fuel is the best option for them.