The Trust expressed particular satisfaction with the “extensive and collaborative process undertaken with the wider construction industry across Scotland” as part of the Working Group, established and managed by the Scottish Building Standards team. 

The Passivhaus Trust was pleased with the direction of travel discussed within the consultation document and was encouraged by a number of the proposals, including:

The amendment of standard 6.1 ‘Energy demand’ to recognise Passivhaus certification as an alternative means of compliance.
Greater focus on building performance, with the use of absolute energy targets, such as space heating demand targets and energy targets.
Stronger compliance and assurance mechanisms, which has been outlined in the proposed compliance handbook. 

But the Passivhaus Trust identified a number of ways the proposals could be better:

Include ventilation losses within the space heating metric so that the metric is representative of real building performance. The Trust has said that “at the very least, this should be an option.”
Set more ambitious airtightness targets: The Trust believes the proposed upper limit of 5 m³/(h.m²) is an improvement but remains too high.
Amend solar PV requirements: The Trust asserts that for domestic projects, PV should either apply across both uplift levels (as is proposed for non-domestic buildings) or be used to compensate for weaker fabric standards instead of stronger ones.
The Trust felt that the decision to enable Passivhaus to be “deemed to satisfy” Scottish building standards is a positive move. But the Trust hopes that the Scottish Government can implement the policy so that it is effective immediately and that other parts of the UK might follow suit. 

At present, the Trust is preparing a detailed response to the Stage 2 Consultation and will be sharing the details of that in the coming weeks, before the consultation deadline on 16 October. 

Jon Bootland, chief executive, Passivhaus Trust, said: “The Passivhaus Trust wholeheartedly welcomes the Scottish Government’s commitment to accept buildings certified to the Passivhaus standard as ‘deemed to satisfy’ building standards. 

“It also welcomes moves towards the use of absolute energy targets and accurate tools such as PHPP.”

Bootland added: “The Trust is pleased that the Scottish Government’s proposals for upgrading building standards are informed by the Passivhaus standard. 

“The proposals represent a very good move in the right direction towards a Scottish Passivhaus Equivalent, with scope to be improved in the future, and we applaud the Scottish Building Standards team for delivering a significant step change for Scottish building performance.”