Scottish Passivhaus Equivalent Consultation
Delta Q have submitted our response to the Scottish Passivhaus Equivalent Consultation. The Scottish equivalent to Passivhaus is a proposed Scottish Building Standard that aims to meet the same high energy efficiency and environmental performance. The Scottish Government has committed to passing legislation to implement the new standard.
Delta Q were pleased to see all the main elements of the Passivhaus standard in the consultation and welcome particularly the proposal that Passivhaus would be deemed to comply with the new standard. However, as we went through the document and studied each section we were shocked to see how the proposals veered away from the Passivhaus requirements on many important points. The following proposals stood out:
- energy modelling with the Scottish wrapper of the home energy model – not PHPP
- use of the notional building rather than absolute targets
- the continued flawed idea than somehow ‘compliance’ modelling serves a purpose in its own right and is separate from design and predictive modelling
- vague proposals around heating demand and airtightness targets and the requirement for MVHR
- QA and verification proposals are lengthy and difficult to interpret, but they seem to avoid the basic idea that what is modelled and what is constructed have to match the design and they don’t seem to address the issue of build quality
The essence of the Passivhaus Standard is that low absolute energy targets are set and that they are met through a QA process which links what has been designed, with what has been modelled and what is constructed. The proposals in the consultation seem to me to break this important linkage.
There may be a misunderstanding regarding the smooth progression of this process through consultation and review towards a true Passivhaus equivalent. It is hoped that this is the case, and that the outcome is not merely a case of greenwashing.