Energy UK response to Permitted Development Rights to support the provision of new homes: consultation (Scotland)

Executive summary 

Energy UK welcomes the Scottish Government’s consultation on the potential to amend PDR for domestic air source heat pumps (ASHPs), and the potential for PDR for connections to heat networks, as part of the Permitted Development Rights to support the provision of new homes: consultation (Scotland). 

Increasing PDRs for Air Source Heat Pumps (ASHPs) will encourage the adoption of low-carbon home heating, helping to achieve the Scottish Government targets of ensuring “almost all” homes using zero emissions heating systems by 2045 and no more than 5% of households are in fuel poverty. 

To achieve the 2045 target, the Scottish government must strengthen the proposals in this consultation by adopting the following positions: 

The Scottish Government must strengthen the proposals in this consultation by adopting the following positions: 

• PDRs for the installation of up to two ASHPs should apply to all dwelling types, where detached properties account for just 23% of occupied Scottish dwellings and have the lowest rates of fuel poverty of any dwelling type.  
• ASHPs should be permitted to be used for cooling purposes in cases where cooling is the sole purpose of the ASHP to provide consumers with greater choice over which low-carbon technology mix is best for their property. 
• The size limit on external heat pump units should be removed to provide households with greater flexibility to design clean heating solutions tailored to their property’s needs. 

We welcome the Scottish Government’s consideration of expanding PDRs to heat networks as this would streamline planning and help accelerate their development across Scotland. To successfully remove barriers to development, Energy UK recommends the following: 

• PDRs should remain technology neutral and aligned with the Heat Network Technical Assurance Scheme (HNTAS). 
• Greater clarity on the roles and responsibilities involved in both attainment and enforcement of PDRs. 
• Alignment with regulatory regimes governing other technologies such as ASHPs.