The SFHA made the call as part of its response to the Scottish Government’s consultation on the Standard, which closed on Friday 8 March.

On energy efficiency proposals, SFHA has supported the introduction of a new target for space heating demand. With homes of different archetypes, of different ages, spread across a wide geography, it said the SHNZS needs to accommodate a diversity of housing stock. That’s why, the SFHA added, it is supporting the option for the energy efficiency target to be set as a range because a one-size-fits-all target would unfairly penalise RSLs with older, more rural, or non-traditional homes.

The consultation proposes that a minimum energy efficiency standard - defined by a list of measures - should be introduced by 2028 and that properties that do not meet this should not be re-let. Again, the SFHA has cautioned against a one-size-fits-all approach and has suggested the use of different lists for different archetypes, or for the options on the list to be extended. In the context of rising development costs and constrained budgets, no one wants to see stock fail against an unfair standard, it argued.

On the move to clean heating, the SFHA said it supports the introduction of milestones leading up to 2045 that will require a transition to the use of electric heating or heat networks, but wider issues may result in unintended consequences. With electricity prices still much higher than gas, the SFHA warned that this proposal could have an impact on tenant energy bills if adequate support is not available.

The housing body has also called for RSLs to be given discretion to make the right decisions for their tenants and their stock. It said the use of exemptions will be crucial in ensuring fairness and it has also made clear the financial cost of both energy efficiency measures and clean heating for RSLs. For the SHNZS to be part of a just transition, clarity is needed on the support that will be available to the sector, the SFHA added. It said members are having to make tough investment decisions and a situation where new requirements may necessitate unavoidable rent rises for tenants must be avoided.

SFHA’s response to the SHNZS consultation followed discussions with members through the Energy and Net Zero Forum, with RIHAF (the Rural and Islands Housing Association Forum), as part of a standalone webinar with Scottish Government officials, and through individual discussions with a range of RSLs.