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FOI/202500491714 · FOI/EIR · partially withheld

Flat roof insulation criteria and compliance (Warmer Homes Scotland): EIR release

Published
2026-02-04
Received
2025-11-01
Responded
2025-11-27
Directorate
Energy and Climate Change Directorate
Topic
Energy, Public sector
Exemptions
20, 39(2)

Information requested

Copies of any documents, guidance, technical standards, or assessment criteria used to determine the suitability of properties for flat roof insulation under the Warmer Homes Scotland scheme. This request includes, but is not limited to:

Any written criteria, policies, or decision matrices used to establish when flat roof insulation may or may not be installed (for example, where a roof already contains some insulation); Any guidance issued by the Scottish Government, Warmworks, or their delivery partners on interpreting those criteria; Any internal review notes, audit reports, or quality assurance findings concerning the correct application of these criteria and their consistency with PAS 2035 whole-building assessment requirements; and Any correspondence or briefing papers relating to the decision that “any existing insulation” disqualifies a roof from further insulation under the scheme.

Response

As the information you have requested is ‘environmental information’ for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA. This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Response to your request

As part of your request, I am providing you with the following information:

A copy of the Warmer Homes Scotland contract Technical Specification. A copy of the Warmworks Technical Specification that is shared with installers.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

Detected exemption language

We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA. This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes.

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