Closing Date: 8 November 2023
Response submitted by: National Insulation Association
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About the National Insulation Association
The National Insulation Association (NIA) represents the insulation industry in the UK with a member base comprised of installers, system certificate holders, and manufacturers who provide a wide range of insulation solutions for homes and buildings. The NIA and its members are fully committed to maintaining and raising standards within the insulation industry.
Section 1: A vision for heat in Wales
Vision: Do you agree with our vision? (Yes/No) Please suggest amendments if you think it could be stronger.
Yes, we agree with the Welsh Government’s vision.
Objectives: The Heat Strategy for Wales policies are broken down into 17 objectives within six groups. Do you agree they adequately cover the areas where Welsh Government needs to focus? (Yes/No) If you think there are any areas missing, please explain what they are.
Yes, we agree with the six areas identified by the Welsh Government.
Section 2: Our enabling framework
Standards: Do you believe the public available specification (PAS) standards are sufficient to ensure high-quality work and a whole-building approach? (Yes/No) Please explain. How can the adoption and implementation of these standards be further encouraged?
Yes, PAS 2035/2030 standards are crucial to ensure a high-quality, whole-building approach to retrofit. The NIA is committed to maintaining and improving quality across the insulation sector so that the true benefits of the installed measures are realised, and the customer and their home are fully protected at all times. We believe that PAS 2035/2030 is a helpful standard which promotes high-quality retrofit and reduces the risk of retrofit projects. Hence, we welcome the plans set out by the Welsh Government to use PAS 2035/2030 standards in all of its retrofit programmes.
PAS 2035/2030 is an industry-led quality standard that provides best practice for retrofit, taking a whole house approach. This provides customers with confidence in the work being carried out, and also prevents poor delivery of measures and costly damage to properties. New PAS standards were brought in after the Each Homes Counts review to safeguard against the damaging consequences of sub-standard installations. Since then, they have been instrumental in improving the quality of installation and customer service across the industry. PAS 2035/2030 focusses on a fabric first approach to home decarbonisation which prioritises vital insulation upgrades as a first step to whole house decarbonisation. It puts whole house retrofit at its heart and sets out a clear platform for sensible, logical retrofit.
Nonetheless, even with the recent revisions which should make the PAS process more streamlined, we recognise that PAS compliance can be costly, especially for small businesses. Therefore, it is important that the Welsh Government supports businesses with these costs and helps them to carry out high-quality, PAS-compliant retrofit. This could include providing more funding within its programmes to cover the costs of PAS compliance. Training and qualifications are another vital element of the PAS framework; hence it is important that the Welsh Government provides support for local businesses so that they are adequately skilled and qualified to carry out PAS-compliant retrofit projects. By providing more support to businesses working towards PAS compliance, this will enable PAS-compliant retrofits to become commonplace across Wales.
Skills: Do you agree that Welsh Government has a role in understanding and subsequently supporting the development of the necessary skills for heat decarbonisation? (Yes/No) Please highlight any emerging skills/roles which we should support.
Yes, we agree that the Welsh Government has a key role to play in supporting the development of the necessary skills for heat decarbonisation. Modelling carried out by the Construction Industry Training Board (CITB) suggests that an additional 12,000 full-time equivalent (FTE) construction jobs will be required in Wales by 2028, the majority to deliver improvements to reduce energy demand in existing buildings. This represents both a challenge and an opportunity for Wales. The retrofit sector in Wales, and the insulation sector more specifically, will need to attract and train new entrants to deliver the volume of installs required to meet net zero. It will also require large-scale training and upskilling of the existing workforce. Retrofit training will demand significant investment from devolved government. Therefore, the NIA would like to see the Welsh Government work with retrofit employers and training providers to widen the provision of retrofit training across the country. This could involve helping employers and training providers to offer subsidised training courses, particularly for roles where there is a shortage, such as Retrofit Coordinators and Retrofit Assessors.
We are pleased to see that the Welsh Government is committed to exploring opportunities for early years and young people to enter the heat decarbonisation sector. There is a clear need for this – according to research by the recruitment brand Reed, current rates of retrofit recruitment will need to triple if Wales and the rest of the UK are to meet our shared net zero 2050 target.1 It is important that industry and government to work together to attract new entrants into the sector. This is something that the NIA is keen to support the Welsh Government with.
The Welsh Government has a key role to play in support the development of the necessary skills for heat decarbonisation in Wales. Targeted investment in retrofit skills will have the added benefit of creating thousands of high-quality and sustainable jobs in communities across Wales. A report published in 2021 by the Future Generations Commissioner for Wales estimated that 26,500 new jobs could be created by 2030 as part of a long-term strategy to decarbonise housing in Wales. The localised nature of most energy efficiency work means that many of these jobs will be created locally within Wales. Hence, Wales can retain the job and growth opportunities offered by the net zero transition.
Costs: Do you agree with the position set out in the strategy that the UK Government should move environmental levies from electricity bills to general taxation? (Yes/No) What additional policies should be implemented to ensure a fairer distribution of costs?
Yes, we agree with the Welsh Government’s plans to rebalance the levies on electricity bills. This is essential to kickstart the transition to low-carbon heat and make sure that it is affordable for consumers.
However, the Welsh Government should also prioritise increased investment in insulation measures as the most effective way to fairly distribute the costs of the transition to low carbon heat. Insulation can significantly decrease the heat demand of a property and cut heating costs. According to research by the Energy & Climate Intelligence Unit, raising the EPC of a property by one SAP band from D to C can reduce space heating demand by 20%.2 Insulation is the most effective way to make home heating affordable because it reduces energy demand and energy bills.
Taking a fabric-first approach is especially important when it comes to the installation of low-carbon heating systems, such as heat pumps. Heat pump efficiency is dependent on the flow temperature at which it operates, running at higher efficiencies when the flow temperature is lower. However, a property can only be adequately heated at low flow temperatures if it has a high thermal efficiency. Therefore, the installation of fabric efficiency measures prior to, or alongside, heat pump installation means a smaller, cheaper heat pump can be installed which will then operate at higher efficiencies over its system lifetime. If low-carbon heating is installed and then insulation added afterwards, consumers may be left with a heating system that is not proportionate with the property’s reduced space heating demand and therefore has capital and running costs that are unnecessarily high. It is vital that properties are as insulated as much possible before installing low-carbon heating systems to ensure they are sized correctly and cost less to run.
The most effective way to ensure that the public can afford the switch to decarbonised heating is by following a fabric-first approach. Insulation will safeguard consumers from increased heating costs, thereby ensuring a just transition to low-carbon heat, especially for those vulnerable groups most at risk of falling into fuel poverty due to energy bill increases.
Section 4: Improving the energy performance of our homes
Do you agree that stronger regulation is needed to encourage the uptake of low carbon heat and more energy efficient homes? (Yes/No) What other interventions must be implemented alongside stronger regulation to ensure no one is left behind?
Yes, the NIA agree that stronger regulation can support uptake of low carbon heat and energy efficiency measures. This is particularly true for Minimum Energy Efficiency Standards (MEES) which require homes to be above a certain EPC. Having higher MEES will encourage more homeowners to invest in the energy efficiency of their properties. MEES are an integral part of improving conditions in the Private Rented Sector whereby tenants are reliant on landlords to invest in energy efficiency measures that will reduce their energy bills and improve their thermal comfort. The UK Government had proposed several amendments to MEES in its 2020 consultation on ‘Improving the energy performance of privately rented homes’. Although it has since abandoned these commitments, as signalled by the Prime Minister’s speech in September 2023, the NIA would like to see the Welsh Government commit to adopting these proposals in Wales. These would improve energy efficiency standards in the private rented sector and improve thermal comfort for private tenants. These proposals include:
- The minimum EPC rating increasing from an E to a C, which would require investments to be made to reach the standard before a property can be rented out. EPC C would need to be reached by 2025 for new tenancies and 2028 for existing tenancies.
- The increase in the cost cap from £3,000 to £10,000 per property, which would allow for investment into measures that have a real impact on the thermal comfort of the property.
- The integration of the fabric first approach, which requires investment in the fabric of the building (lost, cavity or external wall insulation, double windows and doors) prior to other improvements such as heating system upgrades.
Most regulations and targets in the energy efficiency sector are based on EPCs. These underpin our understanding of the efficiency of properties in the UK therefore, they need to be as accurate as possible. The NIA believe that important reforms to EPCs are needed to ensure that households get reliable advice on how to improve their properties. We would support the introduction of similar EPC reforms to the ones currently being proposed by the Scottish Government. These proposed reforms include:
- A separate fabric rating alongside existing metrics to draw attention to the energy efficiency of the property specifically. This supports the fabric first approach.
- A metric for the type of heating system in the property. This will support the transition to low carbon heat as it will highlight the carbon intensity of the heating system as well as the running costs. This enables informed decision making for consumers as we transition towards net zero.
- Improving the explanation of the recommendations given to the consumer to ensure they understand why measures have been suggested and what benefit they offer.
By introducing similar reforms, the Welsh Government could ensure that EPCs more effectively support Wales’ heat decarbonisation pathway by incentivising investment in low carbon heating systems and energy efficiency measures.
Along with this, it will be important for government schemes to target the worst performing or hardest to treat homes first as they may incur the highest cost to the homeowner and be the most dangerous to live in. The effects of exposure to cold homes include poor mental and physical health due to inadequate indoor air temperatures (too cold or too hot), high humidity levels which can lead to mould, high noise and poor air quality. It is estimated that the NHS spend over £540 million each year treating people affected by living in the worst performing properties in England. However, this is a solvable problem, the BRE Group in its’ 2023 report on the Cost of Poor Housing in England by Tenure estimated that of the homes in the PRS experiencing excess cold the average cost to mitigate this is £6,835, which if the MEES reforms were actioned would be under the maximum spend for landlords of £10,000. There are similar average mitigation costs for excess cold across owner occupiers (£6,690) and social homes £3,800). The NIA believe that the worst performing homes need to be supported to improve across all housing tenures and no household should suffer with the effects of poorly performing homes.
Holistic approach to fuel poverty: The Warm Homes Programme has been offering new gas boilers, where appropriate, to those eligible., Do you agree that our future investments in energy efficiency must, where possible, simultaneously support our heat decarbonisation pathway? (Yes/No) Please explain and expand on opportunities to address fuel poverty holistically.
Yes, a holistic approach to fuel poverty which simultaneously supports both energy efficiency improvements and the transition to low carbon heat is crucial. This should revolve around a whole-house, fabric-first approach to heat decarbonisation.
When upgrading or decarbonising a property’s heating system, it is important to assess and upgrade (where necessary) the property’s energy efficiency. As discussed in our response to Question 8, improving a property’s fabric performance will facilitate the installation of a more efficient and cost-effective heating system, thus making the transition to low-carbon heat smoother and more affordable for residents.
A holistic, fabric-first approach is particularly important when it comes to those in fuel poverty, as it ensures that the transition to low carbon heat is affordable. Taking a whole house approach that installs insulation improvements in conjunction with a low carbon heating system will make sure that those in fuel poverty will not see any increase in their heating costs when they transition to a low carbon heating system. As such, a holistic fabric first approach to heat decarbonisation is the best way to ensure that the transition does not place a cost burden on fuel poor households.
Traditional buildings: Do you agree that demonstration projects for historic and traditional building retrofit are needed? (Yes/No) Are there further interventions needed to grow the market for traditional building retrofit?
Yes, we would welcome demonstration projects for historic and traditional building retrofit. These buildings are often avoided as they are perceived as too difficult to retrofit, however this means that they are excluded from the benefits of energy efficiency measures. There is also a significant skills and knowledge gap when it comes to retrofitting traditional and historic buildings. The Retrofit Academy have recently released a new qualification targeted at historic and traditional buildings which is a good step towards addressing this skills gap. The introduction of demonstration projects would be another very useful step as they would encourage new, innovative approaches and the sharing of best practice around hard to treat buildings.
It can be very difficult to get planning permission for retrofit projects on historic and traditional buildings. Thus, it is important that the Welsh Government adopts a joined up approach to retrofitting them which involves Local Authority planning departments in the process. This should help to streamline the process for retrofitting historic and traditional buildings and also make sure that retrofits are compliant with all the requisite planning requirements.
Section 7: Taking action
Our pathway: The strategy is based on the Climate Change Committee’s Balance Pathway. Do you agree with this approach? (Yes/No) Please explain.
Yes, we agree that this is a sensible approach.