Call for evidence – Committees – UK Parliament

Closing Date: 25 August 2023

Response submitted by: National Insulation Association

For more information, please contact: info@nia-uk.org

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.

Homes in the UK account for 26% of greenhouse gas emissions and are amongst the least energy efficient in Europe.1 The NIA therefore believe ambitious targets need to be set to address this. This includes the following policy changes:

1. Additional funding and long-term commitment to existing grant and loan schemes. This will ensure wider access for homeowners and landlords to energy efficiency measures. Across all available schemes, low and high-cost measures should be offered to ensure the most appropriate solution is provided to households. Insulation should be prioritised as it supports a fabric first approach, which significantly reduces heat loss from a building and reduces energy bills, whilst also minimising exposure to health hazards. The NIA suggests that though insulation measures should be made available to a wide pool of applicants, given the size of the challenge to decarbonise housing, the worst-first approach can be helpful to ensure households with the lowest EPC ratings and those in fuel poverty are improved quickly. Requirements for suppliers taking part in the schemes must be monitored to ensure their continued contribution, with suitable consequences for targets not being met. Clear and straightforward pathways to funding for applicants and installers will avoid delays, which have historically reduced the effectiveness of these schemes. To prevent the ‘stop-start’ nature that has previously disincentivised engagement from industry, the Government must set out clear processes for engagement with minimal administrative burdens.

2. Minimum Energy Efficiency Standards (MEES) for both new and existing homes. The Government has proposed a target for the Private Rented Sector (PRS) to reach a minimum EPC Band C by 2028 (for existing tenancies2 ), which the NIA supports. However, this should be expanded to cover all housing tenures to ensure progress in energy efficiency. Enforcement of these standards is a crucial aspect of the policy changes that the NIA would like to see. The NIA urges the Government to release the results of the consultation on MEES in the PRS as this would push forward progress and set a framework to follow across other tenures.

3. EPC reform to facilitate energy efficiency upgrades across the UK. The recent Scottish EPC reform consultation set out some important changes that will support the accurate assessment of EPCs, including a new set of metrics for domestic and non-domestic EPCs and greater focus on the fabric efficiency of the building. The NIA supports the use of these metrics and hold the view that by focusing on fabric efficiency the number of homes with poor energy efficiency can be reduced.

1. Poor scheme design. The under-delivery of government-backed retrofit schemes is a result of poor scheme design. Often governments design a scheme to achieve their own political goals, but do not engage enough with the supply chain to make sure that the scheme is deliverable. To avoid this, earlier consultation with key stakeholders who are directly involved in scheme delivery, such as retrofit businesses, is needed. This is important as delivery organisations are often consulted too late in the process, at which point there is little opportunity to influence and improve the design of schemes.

2. Schemes are too short. Another common issue is that retrofit schemes are too short-term, which prevents them from being a success. Manufacturers, installers and the wider supply chain need to invest and prepare for a scheme. For many businesses, this investment is not economically viable for a short time period. There is a lot of paperwork and onboarding involved with working on government retrofit schemes, which is not always straightforward. It also costs a lot in product development and certification for manufacturers and installers. Therefore, if businesses deem the scheme to be too shortterm, they will not invest. Hence, longer term schemes are vital to give industry the certainty and stability to invest in the materials and training required for scheme delivery. Schemes are often finalised and enacted into law only a matter of months (sometimes less) before they are due to commence. This short timeframe does not give the supply chain sufficient time to ramp up and prepare itself to deliver schemes. In the case of ECO4, delays meant that households missed out on over £32.6 million of predicted bill savings, according the ECIU.3 .The delay also had very damaging effects on the insulation industry. Therefore, the NIA would like to see more notice given between the announcement of retrofit schemes and their start date.

3. Schemes require a lot of administration. The NIA appreciates the need to ensure compliance and high-quality work. However, the administrative burden associated with certain aspects of government retrofit schemes can exclude some businesses from engaging. Many new and smaller businesses do not have the knowledge or experience to support the administrative element of the schemes. This limits the scope of delivery because there is not enough competition or volume in the market. While we recognise that some level of administration is necessary to safeguard quality standards, smaller businesses and new entrants need to be supported through the administrative process to ensure that they are not excluded. To deliver the volume of installs needed to reach net zero, the retrofit industry will have to expand massively. Therefore, it is crucial that new businesses, especially those operating according to industry best practice, are supported in their mission to deliver high-quality retrofit.

4. Availability and cost of retrofit assessment/coordination. Skills shortages are common obstacles for government retrofit schemes, particularly when it comes to finding enough highly skilled retrofit assessors and coordinators. For example, the design of the Great British Scheme Insulation (GBIS) as a single measure scheme makes it difficult for jobs to be profitable. All measures delivered under GBIS require a retrofit assessment prior to install. However, the high cost of retrofit assessments and the difficulty of finding qualified assessors means that it is often not profitable for businesses to deliver a single measure to a property. Therefore, the NIA would like to see a focus on multi-measure schemes that deliver whole house retrofit. This will result in greater energy and cost savings for residents and make jobs more profitable for participating retrofit businesses.he volume of installs needed to reach net zero, the retrofit industry will have to expand massively. Therefore, it is crucial that new businesses, especially those operating according to industry best practice, are supported in their mission to deliver high-quality retrofit.

The Future Homes Standard 2025, particularly the changes to Part L and F of the Building Regulations, will provide the baseline for improvements in the sector. It will aim to ensure that new homes produce 75-80% less carbon than existing ones. Whilst the NIA supports this, attention must also be paid to the 28 million existing homes that have inadequate levels of energy efficiency. Currently, 50% of dwellings have an EPC of D or lower according to the English Housing Survey 20224 , meaning that residents have higher energy bills and are more likely to be exposed to negative health impacts of cold homes. The NIA believe that both the worst first and fabric first approach should be followed to address the need for investment in existing homes. Minimum Energy Efficiency Standards (MEES) across all housing tenures are also a key regulatory lever that will drive progress towards more energy efficient housing.

Continued Professional Development and accreditation is vital to ensure that new technology used to insulate homes is safe and effective and does not result in unintended consequences. Local training programmes, qualification and apprentice schemes need to be made available to incentivise younger generations to enter the industry and upskill the existing workforce. This will address the need for a larger workforce to decarbonise housing and stimulate innovation.

However, even where innovative technologies have been proven to be safe and effective, there are still numerous barriers to their large-scale deployment. Therefore, the NIA would like to see greater government support for innovative measures. One of the most accessible routes for innovative technologies is via the “Innovation Measures” mechanism included within some government energy efficiency schemes. The NIA would encourage government to increase its support by raising the cost cap within government schemes and streamlining the process by which a new technology can be formally accepted as an Innovation Measure. The development of new solutions will be key to unlocking greater energy savings and accelerating the transition to net zero. Hence, it is vital that the industry has the support needed to foster ingenuity in the sector.

The current level of consumer protections for low-carbon home technologies varies, with those receiving installations outside of publicly funded schemes often subject to lower standards and protections. The Competition and Market Authority’s 2023 report on Consumer Protection found that while government schemes follow standards such as PAS 2035/2030 offering relatively strong consumer protections, for products installed outside of these schemes the level and robustness of the protections is lower. The report highlighted the risk that consumers can be put off from buying low carbon products as a result, particularly ‘able-to-pay’ customers who are not eligible for existing fuel poverty schemes despite a genuine need for support.

This barrier to uptake of energy efficiency products is concerning as it makes customers reluctant to invest, while increasing the potential of poor-quality installs, which damages consumer confidence further. The NIA is committed to maintaining and raising standards across the insulation industry. Therefore, we support robust consumer protections as they build trust in the sector and in emerging technologies. Uptake of low-carbon home technologies on an enormous scale is required to reach net zero in homes. For this to be achieved, consumers must have confidence in both the quality of low-carbon products and the quality of installations. It is important therefore, that these protections are clearly communicated, straight forward and readily available for the benefit of both installers and consumers alike. As installers are often the first point of contact for consumers when they learn about new technologies, it is important that installers can communicate their protections effectively. Therefore, the NIA advocates for robust protections, working in conjunction with high quality standards. This is the best way to protect consumers and ensure that residents can benefit from the financial, health and environmental benefits of high-quality retrofit.

The most effective way to ensure that the public can afford the switch to decarbonised heating is by following the fabric-first approach. 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%.5 Insulation is the most effective way to make home heating affordable because it reduces energy demand and energy bills.

However, 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 Government has set ambitious targets for the decarbonisation of heat including to install 600,000 heat pumps per year by 2028, rising to 1.9 million per year by 2035. The NIA support these targets but, for the transition to low-carbon heat to be achievable and cost-effective for consumers, it must be accompanied by a national insulation programme of similar scale and ambition. This will ensure homes are ‘retrofit ready’. As part of this national insulation programme, the Government must consider more policies to support and incentivise the installation of energy efficiency measures, particularly in the “able to pay” sector, for instance by supporting innovative green finance mechanisms and leveraging private investment. This support should be combined with a public information campaign to raise awareness of the financial, health and environmental benefits of insulation. 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.

The NIA recognises that EPCs are a useful framework to facilitate energy efficiency improvements. However, the current framework was created 15 years ago when the retrofit landscape was very different.6 Therefore, we believe reform is needed to modernisation the framework and make it fit for a Net Zero context.

To this end, the Scottish Government’s recently published consultation on EPC reform is encouraging and offers some useful proposals. It proposes to introduce three separate headline metrics: a fabric rating, a cost rating, and heating system type.7 This provides consumers with a more detailed information breakdown on the performance of different aspects of their home, which will help consumers to make informed decisions about the best route to improving the energy efficiency of their homes. The NIA supports the introduction of similar reforms across the UK.

A fabric-first approach is widely accepted across government and industry as the most effective approach to retrofit. To reflect this, we would like to see fabric efficiency given more weighting within EPCs as a necessary first step towards decarbonising homes. Fabric efficiency should also be more clearly signposted on EPCs to give consumers a clear idea of their property’s current fabric performance and how this can be improved. The Scottish Government’s proposals to include fabric efficiency as one of three headline metrics on EPCs are welcome in this regard.8

An additional improvement to the EPC framework includes more regular trigger points for assessment. Currently, EPCs are valid for 10 years. However, the energy efficiency landscape is constantly changing as new policies and targets are introduced to drive the transition. The NIA support reducing the validity period of EPCs and introducing additional trigger points for EPC assessment to encourage engagement with current technology. Trigger points include:

• Major renovations, including extensions
• Minor renovations, including replacing windows
• Marketing of a property
• Applications for green finance.

This would allow a more up-to-date and greater coverage of EPC data across the housing stock. It would also provide a more accurate picture of the UK housing stock and its energy performance for policymakers, businesses, and consumers. The Government must support industry to train new energy assessors and upskill existing workers, to increase the number of skilled energy assessors. This would improve the accuracy of EPCs and thereby increase consumer confidence in the reliability of the EPC framework.

All levels of government have a role to play in delivering energy efficiency schemes. Central government is best placed to set direction in terms of policy and scheme design. This should always be done through early dialogue with those who implement schemes, particularly local authorities and retrofit businesses.

Funding for energy efficiency schemes should also come primarily from central government, alongside some match funding from LAs. However, the private sector also has an important role to play in funding energy efficiency schemes, something has not yet been fully explored in the UK. Some international energy efficiency schemes, such as the PACE (Property Assessed Clean Energy) scheme in the US9 and the KfW loans and grants scheme for energy efficiency refurbishment in Germany10, have already been successful in attracting private investors into the retrofit sector.

By leveraging investment from the private sector, these international schemes, have been able to deliver large numbers of energy efficiency measures to households, particularly in the ‘able to pay’ sector, in a cost-effective manner. The Residential PACE scheme in the US has funded energy efficiency and renewable energy upgrades worth a combined $4.2 billion (as of 2019), while at the same time remaining revenue-neutral for local municipalities.11 In this way, private sector funding can pave the way for retrofit at scale.

When it comes to the implementation of energy efficiency schemes, this is usually most effective at a local or regional level, as most energy efficiency work is carried out by local installers; therefore, it makes sense for implementation to be devolved to local authorities and other local actors. Local authorities have a more detailed and nuanced knowledge of their local housing stock. However, there has historically been issues with a lack of resources to efficiently deliver schemes and a need for technical support to meet funding application deadlines. Without this there is a risk of delay which can have negative impacts on scheme reputations for consumers and industry. The Government need to be aware of this and provide additional support to LAs where needed.

• 1 Office for National Statistics (2022) Climate change insights, families and households, UK: August 2022
• 2 Energy Saving Trust (2022) Landlords: how to make your property more energy efficient
• 3 Energy & Climate Intelligence Unit (2022) Government delay to home insulation scheme could cost 56,000 homes £600 each
• 4 Department for Levelling Up, Housing and Communities (2023) English Housing Survey 2021 to 2022: energy
• 5 Energy & Climate Intelligence Unit (2022) Insulation and gas prices: Households are paying the price for slow progress of insulating homes
• 6 Nexus Energy Solutions (2023) The History of the Energy Performance Certificate
• 7 Scottish Government (2023) Energy Performance (EPC) Reform Consultation
• 8 Scottish Government (2023) Energy Performance (EPC) Reform Consultation
• 9 Department of Energy, Property Assessed Clean Energy Programs
• 10 Global Alliance for Buildings and Construction, KFW Loans and Grants for Energy-Efficient Refurbishment and New Construction
• 11 Department of Energy, Property Assessed Clean Energy Programs

Draft Energy Strategy and Just Transition Plan (www.gov.scot)

Closing Date: 16 June 2023

Response submitted by: National Insulation Association

For more information, please contact: info@nia-uk.org

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.

Yes, the NIA agrees with the proposed approach for annual phase targets, which require suppliers to deliver a minimum number of measures in the first two years and reach at least 90% of the target within the relevant phase year. Ambitious targets are important to drive activity and to ensure that as many insulation measures as possible are delivered to those who need it. The minimum delivery requirement of 90% also provides clarity to suppliers on their obligations and encourages them to pursue a high level of annual delivery throughout the scheme.

The NIA agree that measures delivered on or after 30th March 2023 but before the ECO4A Order has commenced, should be classed as early delivery measures, and still contribute to annual minimum requirements and caps under the scheme, provided they are eligible measures. We recommend that the targets are reviewed on a regular basis to ensure that they are at an appropriate level, and that suppliers are adhering to them. Consequences for not achieving the targets should also be made clear.

We support the proposal to allow unlimited carry-over between annual targets for the first two years of the Great British Insulation Scheme as this could accelerate the delivery of energy efficiency measures. If suppliers have the capacity to overspend on their annual targets, then this should be encouraged as much possible. The NIA are supportive of anything that results in energy efficiency measures being installed at a faster rate.

However, if suppliers have exceeded their targets in Phases A and B of the scheme and are therefore ahead of their overall targets going into Year 3, it is important that there is still an incentive for suppliers to meet their Year 3 targets. Wherever possible, suppliers should be encouraged to exceed their targets, and this includes their whole scheme targets due at the end of Year 3. This could potentially be linked to an extension of the scheme, whereby suppliers that have exceeded their targets over the course of the scheme are allowed to carry over surplus measures into any future phases.

Yes, we agree that some level of carry-under is important to aid with the overall flexibility of the scheme. We believe the carry-under mechanism should be used in exceptional circumstances whereby suppliers must have a valid reason for failing to meet their annual targets.

We recognise that suppliers may experience some difficulties in meeting their Phase A targets due to the significantly delayed start to the scheme. Therefore, we would support a higher level of permitted carry-under between Years 1 and 2 of the scheme to account this delay, and any other issues that may arise during the early stages of the scheme. Under the current proposals, there is a risk that suppliers will be unable to meet their Phase A targets. This situation would not just be detrimental for suppliers, who may face penalties as a result, but it would also be negative for everyone else involved in the scheme. If Phase A targets are missed and not carried over, households will miss out on the opportunity of much-needed insulation measures to improve the thermal comfort of their homes. This will also have damaging consequences for the whole retrofit supply chain who will be prevented from accessing crucial funding to deliver insulation measures.

Therefore, we would urge the Government to allow more flexibility in the level of permitted carry-under between Years 1 and 2 of the scheme, so that suppliers, insulation businesses and consumers are not disadvantaged as a result of targets being missed due to factors out of the industry’s control. Greater flexibility is needed for these initial phases in the context of the current energy crisis and the ongoing climate crisis, as it is imperative that insulation measures are delivered to as many households as possible, as soon as possible.

Our members understand the intention behind using Council Tax bands to verify the eligibility of the general group to focus funding support on those households that need it most. However, they raise concerns over relying on Council Tax bands as they are largely out of data having been first valued in 1991 and again in 2003. Though it is possible to request a review of an individual Council Tax band, our members want to raise their concerns in basing eligibility on this when the Government can’t guarantee they are up to date. This could result in unfair exclusion from GBIS funding.

Our members also highlight the potential for delays in the scheme if suppliers are to be involved in collecting evidence on the resident’s Council Tax band for eligibility purposes, as the consultation suggests. This will involve them collecting a council tax bill from residents to prove their banding level. There is a concern that residents won’t keep the annual letter they receive on their council tax and that collecting this information could cause delay in scheme compliance. Our members see this as a potential barrier to delivery.

It was suggested by some members that the use of the Government’s online Council Tax band checker could be useful in facilitating this approach if it is pursued.

We would like to see low-cost measures, like loft and cavity wall insulation (CWI) offered alongside higher-cost insulation measures, such as solid wall insulation (SWI), being offered to private rented households, and as to this degree do not agree with the proposal. According to the English Housing Survey 2021-2022, homes in the private rented sector (PRS) have lower rates of cavity wall insulation (61%) than other tenures of home (71% of owner-occupied homes and 77% of social rented homes),1 and therefore excluding loft and cavity wall insulation for PRS households would restrict the number of eligible insulation measures for this group. Being able to offer both types of measures will mean that homes receive the most suitable measure for that property. Under the current proposals, households in the PRS with uninsulated lofts and cavity walls would be excluded from support. The NIA does not agree with excluding this group of households from accessing crucial energy efficiency upgrades. According to the latest Household Energy Efficiency data from DESNZ, 29% of cavity walls and 33% of lofts in the UK were still uninsulated. Thus, there is still a sizable volume of households that require CWI and insulation to improve their energy efficiency.

The consultation states that landlords are more likely to pass on the cost of installations to their tenants, citing this as a reason not to include lower cost measures in the general group. However, the lower cost options represent a reduced financial burden for both landlords and tenants, and have the potential to deliver significant benefits for both, therefore there is no reason not to include them as eligible measures.

The NIA and our members would like to highlight that landlords in the PRS have varying abilities to invest in their properties through the scheme, as they may be charities or housing associations dealing with multiple landlords in one building. There will also be situations where landlords are not investing in their properties and local authorities are not adequately enforcing this, it is the view of our members that these tenants should not be left without support and should be eligible for GBIS funding. There is also a portion of tenants in the general group that are experiencing fuel poverty but are not classified as fuel poor under the official definition and therefore do not benefit from additional support. This includes tenants living in LSO areas, receiving mid-market rent, and relying on electric heaters for warmth, pointing to the wider issues in the PRS regarding high rates of fuel poverty and a gap in support for energy efficiency improvements2. Until the government respond to the 2019/2020 consultation on Minimum Energy Efficiency Standards, which would mandate landlord investment in their properties, tenants in the PRS need more support to improve the properties they rent.

The private rented sector experiences significantly higher rates of fuel poverty than other tenure types, with 24.1% of PRS households estimated to be in fuel poverty, according to the latest available data.3 As this data is from 2021-22, prior to the steep rise in the energy price cap, it is highly likely that there are now many more PRS households either in fuel poverty or at risk of falling into fuel poverty as a result of the ongoing energy crisis.

Consequently, the NIA believe it is crucial that loft and CWI insulation are included as options for the general eligibility group in the PRS as part of GBIS funding. This would offer an avenue through which fuel poor households can access additional support to cut their energy bills and improve their thermal comfort. Since the PRS suffers from the lowest rates of energy efficiency and highest rates of fuel poverty, it is vital that households in the sector are eligible for all available measures, including loft and cavity wall insulation.

The NIA has concerns about the current proposals for the Great British Insulation Scheme and their implications for the scheme’s interaction with the Home Upgrade Grant (HUG).

The scheme includes a 20% uplift for rural off-gas properties. However, under the current proposals, this uplift will apply to Scotland and Wales only, not England. The reason given for excluding England from the uplift is because of the ‘overlap in rural areas with the HUG 2 scheme’.4 However, the markedly different eligibility criteria between HUG 2 and GBIS means that, in practice, the overlap between the two schemes will be limited. While HUG 2 is targeted at low-income households, up to 80% of households targeted by the GBIS are set to come from the general eligibility group, not the low-income group. Therefore, a substantial majority of GBIS households will fall outside of the HUG 2 support framework. A 20% uplift is needed for these properties that cannot access HUG 2 funding because of the scheme’s low-income eligibility criteria.

With the current proposals to only apply an uplift to properties in Scotland and Wales, it is likely that installers may target households in Scotland and Wales at the expense of properties in England. This could result in rural off gas properties in England missing out on essential energy efficiency upgrades. This risks creating geographical inequality in energy efficiency and fuel poverty rates between different nations of the UK.

The NIA suggests that the uplift is extended to apply to England, Scotland and Wales rather than not being provided at all. If the Government does not include a 20% uplift, it risks unfairly penalising rural, off grid homes in the general eligibility group. As well as being more remote, these properties are often hard to treat, meaning installers generally face higher installation costs. If there is no uplift to account for these increased costs, then it might not be viable for installers to deliver insulation measures to rural off gas properties, therefore these homes could miss out on much-needed energy efficiency upgrades. The Government’s annual fuel poverty statistics show that off gas properties suffer from much lower energy efficiency and much higher rates of fuel poverty than on gas properties. Only one-third of off gas properties are EPC band A-C and 20.1% are fuel poor.5 By not applying an uplift to off-gas properties in England, this policy risks excluding some of the most vulnerable people and the least energy efficiency properties from support. Therefore, it is critical that the scheme includes a 20% rural uplift to help cover the additional costs of dealing with rural off gas properties.

With the scheme in its current proposed format – as a scheme delivering primarily single insulation measures – it is reasonable to only have one notification template for measures. Having separate templates for measures and projects is not necessary for a single measure scheme and would add unnecessary administrative complexity.

However, we would reiterate that we do not agree with the proposals to limit households to single insulation measures. We understand why the limit of a single insulation measure applies to low-income households eligible for ECO4 funding, as they can receive a deeper, multi-measure retrofit through the ECO4 scheme. However, for the general eligibility group that cannot access multi-measure funding in other schemes, this encourages a piecemeal approach to retrofitting, which isnot as effective as a multi-measure whole house approach. This is widely recognised as best practice across industry and within the PAS 2035/2030 framework. Insulation measures are far more effective at reducing bills and carbon emissions when installed as part of the same whole house package, rather than individually. For instance, in a draughty property, the energy efficiency benefits of installing cavity wall insulation (CWI) are limited if there is no draught proofing to accompany it because the property will still lose high levels of heat through the doors and windows. Hence, the NIA would like to see a package of multiple measures offered under the scheme, as in many cases, different measures can interact to significantly improve a property’s energy efficiency.

We would urge the Government to consider committing more funding to the GBIS to enable homes to receive a deeper, multi-measure retrofit. As a result of recent price increases, many households, even in the general eligibility group, are struggling to afford high energy costs. Annual fuel poverty statistics in England for 2023 show that the number of households that spend over 10% of their income on energy costs is projected to double in 2023 to 8.83 million households.6 This suggests that there is a need to extend the support offered for households to install energy efficiency measures to prevent further people falling into fuel poverty.

Moreover, investment in home insulation has long-lasting financial benefits not just for consumers, but for government as well. Research by the Energy and Climate Intelligence Unit has shown that, had the Government maintained its support for home insulation instead of cutting it in 2013, it could have saved £18 billion spent on subsidising energy bills over the course of the Energy Price Guarantee.7 In this way, more government investment in insulation in the short-term delivers excellent value for money for the taxpayer in the long-term, as well as safeguarding against the economic and social impacts of future energy price spikes. Therefore, we would like to see the Government provide more funding for the GBIS to facilitate a multi-measure, whole-house retrofit that will see individual households benefit from a much greater reduction in their energy costs.

If the Government decides not to increase the current level of funding for the scheme, then we recognise that some properties will be restricted to single measures due to the limited amount of funding available per household. However, in certain situations, it will still be possible to deliver multiple low-cost measures within the scheme’s current funding constraints. For example, in the case of an easy-to-treat cavity wall property with an uninsulated loft and draughty windows, we believe it should be possible to combine CWI, loft insulation and potentially draught proofing. These are all low-cost measures, and a package that combined them all would still be significantly cheaper than installing a single higher-cost measure. Therefore, we do not agree with only offering single insulation measures in situations where multiple low-cost measures could still be delivered at a low combined cost.

The NIA does not agree with imposing a cap on innovation measures, as it is important to encourage innovation within the industry, which can drive improved outcomes for businesses and consumers. If the retrofit sector is to meet its deliver on its ambitious net zero targets, then it must continue to evolve and grow. Innovation is key to this.

There are many households that still require insultation as discussed in our response to Question 5 but retrofit businesses can face various barriers when trying to introduce innovative new materials and installation techniques. For our members and other innovators in the sector, innovation measures, via schemes such as GBIS and ECO4, offer a vital route by which they can bring exciting new products to market. If an innovation measure is shown to deliver improved outcomes compared to its standard counterparts, then there should be no cap on the percentage of a supplier’s obligation it can make up.

Innovation is vital to the future growth of the retrofit sector and for addressing the needs of many households in accessing this work; therefore, it is vital that the Government fosters innovation and ingenuity within the industry.

The NIA agree with this. Our members call for Ofgem to reduce complexity in the scheme and therefore minimise delay by keeping forms similar to those used for ECO. They also point out the importance of allowing the submission of tenures and completed instalments of eligible measures in bulk so that where they are fitting instalments into a high rise block of flats suppliers can submit compliance in bulk rather than individually.

Our members bring up the need for more specific guidance on work carried out on blocks of flats as currently individual leaseholders must all agree to have it carried out. Often, leaseholders live abroad and rent out their properties making it more difficult to consult with them. A suggestion from our members is the use of a Property Management Company or Committee that could facilitate this rather than relying on individual leaseholders.

We believe that draught proofing is missing from the list of eligible insulation measures.

The effectiveness of other insulation and energy efficiency measures is drastically reduced if a property does not have adequate draught proofing. The primary aim of the ECO+ scheme is to save a large number of households money on their energy bills through the installation of insulation measures. However, there is little point in cavity wall and loft insulation if all the property’s heat escapes through draughty windows and doors. Draught proofing is often the first area of concern for many of the vulnerable households our members engage with on the ground.

For a significant number of UK properties, building regulations mean they are not able to benefit from many energy efficiency improvements. This is particularly true for leasehold flats and listed homes. For many of these properties, draught proofing is one of the only options available to them if they want to lower their energy bills and make their home warmer.

Therefore, we would like to see draught proofing included as a low-cost, high impact measure that can be installed alongside other low-cost measures, as without adequate draught proofing, the financial and environmental benefits of these other measures is greatly reduced.

The NIA is generally supportive of the revisions to PAS 2035/2030. We believe that high quality standards are essential to safeguard consumers and promote best practice across the industry. However, we recognise that PAS is not perfect and that some revisions are necessary to ensure that PAS works best for insulation businesses on the ground. If we are to deliver high quality, whole house retrofit at scale, it is critical to strike the right balance between quality and efficiency. Therefore, the NIA welcome PAS 2035/2030 as a crucial quality standard and believe that the latest revisions will benefit industry.

While necessary, PAS compliance can be costly and time-consuming for insulation businesses; therefore, we welcome efforts to streamline the PAS process and lessen the administrative burden of compliance. Most of the revisions seek to make the PAS process more efficient, which is something we are broadly supportive of, as long as improved efficiency does not come about by diluting quality standards.

Please see a summary of the revisions below and our response to them on your behalf.

Removal of Risk Pathways

The main change is the removal of risk pathways to simplify the PAS process (as shown below), but the key roles and responsibilities throughout the process remain similar.

The NIA supports removing the risk pathways as it should make PAS compliance easier and remove unnecessary complexities from the process. The key implications of the removal of pathways for different stages of the process is shown below.

• Assessment: Projects would now follow the same assessment process as the previous Path B route. Thus, assessment would require a basic building assessment and more details to create an accurate RdSAP/SAP/PHPP energy model.

• Design: The design requirements across different pathways have been standardised to simplify the process. The general design requirements under PAS 2035 are now:Complete and detailed design for the measure(s) + improvement options evaluation + heritage significance assessment + ventilation assessment & upgrade (Annex C) + medium-term improvement plan + protected building design in accordance with BS 7913 + airtightness strategy for some projects

• Advice: Advice should be given at more points throughout the process, from inception through to handover. Advice requirements have also been standardised across pathways.

Other Amendments

Alongside the removal of risk pathways, there are a number of other minor amendments.

1. Contents of a Medium Term Improvement Plan are now a requirement in all retrofits rather than guidance.

The NIA is generally supportive of this change, as Medium Term Improvement Plans (MTIPs) are valuable and multi-purpose documents that set out a future strategy to improve a building towards net zero. Making MTIPs a requirement rather than guidance will strengthen the role of PAS 2035 in helping the UK to achieve net zero in the buildings sector. 80% of the UK’s housing stock by 2050 is already in existence and many of these properties will require future retrofit down the line to reach net zero.

MTIPs also provide invaluable data on the current environmental performance of a building and what changes should be considered in future to further improve the property. Therefore, they are excellent sources of building-specific data about the housing stock that can be used to inform future retrofits.

2. Removal of the Retrofit Advisor role pending improved qualifications in this area. Retrofit advice has not been removed from the PAS 2035 process and is delivered by other retrofit professionals.

Retrofit advice can easily be given by other retrofit professionals, so the NIA supports removing the Retrofit Advisor role in the interim while improved qualifications are brought forward in this area. We look forward to the timely introduction of improved qualifications.

3. Clauses have been included to facilitate scale retrofit by allowing Retrofit Design to commence based on Assessments of archetypes.

The NIA recognise the economies of scale that can be gained by allowing Retrofit Design based on assessments of archetypes. However, it is important to recognise that each building is different and requires an approach to retrofit that is tailored to its specific needs. It is important that retrofit designs are still building-specific to avoid the risk of unintended consequences that can arise from overly generic retrofit solutions. Hence, while we acknowledge that there are benefits in terms of efficiency to conducting assessments based on archetypes, it is vital that these improvements in efficiency do not at the expense of quality.

4. Requirements and guidance around moisture in buildings has been brought in line with language in BS 5250.

Management of moisture is a central concern for any retrofit project that seeks to improve the thermal performance and airtightness of a building. Therefore, the NIA supports bringing requirements and guidance with BS 5250 which controls condensation in buildings.

5. Explicit inclusion of airtightness as part of insulation retrofit in both PAS 2030 and PAS 2035. Requirements to produce an airtightness strategy for some fabric projects, which may include setting of an airtightness target and air leakage testing. However, airtightness testing is no longer normative as part of the assessment.

The NIA agrees with the increased consideration the revisions give to airtightness and minimising air leakage. Airtightness is a vital measure of the thermal and environmental performance of a property. When complemented with adequate ventilation and moisture control, improved airtightness can significantly improve the condition and thermal comfort of a building.

6. Clarification of what happens in the PAS 2035 process if historic significance is identified. A new Annex E is included, which contains detailed information about how to assess the significance of a building.

Protected buildings and those with historic significance can pose lots of problems when it comes to retrofit. Therefore, the NIA welcome more clarity and detail on how to assess significance and what happens if historic significance is identified. The inclusion of Annex E also contains useful additional detail about assessing significance. Historically significant buildings can be very complex to retrofit and often miss out on energy efficiency upgrades as a result. However, retrofitting them will be necessary as we move towards net zero and is also important to improve the thermal comfort of the residents living within them. As such, more clarity within PAS on how to effectively assess and retrofit significant buildings is much-needed.

7. Clarification of the role of the Retrofit Coordinator, including site visits and recording of non-compliance. There is now a requirement that the Retrofit Coordinator carries out site inspections during the project which should include a minimum of one visit.

The Retrofit Coordinator is an extremely important role within the PAS 2035 framework, so it is good to see more clarification on the requirements and expectations for the role. We support the introduction of a minimum of one site inspection during a project to ensure high quality retrofit and compliance with PAS.

8. Further Monitoring and Evaluation references the new BS 40101 Building Performance Evaluation, and Monitoring and Evaluation is now considered from inception through to completion.

The NIA support the move to consider monitoring and evaluation throughout the project cycle. Adequate evaluation is important to ensure that a retrofit project delivers on its intended outcomes and the building performs as designed once the project is completed. More monitoring throughout the process may enable potential issues to be identified earlier in the project. The reference to BS 40101 brings PAS 2035 into line with the latest improvements in building monitoring and evaluation, which we see as a positive step.

Query for Commenters

The BSI also asked respondents to provide their views on the following question:

What is an appropriate transition period for the adoption of the new PAS 2035:2023 and PAS 2030:2023 standards, allowing sufficient time for businesses and other industry bodies to comply with the updated requirements? Please submit your views as a general comment.

Many PAS-accredited businesses are already delivering long-term retrofit programmes, such as ECO4, SHDF 2, HUG 2, which are due to run until 2025 or 2026. These projects have been procured, designed and delivered to current PAS 2035:2019 standards. Changing mid-programme to new standards may not be feasible or practical, and may add unnecessary complexity to projects. Therefore, the NIA believe that a reasonable transition period is necessary to allow industry, who are already delivering ongoing long-term projects, time to adapt to new delivery standards.

Another issue is that there will be limited capacity within accreditation bodies to facilitate industry-wide updates to certification within a limited timeframe. The current relevant certification for installers is 2030:2019, which would need updating in line with any new standards. Delays in certification updates caused by a lack of capacity within accreditation bodies could leave many installers unable to provide PAS 2030:2023 certification initially and prove their compliance to new standards. This could be very damaging for individual businesses who might miss out, and the industry as a whole.

Draft Energy Strategy and Just Transition Plan (www.gov.scot)

Closing Date: 9 May 2023

Response submitted by: National Insulation Association

For more information, please contact: info@nia-uk.org

About the National Insulation Association

The National Insulation Association (NIA) represents the insulation industry in Scotland and across 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.

What more can be done to support the development of sustainable, high quality and local jobs opportunities across the breadth of Scotland as part of the energy transition?

The NIA believes that the best way to support sustainable, high quality and local jobs in Scotland is through long term policy commitments, and investment in the energy efficiency industry.

With sufficient targeted investment, Scotland can benefit from the substantial employment opportunities presented by the transition to net zero homes. Retrofitting Scotland’s buildings could create as many as 108,000 jobs over the next 12-20 years, according to a report commissioned by the Scottish Trades Union Congress.1 These jobs will be environmentally, economically and socially sustainable because energy efficiency improvements reduce carbon emissions, lower energy bills and create warmer, healthier homes for residents. Insulation jobs are also high quality, skilled trades that pay well. According to Indeed, the average salary for an insulation worker in the UK is £34,2452 – above the national average. Most jobs in the insulation sector do not require a Level 6 qualification (undergraduate degree or equivalent), so employment in this sector will help to level up communities in Scotland by providing high-skilled and well-paid technical employment for school leavers without a degree. In addition, most energy efficiency work tends be localised; therefore, installations will likely be carried out by Scottish installers and businesses, thus ensuring that employment and growth opportunities remain within Scotland. There is also a significant opportunity for job creation in low-carbon manufacturing in Scotland, particularly in the manufacture of energy efficiency products such as insulation materials. In this way, investment in energy efficiency creates sustainable, high quality and local jobs.

Long-term policy certainty is also crucial for creating jobs that are sustainable. In the past, frequent changes in government policy and short-term funding schemes have contributed to a boom and bust culture within the insulation industry. Developing a national retrofit strategy and committing to longer-term funding schemes would create the policy certainty that industry needs to invest in training and skills. It would also instil a level of confidence amongst consumers to make energy efficiency improvements to their homes. This would ensure that employment in the energy efficiency industry is secure, high quality and sustainable.

To benefit fully from the future job opportunities and growth potential offered by the net zero transition in the energy efficiency sector, Scotland will need a robust supply chain with adequate capacity to install the energy efficiency measures needed to meet net zero. In order to grow the supply chain, it is vital that the Scottish Government supports Scottish insulation businesses by investing in skills and training.

This investment must be complemented by targeted information campaigns and careers advice to encourage new entrants into the sector. It is very encouraging that Scottish colleges offer an insulation apprenticeship – something that is not yet available in England. However, uptake has been minimal so far, which highlights the need for better marketing of apprenticeships and other opportunities within the insulation industry. This correlates with research conducted by L&Q which found that only one in ten children between the ages of 16 and 18 would consider a career in construction.³ To address this, the Scottish Government should introduce more signposting in schools and colleges about the opportunities in the insulation sector and the potential routes into the sector for young people. The insulation sector is a highly skilled, well-paid sector with a strong social and environmental purpose – to reduce fuel poverty and mitigate climate change. This should be emphasised more to change perceptions about the industry and attract new entrants. Attracting and training new entrants is critical if the industry is to deliver the volume of installs required to meet net zero.

The NIA is already working with the Energy Skills Partnership (Construction) to explore how the insulation industry can help Scottish colleges improve apprenticeship uptake. We believe the Scottish Government also has a central role to play in supporting Scottish colleges to market these apprenticeships, along with other training opportunities in the insulation sector. The NIA would like to offer our support to facilitate the Scottish Government’s work in this area.

What further government action is needed to drive energy efficiency and zero emissions heat deployment across Scotland?

The main action required from the Scottish Government to drive energy efficiency and zero emissions heat deployment across Scotland is to commit to further investment and action on retrofit skills.

Skills is one of the biggest issues currently facing the insulation sector. In their Building Skills for Net Zero in Scotland report, the Construction Industry Training Board found that more than three quarters (78%) of respondents believe there will be a shortage of skills in their specific occupation when it comes to decarbonisation work. Lack of training and lack of funding for training were some of the most regularly cited reasons for the absence of appropriate skills in specific roles.4 Therefore, the NIA would like to see the Scottish 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 technical training courses, such as SVQs in Insulation and Building Treatments. The Home Decarbonisation Skills Training Competition exists in England to fund subsidised training courses for employees in the energy efficiency, retrofit and low-carbon heating sectors. The NIA recommends that the Scottish Government introduce a similar scheme in Scotland to encourage energy efficiency businesses to invest in upskilling existing employees and training new entrants.

Investment in skills and training is crucial to guarantee quality within the industry, which is vital to ensure the best outcomes for customers. The NIA and our members are dedicated to maintaining and raising quality standards across the insulation industry. Hence, we would support greater investment in skills, so that the industry has the large, highly-skilled workforce it needs to deliver high-quality retrofit at scale. Long-term policy certainty from government is also important as it gives insulation businesses the confidence to invest in their skills needs. Frequent changes in government policy and short-term funding schemes have contributed to a boom and bust culture within the insulation industry. Developing a coherent national retrofit strategy and committing to longer-term funding schemes would create the policy certainty that industry needs to invest in training and skills.

It is excellent that Scottish colleges offer an insulation apprenticeship – something that is not yet available in England. However, uptake has been very low so far; therefore, the NIA is working with ESP (Construction) to explore how the insulation industry can help Scottish colleges improve uptake. We believe the Scottish Government also has a key role to play in supporting Scottish colleges to market these apprenticeships, along with other training opportunities in the insulation sector. The NIA offers our support to facilitate the Scottish Government’s work in this area.

There is also a need for targeted information campaigns and careers advice to encourage new entrants into the sector. At the moment, the retrofit and wider construction sector have an image problem, particularly among young people, which prevents them from attracting sufficient new entrants. Research by L&Q has found that only one in ten children between the ages of 16 and 18 would consider a career in construction.⁵ To address this, the Scottish Government should introduce more signposting in schools and colleges about the opportunities in the insulation sector and the potential routes into the sector for young people. The insulation sector is a highly skilled, well-paid sector (with wages above the national average6) with a strong social and environmental purpose – to reduce fuel poverty and mitigate climate change. This should be emphasised more to change perceptions about the industry and attract new entrants. Attracting and training new entrants is critical if the industry is to deliver the volume of installs required to meet net zero.

To meet its decarbonization targets, the vast majority of Scotland’s 2.62 million existing dwellings, 20,000 public buildings, and 180,000 other buildings will need to be retrofitted.7 This will require a significant expansion of the retrofit sector over the next 10-15 years, which will bring increased demand for retrofit skills and training. Significant investment in skills and training from devolved government will be necessary to ensure that the retrofit supply chain has sufficient capacity to meet future increases in demand. Without the right support for industry, there is a risk that the transition to net zero in the energy efficiency sector will be held back by a shortage of labour and skills.

The NIA welcomes the support that the Scottish Government already provides for households to install energy efficiency measures through policies such as its Area Based Schemes and Warmer Homes Scotland.8 The NIA would like to see these schemes extended and more funding committed to them, so that we can continue to tackle fuel poverty in Scotland. In addition to these fuel poverty schemes, we would like to see further support offered to incentivise able-to-pay households to make energy efficiency improvements to their properties. This is a huge market for energy efficiency improvements and one that must be addressed if Scotland is to meet its ambitious energy efficiency targets.

Is there any further action that we, or other organisations (please specify), can take to protect those on lower incomes or at risk of fuel poverty from any negative cost impact as a result of the net zero transition?

The most effective way for the Scottish Government to protect those at risk of fuel poverty would be to offer more support for households to install insulation measures. While the Scottish Government has already committed substantial resources towards this issue, the recent cost of living and energy crises has exacerbated the problem and highlighted the need to provide further support to struggling households. According to ONS figures, 35% of properties in Scotland were in fuel poverty, as of October 2022.9 Since low energy efficiency is a key contributor to fuel poverty, the delivery of energy efficiency measures, such as insulation, to fuel-poor households is one of the key levers at the Scottish Government’s disposal to tackle the fuel poverty crisis.

Insulation measures alleviate fuel poverty by reducing household energy demand and lowering energy bills for fuel-poor residents across Scotland. Research by the Energy and Climate Intelligence Unit has found that annual gas bills for homes with an EPC of C could be almost £1000 lower than homes with an EPC of F. Hence, upgrading the energy efficiency of properties byinstalling insulation measures can deliver significant, much-needed cost savings to low-income households.10 Delivering subsidised insulation measures to households in fuel poverty will ensure that the net zero transition benefits the poorest and most vulnerable in Scottish society. Therefore, the NIA would like to see the Scottish Government commit to a national insulation programme as the best and most cost-effective way to lift households out of fuel poverty.