Consultation Responses

Which option for the dwelling notional buildings (for dwellings not connected to heat networks) set out in The Future Homes Standard 2025: dwelling notional buildings for consultation do you prefer?

1. Option 1 (higher carbon and bill savings, higher capital cost)

Option 1 is our preferred option because Option 2, as the Government’s own modelling shows, would leave residents exposed to higher annual energy bills than the 2021 uplift to Part L. The FHS should not under any circumstances lead to higher energy bills for residents than existing new build standards. This would be a completely unacceptable outcome. Therefore, we do not consider Option 2 to be a viable option. Furthermore, as outlined by a cross-industry letter sent to the Secretary of State for Levelling Up, Housing and Communities, there is a risk that Option 2 would contravene the Government’s public sector equality duty by introducing a standard which ‘would unduly affect those on lower incomes’.1

While we support Option 1 over Option 2, it is worth noting that these are the two least ambitious options of the five considered by the Future Homes Hub in their ‘Ready for Net Zero’

Report.2 For instance, home heating demand in the Report’s Contender Specification 4 is just % of that in Option 1 of the FHS, meaning that the options under consideration in the FHS will incur significantly higher bills and carbon emissions. The NIA believe that the U-values outlined in the Option 1 specification need to be tightened further for a number of reasons.

• To protect residents from high energy Heating systems installed under the FHS are expected to be dominated by electrified options like heat pumps. The high electricity to gas price ratio (3.86 to 1 as of the January 2024 price cap level)3means that without significant energy demand reduction measures, residents with electrified heating will be exposed to high energy bills. As such, insulation measures which lower energy demand are especially important with electrified heating options. More ambitious insulation requirements will mean that households living in new builds with electric heating are protected from the risk of high energy bills. This is particularly important given the current cost-of-living and energy crises, with electricity prices expected to remain well above pre-crisis levels for the rest of the decade.4 Therefore, the NIA would like to see stricter U-values to protect vulnerable consumers from high electricity prices.
• To increase the efficiency and reduce the running costs of heat The efficiency of heat pumps is receptive to the fabric efficiency of the home. Introducing more ambitious U-values will increase the efficiency of heat pumps and reduce the cost they incur to run. Higher insulation standards should allow a smaller, cheaper heat pump to be installed that will have lower operating costs for residents. Real-world monitoring and testing is key to find out how the fabric works in practice, enabling more accurately sized heating systems to be installed. Correctly sized heat pumps will operate at a higher efficiency than incorrectly sized systems. Ambitious fabric standards bolstered by effective monitoring and testing will result in more efficient and cheaper-to-run heating systems.
• To reduce the cost of electricity network expansion. If the majority of new (and ultimately existing) homes are to replace gas with electric heating, a huge expansion of the electricity grid will be required. There is a huge capital cost associated with building more renewable generation capacity and expanding the electricity network. According to Ofgem and the Government, £170bn – £210bn will need to be invested in the grid by 2050 to achieve our net zero targets.5Therefore, it is imperative that we build homes which use as little electricity to run as possible because the cheapest energy is the energy we don’t use. High insulation standards which reduce the energy demand of new homes will reduce the scale by which the electricity network and additional renewable capacity will need to be expanded by, thus saving billions in capital costs for residents and government. It will also increase energy security by reducing our demand for energy imports from overseas.

¹ Good Homes Alliance (2024). Future Homes Standard Consultation Response. Available at: Future Home Standard response – Good Homes Alliance
² Future Homes Hub (2023). Ready for Zero: Evidence to inform the 2025 Future Homes Standard. Available at: Ready for Zero – Evidence to inform the 2025 Future Homes Standard -Task Group Report FINAL- 280223- MID RES.pdf (cdn-website.com)
³ Ofgem (2024). Energy price cap. Available at: Energy price cap | Ofgem
⁴ Jillian Ambrose (2023). ‘Higher energy bills forecast for UK households next year’, The Guardian. Available at: Higher energy bills forecast for UK households next year | Energy bills | The Guardian
⁵ Regen. Building a GB electricity network ready for net zero. Available at: Building a GB electricity network for net zero (regen.co.uk)

What are your priorities for the new specification? (select all that apply)

Our priorities for the new specification are:

• Lower energy Lower energy bills are a vital consideration, particularly in the context of the ongoing cost of living and energy crises. The FHS should make every effort to reduce energy bills for residents. For this reason, we support Option 1 which would result in significantly lower energy bills compared to current new build standards. However, as outlined in our response to Question 7, we believe that Option 1 should be more ambitious in terms of insulation. Setting higher insulation standards, in conjunction with the solar PV provisions in Option 1, would ensure that energy bills are as affordable as possible for residents.
• Carbon savings. Higher insulation standards would also have the added advantage of additional carbon savings. The generation emissions factor for grid electricity in the UK is still around 0.2 kg CO2e per kWh.⁶This means that every unit of electricity consumed carries with it associated CO2 Given that the Government does not expect the UK’s electricity grid to be fully decarbonised until 20357, it is imperative that new homes consume as little electricity as possible. The most effective way to do this is by setting higher minimum insulation standards within the FHS.
• Protecting residents’ health. Option 1 sets higher ventilation standards, which are important to prevent the risk of damp and mould, and the potential health issues associated with it. However, we think that Option 1 could also be more ambitious when it comes to ventilation. For instance, it could require mechanical ventilation with heat recovery (MVHR). This would improve air quality, and reduce the risk of condensation and mould, while also conserving heat Strict ventilation minimum requirements are important to go along with increased insulation and airtightness requirements. A combination of high insulation and ventilation standards are the best way to protect residents’ health.
• Reducing pressure on the electricity grid and the capital cost needed to upgrade it. As mentioned in Question 7, the electrification of heat will necessitate a huge expansion of the electricity grid, which comes with a large capital cost associated with building more renewable generation capacity and expanding the electricity network. Therefore, high standards around insulation and solar PV are important to reduce the electricity that new homes require from the grid. This will increase our energy security and save billions in capital costs for government and taxpayers.

⁶ ITPEnergised (2023). New UK grid emissions factors 2023. Available at: New UK Grid Emissions Factors 2023 – ITPEnergised
⁷ Carbon Brief (2023). CCC: Here’s how the UK can get reliable zero-carbon electricity by 2035. Available at: CCC: Here’s how the UK can get reliable zero-carbon electricity by 2035 – Carbon Brief

Which option for the dwelling notional buildings for dwellings connected to heat networks set out in The Future Homes Standard 2025: dwelling notional buildings for consultation do you prefer?

a. Option 1 (higher carbon and bill savings, higher capital cost)

Which option do you prefer for the proposed non-domestic notional buildings set out in the NCM modelling guide?

a. Option 1

What are your priorities for the new specification?

Our priorities for the new specification are:

• Lower energy bills. For commercial buildings, lower bills are important to enable businesses to reduce their overhead costs, which continue to be a significant burden for many during the energy crisis. A survey conducted by PwC in 2023 found that 77% of business respondents had to raise their prices over the past two years as a result of energy-related expenditures8, thus driving inflation across the economy. Moreover, reducing the percentage of their budget spent on overhead costs will enable businesses to invest more in productive activities, such as hiring and training staff and creating economic growth. For this reason, we support Option 1 which would result in significantly lower energy bills compared to current standards. However, we believe that Option 1 should be more ambitious in terms of insulation standards, as set out in our responses to Questions 7 and 8.
• Carbon savings. Our preferred choice is Option 1 as it would deliver higher carbon savings. However, we would like to see higher insulation standards, as mentioned in our responses to Questions 7 and 8.
• Reducing pressure on the electricity grid and the capital cost needed to upgrade As mentioned in Questions 7 and 8, high standards for insulation and solar PV are important to reduce the electricity that new buildings require from the grid. This will increase our energy security and save billions in capital costs for government and taxpayers.

⁸ Sidhi Mittal (2024). ‘British businesses struggling to find right solutions to cut energy costs, survey finds’, Edie. Available at: UK Businesses Grapple with Rising Energy Costs According to PwC Survey (edie.net)

Do you agree that the metrics suggested above (TER, TPER and FEE) be used to set performance requirements for the Future Homes and Buildings Standards?

a) Yes, and I want to provide views on the suitability of these metrics and/or their alternatives.

We agree with the three metrics suggested, however we would like to see an additional metric added to take into account the building’s real-world fabric performance. This additional metric would be based on the results of mandatory post occupancy testing, which we have outlined our support for in Question 40. This Actual/Real Fabric Energy Efficiency metric could be compared to the DFEE to test how the property’s real-world fabric performance compares to its target DFEE rate. Including this as an additional metric would help to close the performance gap between how homes are designed and built. This would give residents and government confidence that buildings are actually being constructed in practice to the standards stipulated by the FHS and Building Regulations.

Mandatory post-occupancy testing, backed up by a metric that measures real-world fabric performance, would reward good performance from housebuilders and retrofit businesses, and generally drive up quality standards across the housing sector.

Do you agree with the proposed changes to minimum building services efficiencies and controls set out in Section 6 of draft Approved Document L, Volume 1: Dwellings?

Yes.

Do you agree with the proposed changes to Section 4 of draft Approved Document L, Volume 1: Dwellings, designed to limit heat loss from low carbon heating systems?

Yes.

Do you agree with the proposed guidance on the insulation standard for building heat distribution systems in Approved Document L, Volume 2: Buildings other than dwellings?

Yes.

Do you agree that the current guidance for buildings with low energy demand which are not exempt from the Building Regulations, as described in Approved Document L, Volume 2: Buildings other than dwellings should be retained without amendment?

Yes.

Should we set whole-building standards for dwellings created through a material change of use?

Yes.

Should the proposed new MCU standard apply to the same types of conversion as are already listed in Approved Document L, Volume 1: Dwellings?

No, standards should also apply to non-dwelling accommodation e.g., student or patient accommodation, care homes, and hotels. In many of the buildings classified as non-dwelling accommodation, residents live there on a semi-permanent basis. We do not believe that buildings which are used as a main place of residence for a significant proportion of the year, such as care homes, patient accommodation, and student accommodation, should be subject to weaker energy efficiency requirements than residential conversions.

Care homes and patient accommodation are used to house some of the most vulnerable people in society, who may be more susceptible to living in cold, damp and inefficient homes. Thus, it is crucial that these types of non-dwelling accommodation are subject to high MCU energy efficiency requirements.

Should different categories of MCU buildings be subject to different requirements?

Yes.

Which factors should be taken into account when defining building categories? (check all those that apply)

The following factors should be taken into account when defining building categories:

• height of the building, e., low versus mid- to high-rise buildings
• floor area of the building
• whether the conversion is a part- or whole-building conversion

Do you agree with the illustrative energy efficiency requirements and proposed notional building specifications for MCU buildings?

Yes.

If you answered no to the previous question, please provide additional information to support your view. Select all that apply. The requirements are:

Not applicable.

Do you agree with using the metrics of primary energy rate, emission rate and fabric energy efficiency rate, if we move to whole dwelling standards for MCU buildings?

Yes, and I want to provide additional suggestions or information to support my view.

As outlined in our response to Question 12, we would also support the inclusion of a metric that measures real-world fabric performance.

Under what circumstances should building control bodies be allowed to relax an MCU standard?

Building control bodies should be allowed to relax an MCU standard under the following circumstances:

• The technical or practical feasibility of achieving the It is important that buildings subject to an MCU are upgraded to the highest possible standards of energy efficiency. However, in some cases, we accept that it may not be technically or practically feasible to reach the required standards, for example, if there is no space or access to install the required insulation.
• Consideration of historic and traditional dwellings. We also recognise that reaching the required MCU standard might not be possible or practical in some historic and traditional buildings, particularly where listed building or conservation status applies.

Do you have views on how we can ensure any relaxation is applied appropriately and consistently?

As set out in our response to Question 32, we recognise that there are certain circumstances where MCU standards may need to be relaxed for practical purposes. However, it is crucial that any exemptions to the standards are robustly policed and accompanied by clear guidance to make sure that developers are only granted exemptions when there is a genuine barrier preventing adherence to the standards. Wherever practically possible, developers must be required to meet high energy efficiency standards in order to ensure that the benefits of energy efficiency measures for the climate and building occupants are fully realised.

Therefore, the NIA believe that the following should be in place to ensure any relaxation is applied appropriately and consistently:

• Only formal relaxation or dispensation through the local authority should be
• There should be guidance on circumstances where relaxation of the notional standard may be appropriate so that it is clear and unambiguous for developers when they are and are not required to meet MCU standards.

Should a limiting standard be retained for MCU dwellings?

Yes.

Even in dwellings where it is not possible to achieve the MCU whole building standard, there should still be minimum limiting standards for fabric insulation. These minimum standards are important to safeguard occupants from high energy bills.

They are also critical to prevent building defects from occurring. If there are sub-standard levels of insulation and ventilation within MCU dwellings, there will be a significantly increased risk of damp and mould, which poses a serious threat to residents’ health.

If a limiting standard is retained, what should the limiting standard safeguard against?

Limiting standards should be retained and they should safeguard against:

• risk of moisture, damp and mould
• high energy demand and energy bills

Do you agree that a BREL report should be provided to building control bodies if we move to energy modelling to demonstrate compliance with MCU standards?

Yes, and photographic evidence is needed.

Do you agree that consumers buying homes created through a material change of use should be provided with a Home User Guide when they move in?

Yes, and I’d like to provide further information.

We agree that consumers buying MCU homes should be provided with a Home User Guide when they move in. Supporting information and advice is important to make sure consumers operate energy efficiency technologies in a way that maximises their efficiency and effectiveness. This is particularly important when it comes to operating low carbon and smart technologies that they may be unfamiliar with.

Do you agree that homes that have undergone an MCU should be airtightness tested?

Yes, and I’d like to provide further information.

Airtightness testing will help to enforce fabric requirements by ensuring that the building fabric performs in practice as modelled. We would support mandatory airtightness testing for all homes including those that have undergone an MCU. This should be accompanied by increased minimum ventilation standards as a higher level of airtightness without sufficient ventilation can increase the risk of condensation and mould.

Do you think that we should introduce voluntary post occupancy performance testing for new homes?

Yes, and I’d like to provide further information.

Introducing post occupancy performance testing will help to protect consumers from experiencing higher bills and lower comfort levels. It will also build consumer confidence in the benefits of energy efficiency measures and the quality of work being carried out by the industry. However, we would like to see post occupancy performance testing implemented as a mandatory requirement, rather than a voluntary measure. Historically, voluntary options have seen very low uptake, therefore implementing this as a voluntary measure will likely result in only a small uptake in occupancy testing, and create an unfair market.

In addition, this approach creates a risk for housebuilders, as those who engage with post occupancy testing could be penalised for reporting the post occupancy testing results – as without mandated testing, 100% compliance is assumed.

Post occupancy testing ensures that homeowners get maximum benefit and the lowest possible bills from purchasing a new home, by reassuring them that their home achieves the efficiency level promised in the design in practice. Post occupancy testing is also important to ensure that homes have correctly sized heating systems, particularly as incorrectly sized heat pumps will

operate at a lower efficiency than correctly sized ones. Real-world monitoring and testing is crucial to find out how the fabric works in practice. This measurement will enable more accurately sized heating systems to be installed and ensure the house operates as an efficient whole house system. It is crucial that the fabric meets its target design efficiency in practice under real-world occupancy.

Mandatory testing should instead be introduced through sampling a percentage of homes to ensure compliance. For example, occupancy testing could be mandated for 10% of completions. Mandating post occupancy testing and making results publicly available will assist with improving quality and provide evidence for real-world efficiencies to monitor effectiveness and non- compliance with standards. This knowledge would help to improve the overall quality of the industry, alleviating the performance gap and raising consumer confidence. There is likely to be a significant performance gap without mandatory post occupancy testing.

Do you think that the government should introduce a government-endorsed Future Homes Standard brand? And do you agree permission to use a government-endorsed Future Homes Standard brand should only be granted if a developer’s homes perform well when performance tested? Please include any potential risks you foresee in your answer.

Yes, and I want to provide additional suggestions or information.

Implementing a government-endorsed Future Homes Standard brand is a positive way to incentivise housebuilders to engage with post occupancy testing to improve and maintain quality standards.

However, there must be a robust quality assurance process in place to ensure that the brand is credible and trustworthy, or risk damaging consumer confidence in the FHS. The brand should only be awarded to housebuilders that have consistently high-quality outputs, and not simply for those who measure performance. This aligns with leading a ‘race to the top’ on quality within the market. If there is not a robust process in place that only rewards consistently high-quality completions, the brand will not achieve the intended purpose and consumers will have difficulty differentiating between good quality and poor quality homes.

In addition, a Future Homes Standard brand is a good opportunity to introduce a public awareness campaign to improve consumer education about energy efficiency measures and standards. This could help with tackling the performance gap regarding the issue of user behaviour.

Do you agree with the proposed changes to Approved Document F, Volume 1: Dwellings to improve the installation and commissioning of ventilation systems in new and existing homes?

Yes, and I’d like to provide further information

We support the proposed changes, as more rigorous testing should lead to higher quality installations of ventilation systems and reduce the risk of condensation and mould resulting from sub-standard installs.

Nonetheless, we recognise that the increased cost of testing equipment, such as calibrated powered flow hoods, represents a barrier to compliance for some contractors. Therefore, we would urge the Government to provide support for contractors to purchase the necessary equipment. This will increase rates of compliance with the new ventilation rules and lead to higher quality across the insulation and ventilation sector.

Do you agree with the proposal to extend Regulation 42 to the installation of mechanical ventilation in existing homes as well as new homes?

We support increased testing of ventilation systems installed into existing homes. This will ensure that ventilation systems installed into residents’ homes are installed correctly and perform as intended. More extensive testing should reduce the incidence of poor quality installs, which can have damaging consequences for residents.

Do you agree with proposed changes to Approved Document L, Volume 1: Dwellings and Approved Document F, Volume 1: Dwellings to (a) clarify the options for certifying fixed building services installations and (b) set out available enforcement options where work does not meet the required standard?

Yes, and I’d like to provide further information.

We welcome further clarity on the options for certifying fixed building services. It is crucial that robust monitoring and enforcement mechanisms are in place to make sure that work is being carried out to the required standard. To this end, it is clear that building control bodies need more resources in order to properly enforce compliance with Building Regulations. For the Future Homes Standard to achieve its objectives, it is absolutely essential that it is backed up by effective enforcement mechanisms.

Do you have a view on how Home User Guides could be made more useful and accessible for homeowners and occupants, including on the merits of requiring developers to make guides available digitally? Please provide evidence where possible.

Yes, (please provide further details)

Developers should be required to make guides available digitally alongside paper copies. It is important that information is easily accessible for existing and also future residents. It can be very difficult for residents to find out property-specific information when they move into a new home, including details of any historic building works or retrofit works that have been carried out. Making Home User Guides digitally available and searchable via a centralised online database would make it much easier for residents to find out important information and help them to maintain their home more effectively. Many consumers may be unfamiliar with some of the technologies installed in new homes, so Home User Guides available digitally are vital to aid

their understanding of new technologies and how to operate them effectively.

Do you think that local authorities should be required to ensure that information required under Regulations 39, 40, 40A and 40B of the Building Regulations 2010 has been given to the homeowner before issuing a completion certificate?

Yes.

Do you agree that it should be possible for Regulation 26 (CO2 emission rates) to be relaxed or dispensed with if, following an application, the local authority or Building Safety Regulator concludes those standards are unreasonable in the circumstances?

Yes, but we believe that relaxation should only be allowed in exceptional circumstances, if for instance, the required energy efficiency measures cannot be installed safely. Use of this power must be policed and monitored very closely to ensure that it is not being used as a loophole to undercut energy efficiency standards without very good reason.

Do you think that local authorities should be required to submit the applications they receive, the decisions they make and their reasoning if requested?

Yes, and I’d like to provide further justification.

If Regulation 26 is subject to potential relaxation or dispensation, the relaxation process must be monitored very closely. Local authorities should be required to submit records of their decisions and the justifications for making them. This is essential to ensure that relaxation powers are not abused and do not become a convenient loophole by which developers can bypass the Future Homes and Buildings Standard.

Local Authorities’ use of these powers should be monitored closely and subject to enforcement action if necessary. For instance, if certain Local Authorities are found to be granting particularly high numbers of dispensations compared to others, an investigation may be required into whether they are abusing dispensation powers, accompanied by appropriate enforcement action if abuses are found to have been taking place.

Are there any additional safeguards you think should be put in place to ensure consistent and proportionate use of this power?

As noted in our response to Question 63, stringent monitoring and enforcement is critical to ensure consistent and proportionate use of this power.

Do you agree that Part L1 of Schedule 1 should be amended, as above, to require that reasonable provision be made for the conservation of energy and reducing carbon emissions?

Yes.

Do you agree that regulations 25A and 25B will be redundant following the introduction of the Future Homes and Buildings Standards and can be repealed?

Yes.

Do you agree that the Home Energy Model should be adopted as the approved calculation methodology to demonstrate compliance of new homes with the Future Homes Standard?

Yes, and I’d like to provide further information.

We agree with the use of the Home Energy Model (HEM) as the approved methodology to demonstrate compliance with the FHS. A replacement for SAP is long overdue and we welcome the increased accuracy that the HEM will bring.

However, given the tight timelines involved and the fact that the HEM is not yet finalised, there is a risk that it may not be ready for the introduction of the FHS. The Government’s consultation on the HEM makes it clear that the HEM is still undergoing development in multiple areas and lacks detail on certain aspects of the model’s design. The Government must work quickly to ensure that the HEM is fully finalised and any major issues with its design are resolved by the time the FHS is introduced. It is absolutely essential that the introduction of the FHS is not pushed back due to issues or delays with the HEM.

Do you agree with the revised guidance in The Future Homes Standard 2025: dwelling notional buildings for consultation no longer includes the average compliance approach for terraced houses?

Yes.

Do you agree with the proposed approach to determine U-values of windows and doors in new dwellings?

Yes.

Do you agree with the proposal to remove the default y-value for assessing thermal bridges in new dwellings?

Yes.

Which option describing transitional arrangements for the Future Homes and Buildings Standard do you prefer? Please use the space provided to provide further information and/or alternative arrangements.

Option 1

Option 1 provides an adequate transitionary period, whilst ensuring that we continue the momentum towards net zero targets. Furthermore, this option is followed by a separate 12-month transitional period anyway, which should minimise the impact on developers.

Do you agree that the 2010 and 2013 energy efficiency transitional arrangements should be closed down, meaning all new buildings that do not meet the requirements of the 2025 transitional arrangements would need to be built to the Future Homes and Buildings Standards?

Yes.

The NIA agree that the 2010 and 2013 energy efficiency transitional arrangements should be closed so that all new buildings are built to the Future Homes and Buildings Standards. Maintaining previous standards would be incompatible with reaching net zero targets and unfair for consumers who would be burdened with the costs of retrofitting a home built to old, outdated standards. This transition is fairest for the consumer, drives the construction industry to adopt more sustainable practices and aligns with net zero targets. To aid this transition, information, advice and guidance should be in place to support homeowners and housebuilders through the transition.

Click here to view the full response.

Consultation Response – Consultation on a new Social Housing Net Zero Standard in Scotland

Consultation on a new Social Housing Net Zero Standard in Scotland (www.gov.scot)

Closing Date: 8 March 2024
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.

Questionnaire

To what extent do you support the use of a fabric efficiency rating, based on heat demand, in the SHNZS?

Strongly support

The NIA supports the use of a fabric efficiency rating that goes beyond EPCs to focus solely on the building fabric and how well it retains heat and mitigates unwanted heat gains. A well-insulated and airtight building fabric is critical for maximising the efficiency of heating systems and minimising energy bills for residents. By prioritising fabric efficiency, the standard can better ensure that tenants benefit from clean heating systems, particularly for heat pump systems, which can perform exceptionally well in tightly sealed and well-insulated environments, further enhancing the efficiency and reducing the overall energy consumption of homes.

Of the options presented for the fabric efficiency rating, which one do you support for the new SHNZS?

Option 2
The NIA supports a fabric energy efficiency rating based on space heating demand only, to reduce external influences on the rating such as consumer behaviour. Meeting the fabric efficiency rating is essential to ensure social housing across Scotland is ready for the transition to clean heat. The NIA supports providing a target range to account for harder to treat property types. Option 2 mitigates the obvious issue of social housing providers aiming for the lower end of the range by providing an additional target to reach 71 kWh m2/year or better by 2040. That said, staggering this requirement by allowing a further 7 years to achieve the fabric efficiency rating will negatively impact tenants and cause further disruption, including some who may be living within vulnerable circumstances. The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

Are there additional options for the fabric efficiency rating that you think should be included? If yes, please describe these here.

The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

What, if any, are your views on how performance against the fabric efficiency rating should be measured?

The NIA advocates for a robust process to measure whether the fabric of homes actually meets its target design efficiency under real-world occupancy to protect residents and ensure that properties are ready for the transition to clean heat. Mandatory and accurate real-world performance monitoring (through sampling) is one way of reducing risk. Social housing providers could also make use of innovative technologies to measure performance which consider user behaviour and occupancy to determine actual energy performance. This will also incentivise high quality retrofit and ensure that residents reap the true benefits of retrofit measures in practice. Social housing providers should engage with tenants as early as possible during the retrofit process to effectively manage and implement this.

What are your views, if any, on the proposal for a minimum fabric efficiency standard?

The Scottish Government have recently consulted on EPC reform, therefore we expect the accuracy of EPCs will improve after the introduction of the new metrics that more accurately reflect the fabric efficiency of a home and support the transition to net zero. This will be further strengthened by the introduction of the Home Energy Model which will result in significantly more accurate and effective EPCs. EPCs take into account the individual property characteristics, whereas using a ‘one size fits all’ list that doesn’t consider property-specific characteristics creates a risk that the list of measures will become a ‘tick-box’ exercise that is irrelevant for certain property types.

It must be recognised and considered that properties have differing energy needs, and it is critical to ensure that residents have access to high quality, accessible advice to make sure that they can make informed choices about which measures are the most suitable for their property.

Should the Scottish Government proceed with a list of measures, we believe that solid wall insulation (IWI and EWI) should also be included on it. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

The proposed requirements reflect a commitment to providing warmer homes and lower bills for residents. However, they must also be accompanied by funding and support to enable social landlords to meet them. Therefore, the NIA recommends the implementation of additional support, resource and guidance to effectively deliver the proposed measures.

What, if any, are your views on whether homes should not be relet if they cannot meet a minimum fabric efficiency standard?

The proposal that social housing cannot be relet if the minimum standard is not met by 2028 does incentivise landlords to make the required changes, however the impact of this exacerbating housing shortages must be taken into account.

The proposed exemptions in Section 3.5 do mitigate this issue somewhat, however more could be done to ensure that a higher proportion of hard-to-treat properties receive much-needed energy efficiency measures. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute – funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.

What, if any, are your views on whether ventilation and monitoring strategies should be required where MVHR is not installed?

The NIA supports the proposition that landlords should be required to devise a ventilation and monitoring strategy to accompany energy efficiency interventions in cases where mechanical ventilation isn’t installed.

In particular, there should be a focus on monitoring to provide essential data to identify potential risks and ensure that air quality meets required standards under real-world occupancy – contributing to the well-being, comfort and health of tenants. Effective ventilation, backed up by stringent monitoring, will protect social housing tenants from health risks associated with damp and mould. The PAS 2035 process sets out clear ventilation requirements, hence it is vital that social housing retrofit is carried out by qualified installers subject to PAS standards. This is integral to an effective ventilation strategy.

Enforcing a mandatory ventilation and monitoring strategy would help to mitigate unintended consequences. There should be a clear process in place to ensure regulations are consistent and guidance and support should be put in place to assist landlords with implementing this.

To what extent do you support the need for landlords to have an element of discretion to ensure measures are cost effective and in the best interest of tenants?

Strongly support

The measures installed should always be in the best interest of tenants, and landlords should ensure that appropriate advice and guidance is provided to make sure that tenants are not in any way negatively impacted by measures, particularly financially. This includes considering disruption to tenants. Early and ongoing engagement throughout the retrofit process is crucial to achieve this.

A report issued by BEIS (now DESNZ) highlighted that tenant behaviour and lack of education and advice is a major barrier to social housing retrofit.1 Landlord discretion must be regulated and monitored to ensure the outcome is best for the tenants.

What, if any, are your views on whether targets should be varied by guidance from the Scottish Government in specific circumstances?

The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach mitigates the risk of the target range disincentivising a best-practice, whole-house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

For the minimum fabric efficiency standard, The NIA supports including solid wall insulation in the list of proposed measures. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that they will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without. Insulating solid wall homes will ensure that residents experience lower bills and higher levels of thermal comfort. It will also ensures that all of Scotland’s social housing sector is ready for the transition to clean heat. Further time could be given to insulate solid wall properties given the additional costs and complexities.

1 Department for Business, Energy and Industrial Strategy (2018). What are the Barriers to Retrofit in Social Housing? Available at: Barriers to retrofit in social housing (publishing.service.gov.uk)

To what extent do you agree that the new SHNZS should apply to mixed tenure properties?

Strongly agree

The NIA agrees the SHNZS should apply to mixed tenure properties and that more should be done to ensure that a higher proportion of mixed tenure properties are included. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute, funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.

To what extent do you agree that the new SHNZS should apply to Gypsy/traveller sites?

The NIA recognise that Gypsy/travellers have poorer outcomes than the settled population across a range of outcomes. These homes have been notoriously hard to treat within government funding streams due to a lack of clear guidance. To protect the most vulnerable residents, a solution must be found to include Gypsy/traveller sites in the SHNZS and further consultation should be sought on this.

What are your views on the timetable for introducing the new SHNZS?

Ensuring the required advice, guidance and support is in place in advance of standards being implemented is crucial to success. Therefore, the NIA accept the timetable for introducing the new SHNZS, to provide adequate time to consider enforcement, build resources and guidance and sufficiently consult and engage with a range of stakeholders. Timelines are already very tight, with minimum fabric efficiency standards due to come into force in 2028. Hence, it is critical that the Scottish Government implements the SHNZS as soon as possible to give social housing providers and the retrofit supply chain sufficient time to meet the regulations. Delays to this timeline would cause significant impact and hinder progress towards crucial net zero targets.

Summary – Scottish Government Heat in Buildings Proposals

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Questionnaire

Question 1
To what extent do you support our proposal to prohibit the use of polluting heating systems in all buildings after 2045?

☒ Strongly support 

The NIA supports the prohibition of polluting systems in all buildings after 2045, as decarbonising Scotland’s buildings is essential for it meet its 2045 net zero target. This is supported by the proposed minimum energy efficiency standards (MEES), which will ensure that the majority of Scottish homes achieve a good level of fabric energy efficiency. However, the standards do not include more expensive measures such as solid wall insulation, which risks leaving some households behind.

A fabric first approach is vital to ensure that properties are ready for the transition to low-carbon heat. If heat pumps (or other low carbon heating systems) are installed in properties with inadequate insulation, there is a risk that those heat pumps will have overly expensive running costs, as heat pumps are most effective in properties with a high thermal efficiency. Making sure that a home has adequate insulation prior to installing a heat pump is essential to safeguard consumers from potential energy bill increases.

To improve information and advice, the NIA supports the development of an assessment tool to help building owners understand which types of clean heating system are most suitable for their building.

Question 2
To what extent do you agree that we should introduce a minimum energy efficiency standard to be met by private sector landlords by the end of 2028 (even if they are already using clean heating)?

☒ Strongly support 

The NIA supports the introduction MEES for private sector landlords by 2028, as private rented homes typically have a poorer standard of energy efficiency. The Scottish House Condition Survey published in May 2023 found that 30% of private rented sector households are fuel poor, in comparison, only 9% of those with a mortgage and 14% of those who own outright are assessed to be fuel poor – highlighting that private rented homes should be urgently addressed to protect tenants.

This said, there must be support in place to support landlords through the transition. A recent report by British Gas found that one of the main barriers for landlords looking to upgrade their properties is a lack of knowledge around EPC standards, with 44% of landlords not knowing the EPC rating of their properties. In addition, over half of landlords don’t know enough about the grants available to them to make improvements. Government and industry must work together to tackle the lack of knowledge and financial support to incentivise landlords to make changes to properties.

It is also important that private landlords are given sufficient notice before MEES come into force, so that they have time to upgrade their properties. Therefore, we would like to see the Scottish Government finalise MEES regulations and embed them into law as quickly as possible. This would provide much-needed clarity to landlords and the retrofit industry, which is important for targets to be deliverable. If MEES are implemented too close to the date they are set to come into force, it may be impossible to feasibly meet them. For instance, there may be a risk of supply chain bottlenecks if thousands of private landlords are trying to install energy efficiency measures at the same time.

The NIA agrees that MEES should still be met even if the property has clean heating installed. A fabric-first approach, in line with PAS 2035, should be followed and is essential to reduce overall energy demand and to improve the comfort and well-being of tenants.

(1 Scottish Government (2023). Scottish House Condition Survey: 2021 Key Findings. Available at: Fuel Poverty – Scottish House Condition Survey: 2021 Key Findings – gov.scot (www.gov.scot), 2 British Gas (2023). Greening the Private Rental Sector. Available at: british-gas-greening-the-prs-report.pdf (centrica.com)

Question 3
To what extent do you agree that we should introduce a minimum energy efficiency standard to be met in owner occupied homes (which still have a polluting heating system) by the end of 2033?

☒ Somewhat support 

The NIA supports the introduction of a MEES to be met in owner occupied homes by the end of 2033.

However, and especially without an initial legal requirement to do so, advice and support for owner occupiers must be improved to incentivise residents to make the necessary improvements to their homes. The proposal does state ‘there will be very strong incentives for homeowners to invest in energy efficiency’ however these are not fully realised within this consultation. We urge the Scottish Government to roll out these strong incentives as soon as possible, as these will be vital to encourage homeowners to meet MEES and to reduce the financial burden of doing so.

The NIA disagrees with the proposal that owner-occupied homes that have ended their use of polluting heating by 2033 will not be required to meet the MEES. Whilst we understand the need to protect homeowners from financial burden, it is vital to treat the fabric of the home first, in line with PAS 2035, to maximise efficiency of low carbon heat and to ensure measures deliver the intended outcomes. A fabric-first approach according to PAS 2035 is of critical importance for the following reasons:

• To protect residents from high energy prices. Low carbon heating system replacements are expected to be dominated by electrified options like heat pumps. The high electricity to gas price ratio (3.86 to 1 as of the January 2024 price cap level) means that without significant energy demand reduction measures, residents with electrified heating will be exposed to high energy bills. Therefore, we believe that households who have replaced polluting heating systems should still be subject to MEES. This is particularly important given the current cost-of-living and energy crises, with electricity prices expected to remain well above pre-crisis levels for the rest of the decade. MEES for all households, regardless of heating system, will protect them from the risk of sustained high energy bills in the long term.
• To increase the efficiency and reduce the running costs of heat pumps. The efficiency of heat pumps is linked to the fabric efficiency of homes. MEES for homes installing heat pumps are important because a higher fabric efficiency will increase the efficiency of heat pumps and reduce the cost they incur to run. Higher insulation standards should allow a smaller, cheaper heat pump to be installed that will have lower operating costs for residents. As such, MEES for all homes will result in more efficient and cheaper-to-run heating systems.
• To reduce the cost of electricity network expansion. If the majority of homes are to replace gas with electric heating, a huge expansion of the electricity grid will be required. There is a huge capital cost associated with building more renewable generation capacity and expanding the electricity network. According to Ofgem and the UK Government, £170bn – £210bn will need to be invested in the UK grid by 2050 to achieve our net zero targets. Therefore, it is imperative that homes consume as little electricity as possible because the cheapest energy is the energy we don’t use. Ambitious MEES which reduce the energy demand of new homes will reduce the scale by which the electricity network and additional renewable capacity will need to be expanded by, thus saving billions of pounds in capital costs for residents and government.

Therefore, the NIA believes that MEES should apply to all homes, including those with a non-polluting heating system. This should be accompanied by greater support for residents to improve the energy efficiency of their homes.

(3 Ofgem (2024). Energy price cap. Available at: Energy price cap | Ofgem, 4 Jillian Ambrose (2023). ‘Higher energy bills forecast for UK households next year’, The Guardian. Available at: Higher energy bills forecast for UK households next year | Energy bills | The Guardian, 5 Regen. Building a GB electricity network ready for net zero. Available at: Building a GB electricity network for net zero (regen.co.uk)

Question 4
Do you agree with our proposal to set a minimum energy efficiency standard that can be met by either installing a straightforward list of measures, or showing a good level of energy efficiency based on a reformed EPC fabric efficiency metric?

☒ Somewhat support 

The Scottish Government has recently consulted on EPC reform, therefore we expect the accuracy of EPCs will improve after the introduction of the new metrics that more accurately reflect the fabric efficiency of a home and support the transition to net zero. This will be further strengthened by the introduction of the Home Energy Model which will result in significantly more accurate and effective EPCs. EPCs take into account the individual property characteristics, whereas using a ‘one size fits all’ list that doesn’t consider property-specific characteristics creates a risk that the list of measures will become a ‘tick-box’ exercise that is irrelevant for certain property types.

It must be recognised and considered that properties have differing energy needs, and it is critical to ensure that residents have access to high quality, accessible advice to make sure that they can make informed choices about which measures are the most suitable for their property. The focus of the minimum energy efficiency standard must be to ensure that each property can benefit from the most suitable energy efficiency measures tailored to its individual needs.

Should the Scottish Government decide to use a list of measures to demonstrate compliance with the MEES, we believe that solid wall insulation (IWI and EWI) should also be included. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

The proposed requirements reflect a commitment to providing warmer homes and lower bills for residents. However, the practicalities for homeowners and landlords must be considered. Meeting the standards may involve a significant financial contribution, particularly in harder to treat properties which require complex measures. To alleviate this, the NIA recommends the implementation of additional support, funding and guidance to effectively deliver the proposed measures.

Question 5
What is your view on the initial proposed list of measures to meet the minimum energy efficiency standard?

☒ Somewhat oppose

We believe that solid wall insulation (IWI and EWI) should also be included on the proposed list of measures. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

Nearly a quarter of homes in Scotland have solid walls and of these, only 16% had insulated walls as of 2022. Hence, there is an urgent need for more targeted support for solid wall homes, particularly because 45% of a home’s heat can be lost through uninsulated solid walls. We recognise that installing solid wall insulation across all of the homes that need it will be a challenge and therefore we would be open to a later compliance date for solid wall properties. However, it is vital that solid wall properties are not disregarded altogether from MEES. This would leave residents of solid wall homes colder and worse off in the long-term. Therefore, solid wall insulation (IWI and EWI) installed in line with PAS 2030/2035 as part of a fabric first approach, should be included on the list of measures for any MEES. According to Energy Saving Trust, this could save a typical detached home £660 per year on their energy bills.

Early engagement with residents is also essential to demonstrate the benefits of such measures. Including higher cost measures in the list alongside providing high-quality advice will help residents to make informed choices. Where necessary, additional time and financial support to complete higher cost measures should be granted.

(6 Scottish Government (2024). Scottish House Condition Survey: 2022 Key Findings. Available at: Supporting documents – Scottish House Condition Survey: 2022 Key Findings – gov.scot (www.gov.scot), 7 Emma Spencer (2024). ‘Save energy with solid wall insulation’, Money Supermarket. Available at: Solid Wall Insulation | MoneySuperMarket, 8 Energy Saving Trust (2024). Solid wall insulation. Available at: Advice on insulating your solid walls – Energy Saving Trust)

Question 6
Do you think that properties for which most or all of the measures on the initial proposed list are not relevant should be required to meet an equivalent minimum energy efficiency standard?

☒ NO – these properties should be considered compliant once they have installed all the measures that are appropriate for their building type, even if this is few or no measures.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), and they should be required to install all of these where feasible.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible and cost effective.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible, and they should be allowed additional time to do so.

Question 7
Do you think that properties for which most or all of the measures on the initial proposed list are not relevant should be required to meet an equivalent minimum energy efficiency standard?

☒ DON’T KNOW – The NIA believe that both the worst first and fabric first approach should be followed to address the need for investment in existing homes. MEES across housing tenures are a key regulatory lever that will drive progress towards more energy efficient housing.

However, the enforcement of private sector MEES and incentivising owner occupier MEES must be considered to ensure residents and landlords are motivated to make energy efficiency improvements. Measures must remain affordable, fair and feasible for homeowners and landlords and the Scottish Government should ensure that advice and financial support is accessible.

In terms of approach, the standard suggests that evidence including invoices or photographs could be used to show that a property has installed all of the measures (or as many as are feasible) for it to meet the standard. However, reformed EPCs will also include all the information that is required to show that an owner has met the standard. The NIA strongly advocates for robust evaluation and quality control of measures installed under MEES (such as through in-use performance testing) to avoid exposing residents to property damage and health risks, such as damp and mould, resulting from poor quality installations. High quality, PAS-compliant installs must be promoted to ensure that the benefits of measures are delivered as intended.

Question 9
To what extent do you support the requirement to end the use of polluting heating following a property purchase?

☒ Neither support nor oppose – The NIA agree that to ensure we reach climate change targets, we should consider other options to influence homeowners, landlords and businesses to make the change to clean heating systems before 2045.

The cost of upgrades to meet requirements will be a significant challenge for homeowners, especially for first-time buyers – and would significantly impact the housing market; affecting property values and impacting the buying/selling process. Lower-income homeowners are likely to be impacted the most, and this could create disparities in housing options.

Importantly, whilst the requirement to end the use of polluting heating is necessary, it is vital to ensure that properties are first ready for the transition to low-carbon heat. If heat pumps (or other low carbon heating systems) are installed in properties with inadequate insulation, there is a risk that those heat pumps will have overly expensive running costs, as heat pumps are most effective in properties with a high thermal efficiency. Making sure that a home has adequate insulation prior to installing a heat pump is essential to safeguard consumers from potential energy bill increases.

The NIA agrees that a grace period should be implemented to allow homeowners to make required changes. In order for the requirement to be fair, the Scottish Government would need to ensure:

• There are robust enforcement procedures in place to monitor and verify that upgrades have been installed to a high standard
• There is a significant range of finance products/ public funding to support people and businesses to make the required upgrades, including those who might not currently be able to access standard forms of private finance, such as mortgages.
• Homeowners have access to comprehensive advice and information services
• That the impact on the housing market is minimised as much as possible – for example providing an exemption for first-time buyers

Question 11
To what extent do you support our proposal to apply a cost-cap where people are required to end their use of polluting heating following a property purchase?

☒ Neither support nor oppose – The NIA understands the rationale for implementing a cost-cap to ensure homeowners do not pay unreasonable costs and that financing options can be determined.

However, introducing a cost-cap can be problematic as it could lead to unintended consequences such as compromising quality and market distortion. A strict cost-cap may influence selection of measures based solely on cost, rather than considering the most effective and sustainable solution – this could also discourage innovation in the sector. For instance, a low cost cap may exclude measures like solid wall insulation which are higher cost but which have significant benefits in terms of energy bill savings and thermal comfort.

If a cost-cap is implemented, the NIA recommends that the cap is flexible and adaptable to account for factors such as inflation, changing market rates and harder to treat properties.

Question 12
To what extent do you support our proposal to apply a cost-cap where people are required to end their use of polluting heating following a property purchase?

☒ Another, please suggest below – The three options proposed each have disadvantages which have been highlighted in the consultation. If a cost-cap is implemented, the NIA recommends that the cap is flexible and adaptable to account for factors such as inflation, changing market rates and harder to treat properties. To provide flexibility and fairness, cost-caps should take a range of variables into account, including building type, wall type, EPC rating, heating type etc, as seen with other energy efficiency schemes. Every property is different and there are many factors that can affect the cost of upgrading to a reasonable level of energy efficiency. Therefore, it is important that any cost cap reflects the heterogenous nature of Scotland’s housing stock and does not exclude harder to treat properties from important energy efficiency standards.

Question 18
We will need to have a way to monitor if people are meeting the Heat in Buildings Standard, and discussed two options for this. Which do you support?

☒ A combination of the two  – The NIA supports using a combination of both EPCs and sampling to monitor and enforce the proposed requirements.

The NIA also strongly advocates for evaluation and quality control of measures installed, to avoid exposing residents to property damage and health risks, such as damp and mould, resulting from poor quality installations. Monitoring must take into account the quality of installs to ensure that the intended consequences are delivered. These further checks could be completed as part of the sampling process.

Question 19
We will need to have a way to enforce the Heat in Buildings Standard. We discussed possible options to help achieve compliance. What are your views on these ideas?

☒ I support a mixture of the above options – The NIA believes the most effective way to enforce the Heat in Buildings Standard is through proactive reinforcement; offering comprehensive information and advice alongside a range of different financing options. The Scottish Government’s priority must be to provide residents with financial support and generous incentives to help them comply with MEES, with penalties a last resort.

The NIA agrees with proposing that private landlords should be subject to civil penalties if they refuse to meet the MEES. However, a recent report by British Gas shows that lack of information and costs are the main barriers for landlords when considering upgrades to properties. Therefore, it is important that appropriate support is available to help landlords comply and to avoid the need for penalties wherever possible.

For homeowners, the NIA agrees with the Scottish Government’s decision to avoid wider civil penalties, at least for the initial stages of the standard – particularly as the main barrier is the cost of measures. Homeowners should be engaged as early as possible to achieve targets. Information and support around eligible funding streams must be improved to incentivise homeowners to implement measures.

In addition, it is likely that enforcement bodies will experience gaps and inconsistencies with the quality of EPC data, hindering the identification of target properties. The Scottish Government should facilitate cross-team working for example between landlords, local authorities, Historic Environment Scotland, building control and trading standards to share intelligence and coordinate enforcement activity.

(9 British Gas (2023). Greening the Private Rental Sector. Available at: british-gas-greening-the-prs-report.pdf (centrica.com), 10 Centre for Sustainable Energy (2022). Compliance & Enforcement of the Minimum Energy Efficiency Standard (MEES) in the Private Rented Sector. Available at: Compliance & Enforcement of the Minimum Energy Efficiency Standard (MEES) in the Private Rented Sector (centreforsustainableenergy.ams3.digitaloceanspaces.com)

Question 20
To what extent do you support our proposals to modify the Standard or exempt certain people from the need to meet the Heat in Buildings Standard?

☒ Somewhat support – The NIA accepts that individual circumstances, and our homes and buildings, vary significantly, and therefore any enforcement should be fair and should protect vulnerable residents. Exemptions should be treated on a case-by-case basis where possible to allow for the greatest flexibility.

As full exemption from standards would hinder the pace we reduce carbon emissions, this should only be provided in a very limited set of circumstances where it is not possible for standards to be met. Instead, additional time and support should be offered for properties where it is more difficult to meet standards. For instance, we would support giving solid wall homes a later date to comply with MEES. This recognises the challenges associated with insulating Scotland’s solid wall housing stock, without excluding them from standards altogether, which would leave residents of solid wall homes colder and worse off.

Question 22
To what extent do you support our proposals to give certain people extra time to meet the Heat in Buildings Standard?

☒ Somewhat support – The NIA accepts that individual circumstances, and our homes and buildings, vary significantly, and therefore any enforcement should be fair and should protect vulnerable residents.

The NIA also agrees that extra time may be required for those living in properties where clean heating options are limited – in this case residents should focus on improving the fabric of the building to reduce energy demand and to ensure the property is ready for clean heat once suitable options become available.

As full exemption from standards would hinder the pace we reduce carbon emissions – additional time and support should instead be offered, where reasonable and feasible, to do so.

Heat strategy for Wales | GOV.WALES

Closing Date: 8 November 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, we agree with the Welsh Government’s vision.

Yes, we agree with the six areas identified by the Welsh Government.

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.

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.

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.

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.

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.

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.

Yes, we agree that this is a sensible approach.

Energy Performance Certificate reform consultation – Scottish Government consultations – Citizen Space Closing Date: 16 October 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.

The NIA agrees with the set of metrics that the Scottish Government proposes to display on the reformed EPC.

The new set of metrics support the need to reduce direct heating emissions, the need to lower residents’ energy bills and tackle fuel poverty, and the need to ensure that the building fabric is as efficient as possible. The proposals provide consumers with a more detailed information breakdown on the performance of different aspects of their home, which will help them to make informed decisions about the best route to improving the energy efficiency of their homes.

It is encouraging to see a separate fabric rating included as one of the headline metrics. A fabric first approach is industry best practice when it comes to whole-house retrofit. It also helps to make the transition to low carbon heat as affordable as possible for consumers. Therefore, it is critically important that the fabric efficiency of homes is clearly displayed on EPCs. This will give consumers a clear of idea of their property’s current fabric performance and how this can be improved, as well as highlighting the importance of adequate insulation to residents. The inclusion and adding weighting given to fabric efficiency on EPCs should help to facilitate muchneeded insulation upgrades to Scottish homes.

The inclusion of a metric for heating system type is also welcome. This means EPCs will more effectively support the transition to low carbon heat. There is very little incentive to install low carbon heating systems within the current EPC framework. Since the EER on current EPCs is based on modelled running costs, cheaper heating systems receive a better rating, regardless of their carbon emissions. Hence, changing EPCs to better incentivise low carbon heating measures, such as heat pumps, is vital if they are to be fit for a net zero future.

No, we agree with the metrics included.

No, the NIA does not think that the Fabric Rating should include hot water heat demand. This risks making the metric more complex and potentially confusing for consumers. It could also dilute the focus on fabric measures.

The rationale for including a fabric rating metric is to give residents a clear idea of how well insulated their home is and to drive insulation improvements. By including hot water heat demand (a non-fabric factor), this could detract from the metric’s primary goal – to improve fabric efficiency. While we recognise the importance of limiting heat loss from hot water systems through measures such as insulating the hot water cylinder, it is vital that the fabric rating is not influenced by nonfabric elements, such as type of hot water system. This would detract from the overall efficacy of the fabric rating.

As current policy commitments and targets are based upon EER bands (in particular Band C), the new fabric rating scale should be aligned with the current EER rating system. This is important to allow for continuity and consistency between different versions of EPCs. It will minimise any confusion that might be caused for businesses and consumers by changes to the EPC framework.

Yes, we agree with this proposal. Including unambiguous information about the dwelling’s specific energy efficiency features should give residents much-needed clarity. This should help them understand the current fabric performance of their home and allow them to make informed decisions about which measures to take in order to upgrade the property’s energy efficiency.

No, we believe that non-domestic EPCs should also include fabric rating as an additional headline metric, as is being proposed for domestic EPCs.

A fabric first approach is the most effective method to carry out whole-building retrofit. This is true regardless of the building’s use. A high level of thermal efficiency is equally important for non-domestic buildings as it is for domestic ones. Adequate insulation could save businesses a significant amount of money on their overhead costs, especially with energy bills at their current high level. Therefore, fabric rating should be clearly displayed on non-domestic EPCs so that building owners are fully aware of their building’s fabric efficiency and what steps they can take to improve it.

The fabric efficiency of non-domestic buildings is also important to ensure that they have a correctly sized heating system. This is particularly important when buildings are installing a new low carbon heating system. For instance, If a heat pump is installed followed by insulation, the building’s heating system output may not be proportionate with its reduced space heating demand and therefore have capital and running costs that are unnecessarily high. The installation of fabric efficiency measures prior to, or alongside, the installation of a low carbon heating system means a smaller, cheaper system can be installed. This is especially important in non-domestic buildings, which often have a significantly larger space heating demand and floor area than domestic dwellings.

In their 2023 Annual Progress Report to Parliament, the Climate Change Committee (CCC) highlighted non-residential buildings as an area of concern, nothing that, “There is a large and increasingly concerning policy gap relating to non-residential buildings.” Hence, it is crucial that the Scottish Government gives the same attention to the fabric efficiency of non-domestic buildings as it does for domestic ones. The best way to reduce the energy use and carbon emissions of non-domestic buildings is to make sure that they are adequately insulated. Thus, a fabric rating should be included on non-domestic EPCs, so that businesses as well as residents are incentivised to improve the fabric efficiency of their buildings.

As set out in our response to Question 6, we believe that non-domestic EPCs should include fabric rating as an additional headline metric.

A fabric first approach is the most effective method to carry out whole-building retrofit. This is true regardless of the building’s use. A high level of thermal efficiency is equally important for non-domestic buildings as it is for domestic ones. Adequate insulation could save businesses a significant amount of money on their overhead costs, especially with energy bills at their current high level. Therefore, fabric rating should be clearly displayed on non-domestic EPCs so that building owners are fully aware of their building’s fabric efficiency and what steps they can take to improve it.

The fabric efficiency of non-domestic buildings is also important to ensure that they have a correctly sized heating system. This is particularly important when buildings are installing a new low carbon heating system. For instance, If a heat pump is installed followed by insulation, the building’s heating system output may not be proportionate with its reduced space heating demand and therefore have capital and running costs that are unnecessarily high. The installation of fabric efficiency measures prior to, or alongside, the installation of a low carbon heating system means a smaller, cheaper system can be installed. This is especially important in non-domestic buildings, which often have a significantly larger space heating demand and floor area than domestic dwellings.

In their 2023 Annual Progress Report to Parliament, the Climate Change Committee (CCC) highlighted non-residential buildings as an area of concern, nothing that, “There is a large and increasingly concerning policy gap relating to non-residential buildings.” Hence, it is crucial that the Scottish Government gives the same attention to the fabric efficiency of non-domestic buildings as it does for domestic ones. The best way to reduce the energy use and carbon emissions of non-domestic buildings is to make sure that they are adequately insulated. Therefore, a fabric rating should be included on non-domestic EPCs, so that businesses as well as residents are incentivised to improve the fabric efficiency of their buildings.

Yes, we agree.

Yes, we agree with this in principle. The energy efficiency landscape is constantly changing as new policies and targets are introduced to drive the transition. The Scottish Government has set a target for all homes to reach EPC C by 2033.1 With the current validity period of 10 years, this means that an EPC carried out today would be still valid in 2033, even though the energy efficiency landscape will look drastically different by then.

Reducing the validity period to 5 years 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.

However, if the Scottish Government is to proceed with this proposal, it must support industry to train new energy assessors and upskill existing workers, as it will be necessary to increase the number of skilled energy assessors to meet the increased demand for EPC assessments. This would also improve the accuracy of EPCs and thereby increase consumer confidence in the reliability of the EPC framework.

This represents a significant challenge for industry and government. 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. The Home Decarbonisation Skills Training Competition has been very successful in England and is now in its second phase.2 When we signposted members towards this latest pot of skills funding, we had interest from Scottish members who enquired about whether Home Decarbonisation Skills Competition funding was available in Scotland (which unfortunately it is not).

There is clearly a demand and need for more subsidised skills funding in Scotland. Therefore, we would urge the Scottish Government to consider introducing a similar scheme to the Home Decarbonisation Skills Training Competition in Scotland, which would enable Scottish retrofit businesses to access subsidised training courses to train existing and new employees, and ultimately grow their businesses. Without more investment in training, we have concerns that there will be severe shortages in energy assessors and other roles key to the decarbonisation of homes. This could limit the practical viability of reducing the validity of EPCs to 5 years, and potentially hinder Scotland from reaching its wider energy efficiency targets.

Based on feedback from our membership, the requirement for installers to be Green Deal certified can represent a barrier to businesses and consumers. There are several reasons why an installer may not be Green Deal certified. For instance, some installers cannot use pre-existing “systems” because they a lot of their business is either architect-specified or needs bespoke solutions for installers. For these installers, it often doesn’t make sense to be Green Deal certified.

However, these businesses often miss out on business unfairly because of difficulty with customers accessing HES funding. Hence, we believe customers accessing HES funding should be allowed to use a Green Deal, Trustmark or NIA registered installer. This would give customers more options as well as ensuring better value for money for homeowners and taxpayers.

Yes, the NIA support this proposal as it will encourage EPCs to be used more and therefore will support its intended use as a guidance document for investment in home retrofit. The proposed changes will improve the accessibility of the document for readers. Enabling residents to view their EPC on a mobile device will allow EPCs to be viewed by a wider group of people. It will also enable people to view EPCs when they are on-the-go or away from their laptop. It will also allow for a more efficient system of updating the documents as the webpage can be updated with new data more frequently than pdf formats. As stated in the consultation, a webpage format will also reduce additional verification steps making the document more useable for those trying to access information about the properties they live in. The NIA support this proposal as it contributes to making EPCs more accessible and user-friendly.

As well as the format being easier to access, having the EPC on web page format will allow for additional links to be included helping readers to understand the content of the EPCs in greater detail. This is currently a barrier for consumers as the information on EPCs can be hard to follow without additional knowledge. In their letter to Lee Rowley MP, Parliamentary Under Secretary of State for the Department of Levelling up, Housing and Communities, ‘Reform of domestic EPC rating metrics to support delivery of Net Zero’ , the Climate Change Committee (CCC) list several factors that contribute to EPCs being unfit for purpose including the 1-100 rating scale, which does not provide useful information on what steps the consumer should take to improve the efficiency of their home.3 If EPCs were moved to webpage format as proposed, the advice provided can be accompanied by additional links enabling the reader to access supporting information to help them understand the content.

However, these businesses often miss out on business unfairly because of difficulty with customers accessing HES funding. Hence, we believe customers accessing HES funding should be allowed to use a Green Deal, Trustmark or NIA registered installer. This would give customers more options as well as ensuring better value for money for homeowners and taxpayers.

Yes. As mentioned above, being able to link readers to external information will support informed decision making on how they should invest in their homes. By directing readers towards existing support, such as existing energy efficiency and retrofit schemes in Scotland, they can see whether they are eligible for financial support, which according to the Energy Saving Trust (EST) is amongst the most common barriers for investing in home retrofit, alongside access to advice and information.4 The NIA support this proposal as this will add an extra layer of support provided through EPCs and will encourage engagement with existing schemes, helping to support the Scottish Government’s target of reducing emissions in homes by 68% from 2020 levels by 2030. Rather than the EPC being a standalone document, it can be used to link readers to information and existing support to help them to realise the retrofit work they are interested in, benefit from the results of an improved EPC rating and contribute to the decarbonisation of the housing sector.

However, it is important that readers understand that whilst EPCs offer advice, they should still get a full survey and retrofit assessment from a reputable installer before getting any work done to their home. This will ensure that they are choosing the right measure for their property and that they understand what is involved including time and cost.

To this end, we would recommend that, as well as linking to EST and HES, EPCs should also signpost customers to where they can find reputable, Trustmark-registered local installers. This is important as for many residents, the next step after having an EPC done is to install retrofit measures. It can be challenging for consumers to know where to start and sometimes speaking to local installers can clarify what work is available and at what cost. Consumers should be encouraged through the advice on their EPC to receive multiple quotations on the cost of the work where possible. By signposting to a trusted site this can help to simplify the retrofit process for consumers and help them take the next step to upgrading their home.

By directing consumers to a site where they can find high-quality, local installers, it would also reduce some of the burden on advice services, thus reducing the risk that a bottleneck could be created through massed calls to EST and HES, for example. For customers looking to install energy efficiency measures of the back of an EPC, it might be helpful to direct them directly towards businesses who can install the measures they want.

Yes, the NIA support this proposal as it will allow new homeowners to view and understand previous EPC ratings allocated to the property and any historical retrofit works that have taken place at the property to get to the current EPC. This proposal will also help local authorities to understand the common issues and solutions in housing in their local area. The effective use of data is vital to give local authorities an in-depth and detailed picture of their housing stock. This will allow them to plan more effectively for council-led retrofit programmes and create local decarbonisation strategies that are tailored to the local housing stock.

This data may also be useful for understanding local skills gaps through the identification of the most common work needed in homes in the area and the availability of local installation companies. The NIA works closely with contractors, suppliers and installers to identify ways to address the UK wide green skills gap with localised solutions being at the forefront of overcoming this issue in order to reach Net Zero.

Yes, the NIA support the proposal to include the EPC register in an Application Programme Interface (API) to allow for key stakeholders to access historical EPC data throughout the year. These key stakeholders could include homeowners, local authorities, industry representatives, research organisations and policymakers. The NIA believe this kind of data transparency can support key stakeholders in understanding how to improve the EPC rating of homes through access to information, which will ultimately support the transition to Net Zero.

Having accurate EPCs is fundamental to the decarbonisation of the housing sector as they are often the starting point from which consumers make decisions on what retrofit works to carry out on their properties. On principle the NIA agree with the proposed changes to the auditing process as smart auditing would allow for automatic triggers for EPCs meeting certain criteria, thereby enabling homes to be highlighted where urgent improvements are needed. This would be particularly useful for identifying the hardest to treat and worst performing homes. However, there are some questions on how this would work in practice in terms of informing homeowners and arranging assessors to visit the properties in question if this is to be part of the process.

The NIA believe prioritising energy efficiency improvements to the building fabric are the most effective ways of increasing thermal comfort, reducing energy loss from properties and reducing energy consumption as properties require less energy for space heating. Therefore, EPCs should advise households to invest first in insulation measures before moving to heating system upgrades according to a fabric-first approach. More widely, following the fabric-first approach has the highest benefits for decarbonisation of the housing sector as insulation measures help to reduce energy consumption and enable an affordable switch to using low-carbon heating systems such as heat pumps.

The NIA agree with the timeline proposed as it allows a grace period for stakeholders and homeowners to become familiar with the changes. The time period aligns with the introduction of other regulations in Scotland including the Energy Performance of Buildings Regulations. However, there is also an urgency to the introduction of policy changes that will serve to encourage investment in the decarbonisation of the housing sector, which these changes are likely to do, therefore we encourage the Scottish government to implement the reforms as quickly as possible.

Proposed amendments to the Boiler Upgrade Scheme Regulations – GOV.UK (www.gov.uk)

Closing Date: 12 October 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 current requirement for a valid EPC with no outstanding recommendations for loft or cavity wall insulation should be maintained. These minimum insulation requirements are vital to make sure that properties are ready for the transition to low-carbon heat. Removing these requirements would create a number of risks, particularly for consumers who may see increased costs and worse outcomes as a result.

Firstly, if heat pumps are installed in properties with inadequate insulation, there is a risk that those heat pumps will have overly expensive running costs, as heat pumps are most effective in properties with a high thermal efficiency. Making sure that a home has adequate insulation prior to installing a heat pump is essential to safeguard consumers from potential energy bill increases. The current level of the energy price cap means that the unit price for electricity is almost 4 times higher than that for gas.1 Therefore, to ensure that consumers do not see higher prices, insulation minimum requirements are absolutely vital to provide the right internal conditions for heat pumps to run as efficiently and as affordably as possible. In this way, insulation has a crucial role to play to ensure that the transition to low carbon heat is a just one which does not result in increased costs for consumers. This is particularly relevant within the context of the current cost of living crisis.

Secondly, if a heat pump is installed followed by insulation, 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. 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. For these reasons, a fabric-first approach has been incorporated into government policy and accepted as industry best practice for a number of years.

According to the Energy Saving Trust, if a home has an uninsulated loft and cavity walls, it could be losing over half of its heat through those two building elements.2 3 Hence, it is crucial that the current requirement for a valid EPC with no outstanding recommendations for loft or cavity wall insulation is maintained. Now is not the time to abandon the importance of a fabric first approach, which is the best way to reduce consumers’ bills and make sure that the transition to low carbon heat is affordable for all. Removing insulation minimum requirements in the middle of a cost of living crisis could have damaging impacts on consumers.

Consumer confidence is a crucial element of the transition to low carbon heat. 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 2035.4 For these targets to be met, consumers must be on board. If residents find that their heat pump is overly expensive or incorrectly sized as a result of inadequate insulation, then this may have damaging effects on consumer confidence, which could hinder the uptake of heat pumps. Thus, the importance of a fabric first approach cannot be ignored, as insulation will be key to ensuring that the transition to low-carbon heat is as smooth and cost-effective as possible for consumers.

The NIA does not consider insulation requirements on EPCs to be a barrier to uptake.

As outlined in our response to Question 3, a fabric first approach to home decarbonisation is vital to ensure that the transition to low carbon heat is as smooth and cost-effective as possible for consumers. Therefore, we believe that the requirement for a valid EPC with no outstanding recommendations for loft and cavity wall insulation should be maintained.

The main issue preventing uptake of heat pumps via the Boiler Upgrade Scheme (BUS) is the level of grant funding being offered. This has been the main barrier to the success of the scheme thus far, not minimum insulation requirements on EPCs, We are pleased to see that the Government is taking steps to address this, as evidenced by the Prime Minister’s announcement last month that the grant funding level will be rising to £7,500 from 23 October 2023.

The findings of the Lords Environment and Climate Change Committee’s inquiry into BUS, published in February 2023, found that the low level of grant funding was one of the main factors holding back the uptake of heat pumps via the scheme. 6 On average, the £5,000 grant offered by the scheme for an Air Source Heat Pump only represents approximately half of the installation cost. 7 Therefore, even with the BUS grant, households still face substantial remaining costs, which has deterred many from applying for the scheme. As a result, the Committee recommended raising the grant level to address low uptake8 , which the Prime Minister has now implemented in a move that has been welcomed across the home decarbonisation industry.

Since the Government is already removing the main barrier holding back the success of the scheme, there is no need to also remove minimum insulation requirements, particularly due to the risks associated with such a move. As mentioned in our answer to Question 2, the removal of insulation requirements would create substantial risks, including raising energy costs for residents and damaging consumer confidence in the transition to low carbon heating.

The main issue preventing uptake of heat pumps via the Boiler Upgrade Scheme (BUS) is the level of grant funding being offered. This has been the main barrier to the success of the scheme thus far, not minimum insulation requirements on EPCs, We are pleased to see that the Government is taking steps to address this, as evidenced by the Prime Minister’s announcement last month that the grant funding level will be rising to £7,500 from 23 October 2023.

The findings of the Lords Environment and Climate Change Committee’s inquiry into BUS, published in February 2023, found that the low level of grant funding was one of the main factors holding back the uptake of heat pumps via the scheme. 6 On average, the £5,000 grant offered by the scheme for an Air Source Heat Pump only represents approximately half of the installation cost. 7 Therefore, even with the BUS grant, households still face substantial remaining costs, which has deterred many from applying for the scheme. As a result, the Committee recommended raising the grant level to address low uptake8 , which the Prime Minister has now implemented in a move that has been welcomed across the home decarbonisation industry.

Since the Government is already removing the main barrier holding back the success of the scheme, there is no need to also remove minimum insulation requirements, particularly due to the risks associated with such a move. As mentioned in our answer to Question 2, the removal of insulation requirements would create substantial risks, including raising energy costs for residents and damaging consumer confidence in the transition to low carbon heating.

Energy Company Obligation schemes: Standard Assessment Procedure (SAP) and Reduced Data SAP (RdSAP) amendments – GOV.UK (www.gov.uk)

Closing Date: 11 September 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.

The NIA agrees with the proposal to update legislation so that only SAP10.2 should be used, subject to the appropriate transition period.

An update to the SAP2012 framework is long overdue. SAP10.2 is more accurate than the existing SAP2012 framework, and is based on more up-to-date and reliable information. This is especially important given recent large fluctuations in energy prices. Therefore, SAP10.2 will result in more reliable energy performance data, which is beneficial for residents and retrofit businesses.

SAP10.2 will also better support the decarbonisation of homes. By providing a reduced value for the carbon emissions of electricity, it provides a greater incentive to install low carbon, electrical systems. This is an important update, which should help to facilitate and accelerate the transition to net zero homes.1 Since SAP10.2 is already in use across England, Scotland and Wales, industry should be capable of adapting to its use within ECO4 and Great British Insulation Scheme (GBIS) retrofits, especially given the proposed six month transition period.

Yes, we agree with the proposed six-month transition period. As this is the completion timeline for ECO4 projects that include a district heating element, this is an appropriate length for the transition.

3.1) The NIA’s top preference is Option 2. This option minimises the transitional impact associated with updating from RdSAP2012 to RdSAP10.2 and it also avoids the administrative issues associated with operating two versions of RdSAP concurrently. We disagree with Option 3 because it risks a significant number of properties becoming ineligible for ECO4 funding, which in turn would result in lost business for the industry. It would also mean that fewer households can benefit from vital energy efficiency upgrades. This is an outcome that must be avoided. Modelling carried out by an NIA member, based on 5 different property archetypes with differing retrofit scopes, shows that RdSAP10.2 lowers both properties’ pre- and post-retrofit scores when compared to RdSAP2012. This decrease is particularly significant in projects that include renewables. Under Option 3, many retrofits will need to be evidenced using RdSAP10.2. There is a substantial risk that some of these retrofits will no longer meet the ECO4 Minimum Requirement (MR), particularly those that would have achieved a post-retrofit SAP band of mid to low C. Furthermore, the hard stop in Option 3 is too risky for installers, as a transition period is essential to effectively adjust to the changes to RdSAP. In practice, installers would avoid carrying out work on properties where their modelling shows that the post-retrofit SAP band will be close to the MR, as there is a risk that the project will not meet the MR when converted to RdSAP10.2. This will mean that many households miss out on energy efficiency measures because of the uncertainty involved in Option 3. Changing the goalposts for eligibility and evidencing overnight without any transition period would be disastrous. This would make a lot of projects ineligible and create dangerous confusion among installers. This would have a significant detrimental impact on scheme delivery. The NIA also has concerns about the workability of Option 1. Under this option, two versions of RdSAP would be running concurrently, which would place a large administrative burden on TrustMark and Ofgem as scheme providers. The software is not designed to support two versions of RdSAP running at the same time. Therefore, we have concerns that under Option 1, inadequate infrastructure and extra administrative complexity may delay projects and create bottlenecks within schemes. This will have damaging effects on both residents and installers. There is also a risk that having two versions of RdSAP running concurrently will create unnecessary confusion among installers.

3.2) The NIA does not have a second preference, as we believe that Option 2 is the only viable option. Neither Option 1 or Option 3 are practical or workable solutions for the reasons outlined in our response to Question 3.1.

Yes, we agree that 3 months is a sufficient period to allow the completion of retrofits following the introduction of RdSAP10.2. Within ECO4, the majority of projects are shorter than 3 months. There may need to be some flexibility within this, as some complicated, multi-measure retrofits, particularly ones that may include a change of heating system, may have longer lead times. However, for most retrofits carried out under ECO4, 3 months is an appropriate timeframe. As GBIS is primarily a single-measure scheme, we do not foresee any issues with completing retrofits in 3 months under this scheme.

If RdSAP10.2 is introduced into other schemes, such as SHDF, which include large scale retrofit projects, then the transition period may need to be longer than 3 months. This is something the Government will need to consider when it introduces RdSAP updates into other schemes. However, considering most ECO4 installations are small retrofit projects, a 3 month period to allow completion should be achievable

While we agree that Option 2 is the only viable option, we recognise the risk that some ECO4 retrofits may not achieve the MR once converted to RdSAP10.2, which will normally result in a lower SAP rating. It is vital that this risk is mitigated as much as possible, so that vulnerable households do not miss out much-needed energy efficiency upgrades and installers do not lose out on business.

We believe that the consultation’s proposal for installers to pre-lodge a post installation EPR based on RdSAP2012 to prove that they would have met the MR is a sensible approach to minimise this risk. Installers will generally carry out their own modelling before embarking on a retrofit project to forecast expected outcomes and ensure that they will meet the MR. This should provide sufficient evidence that a project would have met the MR, as long as, once the install is completed, installers verify that they have installed the measures included in the EPR.

Lowering the MR by half a SAP band is also a viable option. Although it is not as accurate or dwelling-specific as a pre-lodged EPR, it is a fairly simple approach which would not add much administrative complexity. It would also mitigate the risk of projects failing to meet the MR.

Under Option 2, the Building Research Establishment (BRE) would need to publish its conversion methodology, which would enable installers to quickly and easily convert pre-retrofit SAP ratings from RdSAP2012 to RdSAP10.2. To ensure that the change from RdSAP2012 to RdSAP10.2 runs as smoothly as possible, it is important that the BRE publishes this conversion methodology well in advance of March 2024 (the expected changeover date). Before the RdSAP updates come in, energy efficiency businesses will need time to gather existing data points and then go through existing EPCs, converting them to RdSAP10.2. Thus, it is critical that the Government decides on an approach and the BRE publishes its conversion methodology as soon as possible so that industry has sufficient time to prepare and adapt to the changes.

Yes, we agree with this proposal, as updating scoring methodology at this stage would create extra administrative complexity, which could impact upon scheme delivery.

We have concerns that the RdSAP and SAP updates will lead to properties being excluded from schemes. While we agree that an update of RdSAP and SAP is needed, it is vital that the Government implements the changes in a way that will mitigate the number of households being excluded from schemes.

As previously discussed in our response to Question 5, there is a risk that properties which would have achieved a post-retrofit score of mid to low SAP band C under RdSAP2012 may now drop into band D under RdSAP10.2. This could lead to a significant number of previously eligible properties now missing the MR. For installers, it will be too risky to treat marginal properties that may no longer meet the MR under RdSAP10.2 In practice, this could mean lots of vulnerable households are excluded from energy efficiency upgrades.

In order to achieve the scheme’s delivery targets and the UK’s net zero targets, it is important that energy efficiency upgrades are delivered to as many homes as possible. The UK has some of the least energy efficient properties in Europe2 , with many properties in urgent need of upgrade. According to the Office for National Statistics, 704,000 properties in England are still rated E, F and G.3 It is vitally important that the RdSAP/SAP update does not result in vulnerable, lowincome households missing out on much-needed support. National Energy Action’s latest estimates show that there are currently 6.6 million households in fuel poverty.4 As a result of energy price rises over the last year, millions of households across the UK are now struggling to pay their energy bills.

Thus, the Government’s primary consideration when implementing these changes must be to mitigate their impact on vulnerable, fuel poor households. As such, it is crucial that they take steps to ensure that as few households as possible become ineligible for energy efficiency support as a result of RdSAP/SAP updates. To minimise this risk, the NIA supports the Government’s proposed mitigation options, such as enabling installers to pre-lodge a postinstallation EPR and lowering the MR by half a SAP band.

Another issue which could arise from the updates to RdSAP/SAP concerns their interaction with the Minimum Energy Efficiency Standard (MEES). Since RdSAP10.2 generally leads to lower SAP scores than RdSAP2012, there is a risk that some private rented properties, which would have previously achieved MEES under RdSAP2012 may now no longer be compliant under RdSAP10.2. For instance if a landlord has upgraded their property to a SAP band of mid to low C in order to be compliant with proposed changes to MEES, there is a chance that a new EPC carried out using the RdSAP10.2 methodology would give the property a SAP rating of D, thus meaning the property will no longer be compliant once MEES rises to EPC C. While the NIA is supportive of MEES and efforts to raise levels of energy efficiency levels in the private rented sector, we would urge the Government to consider the interaction between RdSAP changes and MEES. This includes offering support where necessary to landlords and tenants to ensure that as many as properties as possible remain compliant with MEES.

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.