Skip to main content
Category

Consultation Responses

Draft Energy Strategy and Just Transition Plan

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

Closing Date: 9 May 2023

Response submitted by: National Insulation Association

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

About the National Insulation Association

The National Insulation Association (NIA) represents the insulation industry in Scotland and across the UK with a member base comprised of installers, system certificate holders, and manufacturers who provide a wide range of insulation solutions for homes and buildings. The NIA and its members are fully committed to maintaining and raising standards within the insulation industry.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Great British Insulation Scheme – Government Consultation Response

Great British Insulation Scheme – Government Consultation Response

This document acts as a summary of the main changes and outcomes of the ECO+/Great British Insulation Scheme consultation. Please read the full policy design and outcomes as detailed here.

Background

ECO+ has been renamed as The Great British Insulation Scheme to help with consumer awareness. The government’s strategic aims for the scheme are to help tackle fuel poverty, achieve Net Zero, and reduce total UK energy demand by 15% from 2021 levels by 2030. Annual phase targets will be set through legislation, and suppliers must meet at least 90% of each annual phase target within that year, with no constraints on exceeding annual targets. The scheme targets two groups: the general group and the low-income group, and a self-referral service will be launched in summer 2023. EPC bands D and E in the private rented sector are eligible for the general and low-income groups, while F and G are excluded unless exempt from PRS regulations. The Scheme will focus on delivering insulation and heating control measures and will support households across Great Britain.

Key Points

  • Overall, respondents were supportive of the proposals for the Great British Insulation Scheme, previously known and consulted on as ECO+. Government have renamed the scheme to help with consumer awareness, and recognition of the support available.
  • The Government’s strategic aims for the Scheme are to help tackle fuel poverty, achieve Net Zero and the aid in the ambition to reduce total UK energy demand by 15% from 2021 levels by 2030 across domestic and commercial buildings and industrial processes.
  • A full scheme obligation with annual phase targets will be set through legislation. The legislation will specify the framework through which Ofgem, as scheme administrator, will determine the amount of annual bill savings that obligated suppliers must achieve, through energy efficiency (primarily insulation) measures. Suppliers must meet at least 90% of each annual phase target within that year, through qualifying measures, with any shortfall made up by scheme end. There will be no constraints on suppliers exceeding annual targets and making faster progress in meeting their scheme obligation.
  • Suppliers may also begin delivering measures ahead of the legislation coming into force, from the date on which this document is published, and Government will take steps to facilitate this. The Scheme will target two groups: the “general group” and the “low-income group”. The general group will consist of those living in homes with an EPC rating D-G and within Council Tax bands A-D in England and A-E in Scotland and Wales. Eligibility in Wales is expanded from Council Tax bands A-C as consulted upon to better align the proportion of eligible homes in each nation.
  • The low-income group will consist of those living in homes with an EPC rating D-G and will broadly mirror the household eligibility requirements of ECO4 (being on means tested benefits or living in the least efficient social housing). At least 20% of each supplier’s annual phase target must be delivered to households in the low-income group. There will also be a flexible eligibility element to the Scheme, where households that do not meet the low-income group eligibility criteria but are considered by a local authority, or participating energy supplier to be living in fuel poverty, or on a low-income and vulnerable to the effects of living in a cold home can be supported. Households treated via this mechanism can comprise up to 80% of a supplier’s low – income minimum.
  • To help households to learn about and access the Scheme, Government plan to launch a self-referral service in summer 2023 as part of GOV.UK.
  • For the private rented sector (PRS), the proposal will be retained as consulted on, so that households in EPC bands D and E are eligible in the general and low-income groups, while those in EPC bands F and G will be excluded unless exempt from the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (‘PRS Regulations’). PRS households in the general group are only eligible for higher-cost insulation measures excluding loft or cavity wall insulation.
  • Social housing will be eligible where it has an EPC band of D-G, and the eligible measures depend on this EPC rating.
  • In Scotland and Wales, low-income off-gas households living in rural areas will be supported with a 20% uplift to the score given to each measure. In England, where different arrangements apply, the Home Upgrade Grant will support low-income off-gas households; it has ringfenced 60% of funding for rural local authorities.
  • In a change to the approach proposed in the consultation, obligated suppliers will not have to prove that low income properties cannot meet the ECO4 minimum requirement in order to be eligible for support through the Scheme. This is to simplify delivery and ensure support is available for all low-income households.
  • There will be no requirement to improve properties by a certain number of EPC bands and the Scheme will focus solely on the delivery of insulation and heating control measures. All measures must be delivered in accordance with PAS 2035; this includes cavity and loft insulation in all scenarios and heating controls.
  • Each household in the general group will only be able to receive one measure. Owner occupied households in the low-income group are eligible for heating controls in addition to an insulation measure. In setting the overall scheme obligation, Government assume that households in the general group will collectively contribute £80 million towards insulation measures (equivalent to 10% of the £800 million scheme budget earmarked for this group). However, they believe it will be for suppliers to manage how this is achieved overall, with any contributions agreed on an individual household basis linked to the work done. Innovation Measure (IM) scores will receive a 25% or 45% uplift, as applies in ECO4, in the low-income group only.
  • As consulted on, ECO4 partial project scores will be used in the Scheme to calculate the bill savings a measure achieves. As pre-retrofit RdSAP (Reduced Data Standard Assessment Procedure) assessments are required for all retrofits under the Scheme, EPCs will not be required to evidence the pre-installation energy efficiency rating of a property.
  • The cost of delivering GBIS will be included within the Energy Price Guarantee. To facilitate that, an allowance for the scheme has been included by Ofgem in the default tariff cap (the price cap) from April 2023 onwards. In terms of scheme administration, the notification processes and deadlines will remain as proposed in the consultation.
  • The trading of obligations and transfer of measures will be permitted, within set parameters, as widely supported by respondents to the consultation.
  • The Scheme will support households across Great Britain, recognising the benefits in terms of efficiency and reduced bureaucracy from a single, consistently designed scheme. The UK Government will work in dialogue with the Scottish and Welsh Governments to implement the Scheme.

ECO4 Amendments

There was overall support for the changes proposed by the Government. The following changes have been made:

  • The definition of a renewable heating system will be amended back to the ECO3 definition of “wholly or partly”. This will allow electricity generation equipment, such as solar PV, to be installed alongside electric storage heaters (ESH) and electric heating systems (EHS) and considered a renewable heating system if some of the electrical output produced by the solar PV is used to generate heat.
  • Solar PV is eligible for install in on-gas and off-gas homes that already have a hydronic heat pump, ESH or EHS installed with a manufacturer responsiveness rating of 0.8 or above when assessed against the Standard Assessment Procedure, or that have had them installed as part of an ECO4 project.
  • Coal, oil, LPG and biofuels are excluded fuels from ECO4, and by extension ECO+.
  • ESH/EHS installation will be extended to homes with neither an efficient nor inefficient heating system (i.e., homes with no heating or that use only plug in room heaters or wall mounted electric heaters), and for offgas homes where it is not possible to install measures from the off-gas heating hierarchy in these homes. However, there are no changes to the types of eligible measures allowed in different tenure types.
  • Off-gas homes may connect to district heating systems fuelled wholly or partly by gas in accordance with the off-gas heating hierarchy at stage 2.
  • SAP10 and RdSAP10 assessments will be used for evidencing instead of SAP2012 and RdSAP201

Future Publications

Following publication of this document, government will lay affirmative regulations in Parliament, which we expect to come into force later this year. The policy described here is subject to Parliamentary approval of the regulations. Ofgem, the administrator of the Scheme, will publish separate guidance for local authorities, the devolved administrations, and suppliers. The government will publish the Final Impact Assessment for the Scheme in spring 2023

The Warm Homes Programme – NIA Consultation

The Warm Homes Programme – NIA Consultation Response

In April 2022, in the same week that it published its “ECO4: 2022 – 2026” response to the Energy Company Obligation, the Department for Business, Energy and Industrial Strategy (BEIS) also issued its Response to the Warm Home Discount. (Link opens as a PDF.)

The document follows a consultation held between June and August last year, which drew 87 individual responses from across 79 organisations. In its executive summary, BEIS writes: “In the Energy White Paper in December 2020, the Government committed to extend, expand, and consult on reforming the scheme from 2022 onwards. The scheme will be extended to 2025/26 at least and expanded to £475m (in 2020 prices) per year.”

In that same week, the NIA submitted its response to the Welsh Government’s proposals for the next iteration of the Warm Homes Programme. The following are some key points from that response:

 

  • Tackling the climate emergency, alleviating fuel poverty and creating a socially just nation can be mutually compatible goals. For example, insulating a building helps to reduce carbon emissions, to lower residents’ bills and thus to alleviate fuel poverty.
  • However, priorities can conflict. For example, as things stand, it is more cost effective for a homeowner to replace a broken boiler with a new one, rather than installing a low-carbon alternative such as an Air Source Heat Pump.
  • It is important that the Warm Homes Programme works effectively towards shared objectives of meeting fuel poverty obligations, meeting statutory climate change targets, and keeping household bills affordable across the wider population. The Programme should prioritise a holistic approach for measures that provide the best outcome in the long-term.

 

We also responded to the following question: “What is the gap in provision which you believe the next Warm Homes Programme should fill to achieve a greater benefit for Wales?” We noted that the Warm Homes Programme should take a fabric first approach and promote a whole house retrofit in order to fulfil its aims and to reach its targets.

 

Other responses included the following:

  • We support the proposal in the optimised retrofit model, to “maximise airtightness, eliminate thermal bridging, optimise insulation, solar gain and natural ventilation so reducing heat loss and making homes fabric ready.”
  • The Warm Homes Programme must consider the quality of installations, ensuring that they are to the highest standards, namely to PAS2035/2030. Requiring TrustMark registration for all installations ensures adherence to the TrustMark framework and to PAS2035/2030. The NIA suggests that this be considered for the Warm Homes Grant.
  • The quality of installations should not be sacrificed for the sake of reducing costs. The ambition to reduce energy-use in new buildings is welcome, but this should be achieved via the installation of high-quality measures.
  • Fuel poverty is highest in the 75+ age group. We therefore suggest that this age group is prioritised in the next iteration of the Warm Homes Programme.
  • It is welcome that the proposal wishes to alter the definition to include single-occupant homes aged under 25 years of age as vulnerable, but we suggest it be extended also to 55-64s.
  • We agree with the ‘worst first’ principle to prioritise those most severely fuel-poor. Such homes tend to be more costly to retrofit as they are usually harder to treat, but we would suggest that the policy cannot leave them behind even if they are more costly, as that would contribute to failures in meeting fuel poverty and climate targets.
  • We suggest that fuel poverty targets are made statutory in order to demonstrate commitment. This will help to give manufacturers, advisory services, installers and wider supply chain partners the certainty they need to invest and help achieve the Programme’s targets.
  • We broadly agree that the Warm Homes Programme should be extended to other households (in both the owner-occupier and private rented sector). 84% of fuel-poor households in Wales are in that very sector.

NIA Consultation Response 

Our response also encompasses recommendations for measures that should be included or excluded from the next iteration of the Warm Homes Programme, responses to questions about funding sources, and the prioritisation of certain types of homes and residents. The full 12-page document can be viewed here. (PDF.)

We would like to thank all those members who contributed to the consultation.