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November 2023 Newsletter

Hello and Welcome

Firstly, thank you for your continued support for the NIA. This year has seen over 1700 referrals to NIA members via the NIA website, the successful Supply Chain Speed-Networking Day which gave you the opportunity to meet one-to-one with Tier 1 contractors and energy suppliers, our upcoming Parliamentary Reception, and more! Without your loyalty, this wouldn’t be possible. With that in mind, a friendly reminder, if you haven’t already done so, it’s time to renew your membership of the NIA – it would be fantastic to see you return! If you would like to renew your membership, or if you have any queries about your membership renewal with us, please send an email to info@nia-uk.org by the end of November. Renewal before this deadline will help us to plan next year’s programme.

Read on to hear about how our members benefitted from the fantastic Supply Chain Speed-Networking Event, as well as our exciting upcoming NIA events, with less than a month to go until the Parliamentary Reception. Discover how your voice has been represented via recent consultation responses and other interesting policy developments in the sector – make sure you’re up to speed!

Success at our Supply Chain Speed-Networking Event!

What a day! With over 100 attendees, 50 organisations and 300 one-to-one appointments taking place it was great to see such a buzz at the highly anticipated Supply Chain Speed-Networking Event at the Birmingham Council House on 6th November. There were lots of exciting conversations in the room throughout the day, with NIA members, leading Tier 1 contractors, energy suppliers and the wider supply chain.

You can read our reflection piece about the event here and watch the video to see what members got up to on the day!

Derek Horrocks, chair of the NIA, said: “This event was a well-planned opportunity to foster connections, collaborations and commercial relationships that are integral to delivering decarbonisation at scale.

“As our industry is so people-focused, taking the time to come together and invest time in one another is always beneficial. The positive response we have had speaks volumes of all attendee’s determination to lead our industry forward in the right direction and with the necessary ‘can do’ mentality.”

This is the first time this event has been ran, thank you to all the members who joined us to make it such a huge success! If you missed the opportunity to attend and would like to attend a similar event in the future, please email info@nia-uk.org so we can determine interest.

Don’t miss out! Come along to the Parliamentary Reception next month

It’s the last chance to register for the unmissable annual Parliamentary Reception event, taking place from 7pm on Wednesday 13th December at the prestigious House of Lords, hosted by Lord Best. If you haven’t already, book your space here!

Collaboration across industry has been a key theme this year, widening the supply chain and fostering relationships. This event aims to provide another opportunity to collaborate across industry where you will meet over 150 attendees, including parliamentarians, civil servants and key stakeholders in the low carbon sector.

You will also hear from Lord Callanan, Minister for Energy Efficiency and Green Finance.

We would like to take this opportunity to thank all of our sponsors for the event, we really value your continued support!

We look forward to seeing you there to celebrate the hard work of the insulation and decarbonisation sector, as we look forward to how the industry and government can work together to achieve our shared Net Zero ambitions.

Representing you – our policy work and consultation responses

Invitation to ESNZ Committee session on Heating our Homes – 22nd November 2023

Thank you to those members who provided valuable input to shape and inform our response to the Energy Security and Net Zero Committee Call for Evidence: Heating our Homes. Off the back of this, the Energy Security and Net Zero Committee has agreed a plan for its Heating our Homes inquiry, and we are delighted that the committee has approached the NIA to participate in its first oral evidence session.

NIA Board Member and Chief Executive of InstaGroup, David Robson, will speak on behalf of NIA members at the committee, which will provide a scene-setting introduction to the inquiry, including discussion on past and current support schemes, the role of industry and policy options. The NIA will feature alongside other national organisations working in the sector.

Invite to attend Building Sector Roundtable – IEA UK Energy Policy Review – 23rd November 2023

NIA Chairman, Derek Horrocks, will be attending the Building Sector Roundtable, led by the International Energy Agency (IEA) as part of their In-Depth Review of UK energy policy. The IEA are keen to hear insights on the impact of current and planned government policies, key energy sector challenges and opportunities and how policies can be changed to address challenges / take advantage of opportunities.

In addition, you have been represented via three consultations in the last few weeks: the Scottish Government’s Energy Performance Certificate (EPC) reform consultation, the proposed amendments to the Boiler Upgrade Scheme Regulations and the Heat Strategy for Wales. Thank you to those members who provided valuable input which helped to shape and inform our responses.

Scottish Government’s Energy Performance Certificate (EPC) reform consultation – submitted 16th October 2023

This consultation sought views on EPC reform and included plans to reform domestic and non-domestic EPC metrics, the purpose and validity period of EPCs, the EPC format, and quality assurance procedures.

As a result of these proposals, EPCs would provide relevant and holistic information to interested parties to help them make informed purchase, rental and retrofit decisions. Ensuring EPCs show the right information is essential to inform decisions that support the improvement of our homes and buildings towards net zero.

The NIA agreed 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.

Please read our full response here.

Proposed amendments to the Boiler Upgrade Scheme Regulations – submitted 12th October 2023

This consultation sought views on policy proposals and the introduction of a range of proposed amendments to the existing Boiler Upgrade Scheme (introduced in 2022) Regulations.

We called for the current requirements for a valid EPC with no outstanding recommendations for loft or cavity wall insulation to 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.

Please read our full response here.

Heat Strategy for Wales Consultation – submitted 8th November 2023

This consultation sought views on the Heat Strategy for Wales, which aims to develop a decarbonised heat system to deliver on net zero ambitions.

The NIA responded to several sections of the consultation. The response reiterated that PAS 2035/2030 standards are crucial to ensure a high-quality, whole-building approach to retrofit and agreed that stronger regulation can support uptake of low carbon heat and energy efficiency measures.

Please read our full response here.

Get in the know – latest industry news!

Government Response to the Climate Change Committee’s annual progress report

The Government have responded to the Climate Change Committee’s annual progress report. In the Government’s response, they have noted they are partly or fully acting upon 85% of the CCC’s priority recommendations and are acting on the majority of the remaining 273 recommendations. However, they also state they are “determined to get the consent of the public to ensure net zero is achieved”. That means not taking forward CCC recommendations on policies that force families to make “costly and burdensome changes” to their lifestyles.

You can read the full response here.

Upcoming 2023 Autumn Statement – 22nd November

The 2023 Autumn Statement will be presented to Parliament on Wednesday 22nd November 2023. The NIA, in conjunction with the NHDG, have urged the Government to announce the release of the full £3.8bn of the Social Housing Decarbonisation Fund in the upcoming Autumn Statement, recommitting the Government’s net zero manifesto pledge.

Home Decarbonisation Skills and Training Competition: Phase 2 successful projects

Back in September 2023, Elliot Roofe from the Department for Energy Security and Net Zero (DESNZ) attended the NIA Insulation Intelligence Call to discuss how members can upskill their workforce by taking advantage of the Home Decarbonisation Skills and Training Competition funding. The gov.uk page for the Home Decarbonisation Skills Training Competition has now been updated and most providers will now have a link for interested parties to click through and sign up for courses.

You can find out more information here.

Which? report ‘Priority Places for Insulation Index: Mapping the UK’s Home Insulation Needs’

New research from Which? has revealed the locations across the UK in greatest need of insulation upgrades as it calls for the government to provide better support for households living in fuel poverty and in urgent need of improved insulation.

You can read the full report here.

Heat Strategy for Wales

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.

Section 1: A vision for heat in Wales

Vision: Do you agree with our vision? (Yes/No) Please suggest amendments if you think it could be stronger.

Yes, we agree with the Welsh Government’s vision.

Objectives: The Heat Strategy for Wales policies are broken down into 17 objectives within six groups. Do you agree they adequately cover the areas where Welsh Government needs to focus? (Yes/No) If you think there are any areas missing, please explain what they are.

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

Section 2: Our enabling framework

Standards: Do you believe the public available specification (PAS) standards are sufficient to ensure high-quality work and a whole-building approach? (Yes/No) Please explain. How can the adoption and implementation of these standards be further encouraged?

Yes, PAS 2035/2030 standards are crucial to ensure a high-quality, whole-building approach to retrofit. The NIA is committed to maintaining and improving quality across the insulation sector so that the true benefits of the installed measures are realised, and the customer and their home are fully protected at all times. We believe that PAS 2035/2030 is a helpful standard which promotes high-quality retrofit and reduces the risk of retrofit projects. Hence, we welcome the plans set out by the Welsh Government to use PAS 2035/2030 standards in all of its retrofit programmes.

PAS 2035/2030 is an industry-led quality standard that provides best practice for retrofit, taking a whole house approach. This provides customers with confidence in the work being carried out, and also prevents poor delivery of measures and costly damage to properties. New PAS standards were brought in after the Each Homes Counts review to safeguard against the damaging consequences of sub-standard installations. Since then, they have been instrumental in improving the quality of installation and customer service across the industry. PAS 2035/2030 focusses on a fabric first approach to home decarbonisation which prioritises vital insulation upgrades as a first step to whole house decarbonisation. It puts whole house retrofit at its heart and sets out a clear platform for sensible, logical retrofit.

Nonetheless, even with the recent revisions which should make the PAS process more streamlined, we recognise that PAS compliance can be costly, especially for small businesses. Therefore, it is important that the Welsh Government supports businesses with these costs and helps them to carry out high-quality, PAS-compliant retrofit. This could include providing more funding within its programmes to cover the costs of PAS compliance. Training and qualifications are another vital element of the PAS framework; hence it is important that the Welsh Government provides support for local businesses so that they are adequately skilled and qualified to carry out PAS-compliant retrofit projects. By providing more support to businesses working towards PAS compliance, this will enable PAS-compliant retrofits to become commonplace across Wales.

Skills: Do you agree that Welsh Government has a role in understanding and subsequently supporting the development of the necessary skills for heat decarbonisation? (Yes/No) Please highlight any emerging skills/roles which we should support.

Yes, we agree that the Welsh Government has a key role to play in supporting the development of the necessary skills for heat decarbonisation. Modelling carried out by the Construction Industry Training Board (CITB) suggests that an additional 12,000 full-time equivalent (FTE) construction jobs will be required in Wales by 2028, the majority to deliver improvements to reduce energy demand in existing buildings. This represents both a challenge and an opportunity for Wales. The retrofit sector in Wales, and the insulation sector more specifically, will need to attract and train new entrants to deliver the volume of installs required to meet net zero. It will also require large-scale training and upskilling of the existing workforce. Retrofit training will demand significant investment from devolved government. Therefore, the NIA would like to see the Welsh Government work with retrofit employers and training providers to widen the provision of retrofit training across the country. This could involve helping employers and training providers to offer subsidised training courses, particularly for roles where there is a shortage, such as Retrofit Coordinators and Retrofit Assessors.

We are pleased to see that the Welsh Government is committed to exploring opportunities for early years and young people to enter the heat decarbonisation sector. There is a clear need for this – according to research by the recruitment brand Reed, current rates of retrofit recruitment will need to triple if Wales and the rest of the UK are to meet our shared net zero 2050 target.1 It is important that industry and government to work together to attract new entrants into the sector. This is something that the NIA is keen to support the Welsh Government with.

The Welsh Government has a key role to play in support the development of the necessary skills for heat decarbonisation in Wales. Targeted investment in retrofit skills will have the added benefit of creating thousands of high-quality and sustainable jobs in communities across Wales. A report published in 2021 by the Future Generations Commissioner for Wales estimated that 26,500 new jobs could be created by 2030 as part of a long-term strategy to decarbonise housing in Wales. The localised nature of most energy efficiency work means that many of these jobs will be created locally within Wales. Hence, Wales can retain the job and growth opportunities offered by the net zero transition.

Costs: Do you agree with the position set out in the strategy that the UK Government should move environmental levies from electricity bills to general taxation? (Yes/No) What additional policies should be implemented to ensure a fairer distribution of costs?

Yes, we agree with the Welsh Government’s plans to rebalance the levies on electricity bills. This is essential to kickstart the transition to low-carbon heat and make sure that it is affordable for consumers.

However, the Welsh Government should also prioritise increased investment in insulation measures as the most effective way to fairly distribute the costs of the transition to low carbon heat. Insulation can significantly decrease the heat demand of a property and cut heating costs. According to research by the Energy & Climate Intelligence Unit, raising the EPC of a property by one SAP band from D to C can reduce space heating demand by 20%.2 Insulation is the most effective way to make home heating affordable because it reduces energy demand and energy bills.

Taking a fabric-first approach is especially important when it comes to the installation of low-carbon heating systems, such as heat pumps. Heat pump efficiency is dependent on the flow temperature at which it operates, running at higher efficiencies when the flow temperature is lower. However, a property can only be adequately heated at low flow temperatures if it has a high thermal efficiency. Therefore, the installation of fabric efficiency measures prior to, or alongside, heat pump installation means a smaller, cheaper heat pump can be installed which will then operate at higher efficiencies over its system lifetime. If low-carbon heating is installed and then insulation added afterwards, consumers may be left with a heating system that is not proportionate with the property’s reduced space heating demand and therefore has capital and running costs that are unnecessarily high. It is vital that properties are as insulated as much possible before installing low-carbon heating systems to ensure they are sized correctly and cost less to run.

The most effective way to ensure that the public can afford the switch to decarbonised heating is by following a fabric-first approach. Insulation will safeguard consumers from increased heating costs, thereby ensuring a just transition to low-carbon heat, especially for those vulnerable groups most at risk of falling into fuel poverty due to energy bill increases.

Section 4: Improving the energy performance of our homes

Do you agree that stronger regulation is needed to encourage the uptake of low carbon heat and more energy efficient homes? (Yes/No) What other interventions must be implemented alongside stronger regulation to ensure no one is left behind?

Yes, the NIA agree that stronger regulation can support uptake of low carbon heat and energy efficiency measures. This is particularly true for Minimum Energy Efficiency Standards (MEES) which require homes to be above a certain EPC. Having higher MEES will encourage more homeowners to invest in the energy efficiency of their properties. MEES are an integral part of improving conditions in the Private Rented Sector whereby tenants are reliant on landlords to invest in energy efficiency measures that will reduce their energy bills and improve their thermal comfort. The UK Government had proposed several amendments to MEES in its 2020 consultation on ‘Improving the energy performance of privately rented homes’. Although it has since abandoned these commitments, as signalled by the Prime Minister’s speech in September 2023, the NIA would like to see the Welsh Government commit to adopting these proposals in Wales. These would improve energy efficiency standards in the private rented sector and improve thermal comfort for private tenants. These proposals include:

  • The minimum EPC rating increasing from an E to a C, which would require investments to be made to reach the standard before a property can be rented out. EPC C would need to be reached by 2025 for new tenancies and 2028 for existing tenancies.
  • The increase in the cost cap from £3,000 to £10,000 per property, which would allow for investment into measures that have a real impact on the thermal comfort of the property.
  • The integration of the fabric first approach, which requires investment in the fabric of the building (lost, cavity or external wall insulation, double windows and doors) prior to other improvements such as heating system upgrades.

Most regulations and targets in the energy efficiency sector are based on EPCs. These underpin our understanding of the efficiency of properties in the UK therefore, they need to be as accurate as possible. The NIA believe that important reforms to EPCs are needed to ensure that households get reliable advice on how to improve their properties. We would support the introduction of similar EPC reforms to the ones currently being proposed by the Scottish Government. These proposed reforms include:

  • A separate fabric rating alongside existing metrics to draw attention to the energy efficiency of the property specifically. This supports the fabric first approach.
  • A metric for the type of heating system in the property. This will support the transition to low carbon heat as it will highlight the carbon intensity of the heating system as well as the running costs. This enables informed decision making for consumers as we transition towards net zero.
  • Improving the explanation of the recommendations given to the consumer to ensure they understand why measures have been suggested and what benefit they offer.

By introducing similar reforms, the Welsh Government could ensure that EPCs more effectively support Wales’ heat decarbonisation pathway by incentivising investment in low carbon heating systems and energy efficiency measures.

Along with this, it will be important for government schemes to target the worst performing or hardest to treat homes first as they may incur the highest cost to the homeowner and be the most dangerous to live in. The effects of exposure to cold homes include poor mental and physical health due to inadequate indoor air temperatures (too cold or too hot), high humidity levels which can lead to mould, high noise and poor air quality. It is estimated that the NHS spend over £540 million each year treating people affected by living in the worst performing properties in England. However, this is a solvable problem, the BRE Group in its’ 2023 report on the Cost of Poor Housing in England by Tenure estimated that of the homes in the PRS experiencing excess cold the average cost to mitigate this is £6,835, which if the MEES reforms were actioned would be under the maximum spend for landlords of £10,000. There are similar average mitigation costs for excess cold across owner occupiers (£6,690) and social homes £3,800). The NIA believe that the worst performing homes need to be supported to improve across all housing tenures and no household should suffer with the effects of poorly performing homes.

Holistic approach to fuel poverty: The Warm Homes Programme has been offering new gas boilers, where appropriate, to those eligible., Do you agree that our future investments in energy efficiency must, where possible, simultaneously support our heat decarbonisation pathway? (Yes/No) Please explain and expand on opportunities to address fuel poverty holistically.

Yes, a holistic approach to fuel poverty which simultaneously supports both energy efficiency improvements and the transition to low carbon heat is crucial. This should revolve around a whole-house, fabric-first approach to heat decarbonisation.

When upgrading or decarbonising a property’s heating system, it is important to assess and upgrade (where necessary) the property’s energy efficiency. As discussed in our response to Question 8, improving a property’s fabric performance will facilitate the installation of a more efficient and cost-effective heating system, thus making the transition to low-carbon heat smoother and more affordable for residents.

A holistic, fabric-first approach is particularly important when it comes to those in fuel poverty, as it ensures that the transition to low carbon heat is affordable. Taking a whole house approach that installs insulation improvements in conjunction with a low carbon heating system will make sure that those in fuel poverty will not see any increase in their heating costs when they transition to a low carbon heating system. As such, a holistic fabric first approach to heat decarbonisation is the best way to ensure that the transition does not place a cost burden on fuel poor households.

Traditional buildings: Do you agree that demonstration projects for historic and traditional building retrofit are needed? (Yes/No) Are there further interventions needed to grow the market for traditional building retrofit?

Yes, we would welcome demonstration projects for historic and traditional building retrofit. These buildings are often avoided as they are perceived as too difficult to retrofit, however this means that they are excluded from the benefits of energy efficiency measures. There is also a significant skills and knowledge gap when it comes to retrofitting traditional and historic buildings. The Retrofit Academy have recently released a new qualification targeted at historic and traditional buildings which is a good step towards addressing this skills gap. The introduction of demonstration projects would be another very useful step as they would encourage new, innovative approaches and the sharing of best practice around hard to treat buildings.

It can be very difficult to get planning permission for retrofit projects on historic and traditional buildings. Thus, it is important that the Welsh Government adopts a joined up approach to retrofitting them which involves Local Authority planning departments in the process. This should help to streamline the process for retrofitting historic and traditional buildings and also make sure that retrofits are compliant with all the requisite planning requirements.

Section 7: Taking action

Our pathway: The strategy is based on the Climate Change Committee’s Balance Pathway. Do you agree with this approach? (Yes/No) Please explain.

Yes, we agree that this is a sensible approach.

Energy Performance Certificate reform consultation

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.

Domestic Energy Performance Certificate Metric Reform Proposals (MR)

Do you agree with the set of metrics that we propose to display on the reformed EPC?

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.

Are there additional metrics that you think should be included on the EPC, or metrics that you do not think should be included?

No, we agree with the metrics included.

Considering our proposal to include a Fabric Rating on EPCs, do you think this metric should include domestic hot water heat demand?

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.

Do you have a view on the way that the Fabric Rating mapped against a scale, for example, how ‘A’ or ‘G’ rated performance is determined?

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.

Do you agree with our proposal to give more prominence to the energy efficiency features of the home (such as the depth of loft insulation)?

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.

Non-Domestic Energy Performance Certificate Metric Reform Proposals (MR)

Do you agree with the set of metrics that we propose to display on non-domestic EPCs?

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.

Are there any additional metrics that you think should be displayed, or any in the proposed set that should not be included?

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.

EPC Purpose and Validity (MR)

Do you agree with us that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to consider retrofit options?

Yes, we agree.

Do you agree that the validity period of EPCs should be reduced from 10 to five years?

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.

We welcome any views on the usefulness of our proposals for other relevant policy areas, such as fuel poverty or the delivery of government schemes. Please provide any comments you wish to share.

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.

Digital and Accessible EPC Format and Content (PA)

Do you agree with our proposal that EPCs should move from PDF to webpage format?

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.

Do you agree with our proposal to improve signposting to further support and advice schemes on the EPC?

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.

Do you agree historical EPCs should be publicly accessible on the EPC register (while clearly marked as historic)?

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.

Do you agree that the EPC register should be accessible by API?

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.

EPC Auditing and Assurance (PA)

Do you agree with our proposals to review and update the auditing and assurance requirements for EPCs in Scotland?

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.

Please detail any additional assurance activity that you think would be appropriate to enhance the accuracy and reliability of EPCs.

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.

Consultation Questions: Legislating for EPC Reform and Timeline (PA)

Do you have a view on our timeline for reform implementation?

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

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.

Should we maintain the current requirement for a valid EPC with no outstanding recommendations for loft or cavity wall insulation?

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.

If you consider the EPC requirements to be a barrier to uptake, what specifically do you consider to be the issue:

a) Requirement to have a valid EPC
b) Requirement to have a valid EPC with no outstanding recommendations relating to loft or cavity wall insulation
c) Other

Please select one of the above and provide evidence to support your response.

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.

If we retain the EPC requirements, are there any potential changes we could make to ease the consumer journey without risking heat pumps being installed in unsuitable properties? For example, allowing the submission of an expired EPC with no recommendations for loft or cavity wall insulation.

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.

If we retain the EPC requirements, are there any potential changes we could make to ease the consumer journey without risking heat pumps being installed in unsuitable properties? For example, allowing the submission of an expired EPC with no recommendations for loft or cavity wall insulation.

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.

NIA calls on Government to release SHDF Wave 3 in Autumn Statement

NIA calls on Government to release SHDF Wave 3 in Autumn Statement

The government’s recent steps back on green policies are a cause for concern in successfully decarbonising the UK’s homes. Speaking on behalf of its members, the chairman of the National Insulation Association (NIA), Derek Horrocks is calling on the government to sustain the momentum built so far in the sector – and to announce the release of the full £3.8bn of the Social Housing Decarbonisation Fund in the upcoming Autumn Statement, recommitting the government’s net zero manifesto pledge.

Click here to read our letter sent to the Prime Minister.

The UK is often described as having some of the oldest and least energy efficient housing in Europe meaning there is substantial work to be done to decarbonise some 27 million homes if we’re going to meet our ambitious targets. Over the course of this parliament, a long-term plan to fund decarbonisation of social housing has been built, and the scale and ambition of the Social Housing Decarbonisation Fund has attracted significant investment and forward-thinking contributions from the construction industry.

Despite this, Prime Minister Rishi Sunak has chosen to back pedal on a number of green policies that risk substantially slowing progress. This all feels like a big step back in net zero agenda and we’re urging the government to be more ambitious in the short term.

Confidence across the market has been severely shaken through the government’s announcement to scrap policies to force landlords to upgrade energy efficiency in their homes, instead only ‘encouraging’ households to carry out the work. Meanwhile, the phase out of fossil fuel boilers has been pushed back significantly, along with disbanding the energy efficiency taskforce intended to speed up home insulation and boiler upgrades, which was only launched in March of this year.

This may have a knock-on impact for the work in the social housing space, which is the catalyst for everything else. It’s the way we build our supply chain, skills, and innovation – so when businesses in the private decarbonisation sector accelerate this work, the foundation is already there. The government’s commitment thus far has played a key role in forging partnerships between industry, social housing providers, education providers and more to drive retrofit at scale.

Only days before the announcements, the National Housing Federation’s chief executive Kate Henderson urged the government to not let net zero slip down the political agenda and to make sure housing associations have the vital funding required to play their part in meeting targets.

This is a message that the NIA and its members wholeheartedly echo. The decarbonisation sector needs certainty and confidence in the long-term to invest in the supply chain – and it’s clear that the recent announcements have damaged that confidence, causing concern that a step back will come for social housing decarbonisation too.

The Social Housing Decarbonisation Fund (SHDF) has seen great success, but with Wave 2 schemes already allocated that long-term certainty for all is still needed. The PM himself said that his government would ‘continue to subsidise energy efficiency’, and with £3.8 billion already allocated to Wave 3 of the fund, we’re calling on the government to announce and bring forward this funding in the Autumn Statement.

This should be accompanied with details of the competition and an aspiration for successful bids to be announced before the end of the fiscal year. This would be the clear signal to housing providers, and the decarbonisation supply chain to continue the investment in innovation, skills and training at scale – continuing to build the foundation for the drive to net zero.

So much momentum has built over recent years, and we simply cannot let that go to waste and descale the industry. Many contractors and housing providers have invested huge amounts of time, resource and money to invest in the skills, innovation and processes to carry out the work needed – and in many cases has shaped parts of their business plans too when it comes to investing those resources. It’s important that we further the agenda to provide home decarbonisation at scale more quickly and efficiently than ever. Collaboration at scale and a community-driven approach are definitely key to this.

Ultimately, we have to remember that decarbonising homes is about much more than just achieving net zero. It’s also about supporting millions of people feeling the impact of the ongoing energy, cost of living, and health crises too – so the sooner we get these homes decarbonised, the better for society all-round.

We have as a collective, in conjunction with the National Home Decarbonisation Group, written to Prime Minister Rishi Sunak to engage on ensuring the all-important momentum needed. We also look forward to continuing our close working relationship with the government to achieve collective goals, starting with this recommitment to the net zero manifesto pledge in the upcoming Autumn Statement through releasing the full £3.8bn Social Housing Decarbonisation Fund to help decarbonise the UK’s social homes.

Energy Company Obligation schemes: Standard Assessment Procedure (SAP) and Reduced Data SAP (RdSAP) amendments

Energy Security and Net Zero Committee Call for Evidence: Heating our Homes

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.

For ECO4 retrofits where a full SAP assessment is required, do you agree with the proposal to update legislation to require that, after a transition period, only SAP10.2 be used?

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.

Do you agree with a six-month transitional period from the date the amended legislation comes into force, during which either SAP2012 or SAP10.2 can be used for ECO4 retrofits that require a full SAP assessment? If not, please provide details of alternative transition arrangements?

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.

Of the three options presented here for evidencing:
3.1 Which is your top preference and why?
3.2 Which is your second preference and why?

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.

For options 1 and 2, do you agree that 3 months following the introduction of RdSAP10.2 is sufficient to allow the completion of retrofits?

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

Option 2 involves converting pre-retrofit SAP ratings from RdSAP2012 to RdSAP10. When this conversion takes place on the pre-retrofit SAP rating, there is a chance that some ECO4 retrofits may no longer meet the ECO4 minimum requirement (MR). What do you think the best approach would be to minimise this risk?

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.

Do you agree with our proposal to not require Ofgem to update their scoring methodology for ECO4 following the change from SAP2012 to SAP10.2?

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

Do you agree with our proposal to not require Ofgem to update their scoring methodology for the GB Insulation Scheme following the change from SAP2012 to SAP10.2?

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.

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Energy Security and Net Zero Committee Call for Evidence: Heating our Homes

Energy Security and Net Zero Committee Call for Evidence: Heating our Homes

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.

What policy changes are needed to deliver energy efficient homes across the UK?

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.

What are the key factors contributing to the under-delivery of the UK’s government-backed retrofit schemes?

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.

Which standards and assessment frameworks are needed to deliver a reliable, skilled workforce capable of transitioning UK homes to modern heating solutions?

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.

How might the Government support innovation in delivering local solutions?

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.

What role should customer choice play in the future planning of energy networks for home heating?

Does the current state of consumer protections for low-carbon home technologies represent a barrier to uptake of these products?

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.

How will the public be able to afford the switch to decarbonised heating?

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.

How will decarbonisation plans be drawn up in each area?

Do the current EPC frameworks help consumers make informed decisions on transition?

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.

Do standards need to differ for different types of housing?

What is the role of different levels of government in developing, funding and implementing schemes?

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.

Net Zero APPG Myth Busting Report – NIA Policy Summary

Net Zero APPG Myth Busting Report - NIA Summary

The Net Zero All Party Parliamentary Group (APPG) has published a report aimed at dispelling myths and misinformation surrounding the Net Zero transition. It highlights the need for accurate information and a shared understanding of the path towards Net Zero among policymakers, industry leaders and citizens. It emphasises the role of education, communication and behaviour change and notes the challenge of effectively communicating climate change issues – and the importance of using language that the general public can understand. Ultimately, the report aims to debunk myths, provide clarity, and drive real behaviour change to accelerate progress towards Net Zero.

The Net Zero APPG – Who are they?

The Net Zero APPG aims to accelerate the transition to a low carbon and affordable future, embed zero carbon solutions and achieve Net Zero growth and innovation, as a well as a carbon-neutral economy in the UK. The APPG promotes cross-party debate, consensus, and support to effectively address the climate change challenges. Their overarching aim is to unlock green innovation investment and incentives while driving better communication and changing the narrative surrounding Net Zero.

Why the narrative needs to change?

In the foreword of the report, Lord Deben summarises why the narrative needs to change:

  • Terms related to climate change are not well understood, such as ‘retrofit,’ ‘modelling,’ and ‘sequestration.’
  • People struggle to grasp concepts like ‘kilowatt-hour’ because it cannot be felt, touched or seen.
  • To engage people, it is more effective to discuss how climate change affects their bills and emphasisethe financial benefits of home improvements that save energy.
  • Statistics need to be translated into relatable experiences for the audience, for example understanding that just over 1°C of warming can have a significant impact on global weather patterns and can cause extremely hot weather.
  • Experts have historically prioritised scientific communication over effective public engagement – this needs to change to build public support for Net Zero.
  • Lack of understanding of climate change terminology can lead to the spread of myths.
  • The language we use to talk about climate change is crucial because it influences people’s actions.

Debunking some Net Zero Myths

In tackling the challenge of achieving Net Zero in the UK, the APPG makes clear that it is important to address the misconceptions, misinformation and myths surrounding the climate change narrative.

To accelerate behaviour change and promote informed decision making, effective communication is paramount and while it may not always be possible to completely dispel every myth, the Net Zero Myth Busting Report aims to provide policymakers with better information. The report seeks to highlight areas of consensus and identify the key areas that warrant greater debate and clarity from Government so that there is a more accurate understanding of the challenges and solutions on the road to Net Zero.

Myths highlighted in the Net zero appg myth busting report

#1 Net Zero is bad for growth and pushes up costs

#2 Getting to net zero costs

#3 We don’t have the green skills and jobs we need to scale up and get to net zero

#4 Our cities are bad for the environment

#5 Carbon capture and storage (CCS) is counterproductive and unnecessary

#6 Nuclear power isn’t a clean energy source too much money

#7 Renewable energy is too reliant on the weather, and too expensive

#8 It’s just not possible to make all homes energy efficient

#9 Tenants jump at the chance to retrofit their homes if it’s free

#10 Heat pumps are too expensive and don’t work in old properties or in cold temperatures

#11 Green hydrogen is the ‘silver bullet’ for Net Zero Homes and buildings

#12 Consumers will always choose the sustainable option

#13 It’s too expensive to electrify our railways

#14 We need more electric vehicle charging points to match demand

#15 We don’t need more road capacity to reach Net Zero

#16 All buses must be Net Zero emission if we are going to reach our decarbonisation target

#17 Hydrogen plans will deliver Net Zero aviation

#18 Jet Zero won’t happen and can’t be delivered by 2050

#19 Focusing on reaching Net Zero by 2050 is enough to tackle the climate emergency

#20 It’s too hard to decarbonise our Ports

#21 The UK will need to import plant- based alternatives to replace its meat and dairy products to reach Net Zero

#22 We just need to reduce carbon to get to Net Zero

#23 Recycling is the best way for me to do my bit for the planet

A Summary of Recommendations

After reviewing the report and examining the myths and recommendations, we have identified the key insights relevant to energy efficiency in buildings. The relevant myths, ‘myth busts’ and recommendations are shown in the table below. Please note that each response reflects the opinion of the author and not the collective view of the Net Zero APPG and its supporters.

Climate Change Committee – 2023 Progress Report to Parliament

Climate Change Committee – 2023 Progress Report to Parliament

On 28th June 2022, the Climate Change Committee published their Annual Progress Report to Parliament. The CCC have reviewed the impacts of the government’s net zero strategy and policies across all sectors and analysed its adequacy. Set out below is a summary of the report.

Energy Efficiency

Overall, the CCC declared that their confidence in the UK meeting its carbon reduction targets has decreased over the last year. The CCC’s Monitoring Framework, which measures the UK’s progress towards net zero, concluded that progress on energy efficiency measures is “significantly off track”. Progress against the CCC’s recommendations from last year has largely been insufficient. In particular, no progress was made in introducing a clear, implementation focused policy to ensure owner-occupied homes reach a minimum energy performance of EPC C by 2035.

Despite the Government detailing its ambition to decarbonise buildings in 2021’s Heat and Building Strategy, the CCC’s Progress Report notes that all major progress indicators are falling behind, with the possible exception of overall emissions reduction. In this area, there has been a 16% decrease since 2022 in emissions from homes. However, the CCC noted that this headline decrease was largely due to high energy prices and milder than usual weather. Adjusting the data to account for temperature-related factors reduces the decrease in residential emissions to just 6%. It also observed that reductions in emissions and energy use are unlikely to continue without further policy interventions.

While the CCC reiterated its support for upcoming changes to regulation, including the implementation of the Future Homes Standard, there is a sense that the current pace of decision making is not fast enough to deliver Net Zero commitments. Slow decision making is creating uncertainty right across the sector, ranging from how to deliver sufficient retrofit measures to investment decisions in skills and building supply chains.

The CCC also point to the need to give greater attention to policy gaps relating to non-residential buildings. Temperature-adjusted emissions show an increase of 5% in emissions from non-residential buildings since 2022. This is partly due to a rebound in the number of people returning to office work after the pandemic, however, there is still an urgent need for more policy certainty in this area. Currently, “There are no convincing plans to decarbonise commercial buildings”, according to the CCC.

Progress reported for specific indicators are as follows:

  • Despite an increase in funding available for social homes, actual numbers of installations have not yet increased, and installations under ECO also lag behind the CCC’s pathway expectations with each iteration of ECO delivering fewer measures, and ECO4 starting slowly.
  • The uptake of energy efficiency measures remains slow, especially in the owner-occupied and private-rented sectors, despite the energy crisis providing an increasingly clear financial incentive to retrofit properties
  • Public sector and commercial buildings also require an increase in the uptake of fabric energy efficiency improvements.

The CCC reported that 77% of building related emissions in the 6th Carbon Budget are judged to be “at significant risk, or with insufficient plans”, highlighting significant policy gaps in this sector. They judged that the greatest policy gap is in dealing with energy efficiency in non-fuel-poor homes. For each sector, a number of specific recommendations have been set out to address the evident policy gaps, which we have summarised below.

Recommendations

The CCC report classes energy efficiency improvements to existing buildings as a “no-regret” option for the decarbonisation of buildings.

As an urgent priority, the CCC has called on the Government to finally respond to the 2020 consultation on requiring that homes in the Private Rented Sector (PRS) meet an EPC C by 2028. This response was promised at the end of 2021. This substantial delay and a lack of policy certainty from Government is holding back progress in this area.

A comprehensive home energy retrofit scheme is required to provide long term funding for consumers and supply chains and support the installation of energy efficiency measures. It is also necessary to consider a whole building approach that will be effective across multiple building archetypes, including those that are traditionally difficult to retrofit, such as large blocks of flats.

Workforce and Skills

‘Workforce and skills’ is another area where the CCC rated progress as being off track for achieving Net Zero. In particular, the CCC has warned that there are insufficient plans in place in terms of the ambition and timelines required in the skills sector to facilitate Net Zero. Progress is being made in specific areas, but a lack of clear strategy means that overall change is slow and fragmented. Clearer plans are needed from government to harness the potential of the transition and manage its risks.

The sector has clear cross-cutting implications on the transition in the energy efficiency sector, so slow progress in this area poses a serious risk to meeting our net zero targets in terms of decarbonising buildings.

Moving forward, there is potential for the Net Zero transition to create more jobs than will be lost. Between 135,000 and 725,000 net new jobs could be created by 2030 in low-carbon sectors, with the majority of these expected to come in the buildings retrofit sector. However, this is contingent on having a clear green skills strategy in place.

Broadly speaking, there is expected to be increased employment in growth sectors such as the retrofit sector. Low Carbon and Renewable Energy Economy (LCREE) employment across the UK grew 16% from 207,800 in 2020 to

247,400 in 2021, representing the largest year-on-year increase recorded. Over the same period, total UK employment only grew by 6%.

There are a number of key barriers in this sector that need to be overcome to reach Net Zero:

  • Lack of clear strategy from government
  • Inadequate supply of skilled workers
  • Lack of long-term certainty around investment incentives and sector demand
  • Competition from overseas
  • No consistent UK-wide evidence is available for monitoring progress on green skills
  • Low levels of diversity in the Net Zero workforce
  • Potentially disruptive impacts for some communities (i.e. job losses)

Recommendations

The CCC made a series of recommendations on actions the Government must take to ensure that the workforce and skills is in place for us to deliver on our net zero ambitions in the retrofit sector.

Meeting or Missing the Milestones: Committee on Fuel Poverty Annual Report 2023

Policy Summary: Meeting or Missing the Milestones: Committee on Fuel Poverty Annual Report 2023

Introduction

The Committee on Fuel Poverty (CFP) has published their latest annual report today, which assesses progress towards the Government’s 2030 fuel poverty statutory target and 2025 fuel poverty interim milestone. The report also makes a series of recommendations to Government on how they can address fuel poverty in order to meet these targets.

The Government has already declared its intention to review the 2021 Fuel Poverty Strategy, which is vital if it is to meet the 2025 and 2030 targets. This report is expected to inform the Government’s review.

Below is a summary of some of the report’s key findings and recommendations.

You can also read the full report here.

The Government’s Fuel Poverty Targets

The government’s statutory fuel poverty target is to ensure that as many fuel poor homes as is reasonably practicable achieve a minimum energy efficiency rating of Band C, by 2030. The interim milestones are:

  • As many fuel poor homes as is reasonably practicable to Band E by 2020
  • As many fuel poor homes as is reasonably practicable to Band D by 2025

Wider Context

  • The last Annual Report was published in October 2021. Since then there have been a series of shocks to the UK economy which have hindered progress towards the Government’s fuel poverty targets.
  • Since 2021, soaring fuel prices have forced 287,000 more households into fuel poverty. On the other hand, energy efficiency measures have contributed to some 145,000 households being removed from fuel poverty, whilst increased incomes have lifted 48,000 out of fuel poverty. The net effect is an increase of 100,000 more households being in fuel poverty compared to 2021.
  • The Government forecasts a further rise in fuel poverty to 3.53 million this year (a rise of 270,000), and a further widening of the fuel poverty gap to an average of £443 per household, an increase of 31%.

2020 Milestone

  • The 2020 Fuel Poverty milestone has already been missed and an unacceptable number of CFP recommendations have yet to be acted upon.
  • The 2020 milestone to ensure that as many fuel poor homes as is reasonably practicable achieve a minimum energy efficiency rating of Band E has still not been met. This does not bode well for meeting the 2025 milestone.

2025 Milestone

  • The 704,000 properties in England rated E, F and G require urgent upgrading, or the second 2025 milestone will be missed.
  • According to the Government’s own assessments, published in a response of 18 January 2023 to an Environmental Information Regulations request, “Current announced policies are expected to upgrade around 140,000 E-G homes to D+ by 2025. This would result in 515,000 fuel poor households still being rated E-G in 2025.”
  • To ensure that low income households are living in homes that are at least Band D rated by 2025, the Committee has identified two things as essential: o That all such households are easily, cost-effectively, identified.
  • That energy efficiency programmes are well-targeted at those households

2030 Milestone

  • Achieving the 2030 target will involve upgrading approximately 3.26 million D-G rated households to a C rating.
  • To meet the 2030 target, the Government will have to upgrade to a C rating at least 365,000 D rated properties per year from 2023 to 2030.

Key Recommendations

  • The report makes 5 broad recommendations on how the Government can address fuel poverty in England in order to meet its fuel poverty targets. They are:

    1. Ensure a robust Fuel Poverty Strategy and effective measurement of fuel poverty that leaves no one behind.

    2. Improve targeting of payments to support bills and better targeted energy efficiency programmes to meet the government’s milestones.

    3. Improve affordability of bills through fairer pricing and better regulation to protect the fuel poor.

    4. A shared mission to tackle fuel poverty adopted by government, local government and the NHS.

    5. A fair transition to net zero that does not increase fuel poverty.

Table of Recommendations and Calls to Action

These 5 key recommendations are underpinned by 19 calls to action, which are laid out in the table below.

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