News

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

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

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

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

No, we agree with the metrics included.

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

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

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

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

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

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

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

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

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

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

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

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

Yes, we agree.

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

Reducing the validity period to 5 years would allow a more up-to-date and greater coverage of EPC data across the housing stock. It would also provide a more accurate picture of the UK housing stock and its energy performance for policymakers, businesses and consumers. The Government.

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

This represents a significant challenge for industry and government. Therefore, the NIA would like to see the Scottish Government work with retrofit employers and training providers to widen the provision of retrofit training across the country. The Home Decarbonisation Skills Training Competition has been very successful in England and is now in its second phase.2 When we signposted members towards this latest pot of skills funding, we had interest from Scottish members who enquired about whether Home Decarbonisation Skills Competition funding was available in Scotland (which unfortunately it is not).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Closing Date: 12 October 2023
Response submitted by: National Insulation Association
For more information, please contact: info@nia-uk.org

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

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

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

Secondly, if a heat pump is installed followed by insulation, consumers may be left with a heating system that is not proportionate with the property’s reduced space heating demand and therefore has capital and running costs that are unnecessarily high. The installation of fabric efficiency measures prior to, or alongside, heat pump installation means a smaller, cheaper heat pump can be installed which will then operate at higher efficiencies over its system lifetime. For these reasons, a fabric-first approach has been incorporated into government policy and accepted as industry best practice for a number of years.

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

Consumer confidence is a crucial element of the transition to low carbon heat. The Government has set ambitious targets for the decarbonisation of heat, including to install 600,000 heat pumps per year by 2028, rising to 1.9 million per year by 2035.4 For these targets to be met, consumers must be on board. If residents find that their heat pump is overly expensive or incorrectly sized as a result of inadequate insulation, then this may have damaging effects on consumer confidence, which could hinder the uptake of heat pumps. Thus, the importance of a fabric first approach cannot be ignored, as insulation will be key to ensuring that the transition to low-carbon heat is as smooth and cost-effective as possible for consumers.

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

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

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

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

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

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

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

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

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

Closing Date: 11 September 2023
Response submitted by: National Insulation Association
For more information, please contact: info@nia-uk.org

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Call for evidence – Committees – UK Parliament

Closing Date: 25 August 2023

Response submitted by: National Insulation Association

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

About the National Insulation Association

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The most effective way to ensure that the public can afford the switch to decarbonised heating is by following the fabric-first approach. Insulation can significantly decrease the heat demand of a property and cut heating costs. According to research by the Energy & Climate Intelligence Unit, raising the EPC of a property by one SAP band from D to C can reduce space heating demand by 20%.5 Insulation is the most effective way to make home heating affordable because it reduces energy demand and energy bills.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Closing Date: 16 June 2023

Response submitted by: National Insulation Association

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

About the National Insulation Association

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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