Blog from Stuart Fairlie: Don’t reinvent the wheel for commercial property retrofit

In the same way that Government-approved technical standards provided the foundation for the Green Homes Grant and the low energy retrofit of millions of UK homes, so similar energy efficiency standards are now being developed that should pave the way for the retrofit of commercial buildings.

The only trouble is, the first draft of these standards seems to exclude most of the qualified, experienced and quality assured people with the ability to deliver them.

Unsurprisingly then, the official consultation on proposed new technical standards for retrofitting the UK’s offices, shops, hotels and other non-domestic buildings for improved energy efficiency has received howls of protest from professional energy assessors.

A PAS is a ‘publicly available specification’, a sponsored, fast-track, consensus-building informal standard that is produced by the UK national standards body, BSI Standards Ltd.

PAS 2038 has been sponsored by the Department for Business, Energy and Industrial Strategy (BEIS) to establish the standards for ‘Retrofitting non-domestic buildings for improved energy efficiency’. The specification covers all buildings except those used as private dwellings (houses, bungalows, flats or apartments). However, non-domestic buildings do include multi-residential buildings in which occupants share some communal facilities, such as hotels, guest houses, hostels, and students’ and nurses’ accommodation.

The draft PAS 2038 sets out the requirements for the assessment of commercial buildings for retrofit, as well as the identification, design, installation and evaluation of measures that improve the buildings’ energy performance, including insulation, air-tightness and ventilation, heating, lighting and other essential areas that impact on energy efficiency.

Controversially, the current draft PAS excludes Non-Domestic Energy Assessors (NDEAs) and other qualified professionals from its list of competent people who could implement the specification.

This makes no sense.

NDEAs should have the opportunity to be part of the retrofit project team, using their well-established accreditation, quality assurance, insurance, knowledge, expertise and competency in the energy assessment industry.

The draft PAS 2038 seems to be ‘reinventing the wheel’ where there is already a major energy assessment industry to deliver the requirements. An additional course can quickly upskill NDEAs and Display Energy Certificate Assessors with PAS 2038 specific knowledge, guaranteeing the much-needed human resources and quality assured expertise to deliver this scheme.

As they stand now, these proposals could be an own goal for BEIS when it is trying so hard to build up a stronger market for low energy retrofits. There are more than 1,000 qualified and accredited assessors in Elmhurst Energy’s membership who are specialists in the commercial sector. They should be the first port of call for designing, promoting and delivering the energy efficiency scheme.

If excluded from this market, many opportunities will be missed and these vital ‘green jobs’ could be lost. But if engaged, these individuals, whose expertise and passion is to save energy, will be excellent ambassadors for the scheme and can rise immediately to the challenge of decarbonising our commercial property stock.

We also believe that the proposed PAS 2038 should make use of the regulated, Government-approved national calculation method that is already used to underpin other energy efficiency regulations and legislation.

An Energy Performance Certificate and SBEM calculation is currently used as a basis for many Government regulations. It seems arbitrary not to follow the same consistent method for assessing the energy performance of non-domestic buildings. If adopted, the current SBEM calculation that is already well known and well established in the commercial property sector will ensure a smooth and seamless transition into the retrofitting process for building owners.

The same applies for Display Energy Certificates (DECs). A DEC assessment should be listed as an equally appropriate method to calculate the energy usage of a building. We do not understand why a tested and proven method of calculating energy usage has not been employed as a crucial step within the retrofit assessment process.

So let’s see how this pans out. The consultation responses on the proposed PAS 2038 will now go forward for review, before publication of the finalised specification in the New Year.

Elmhurst’s three main points can be summarised as:

  • To acknowledge and include the role of existing accredited NDEAs and DEC assessors, suitably upskilled to meet the extended requirements of PAS 2038
  • To encourage the use of SBEM, the Government’s approved national calculation methodology which is currently used for assessing the energy efficiency of non-domestic buildings.
  • To encourage the use of DECs – the Government’s approved methodology for undertaking occupancy assessments – instead of CIBSE TM54.

To read Elmhurst’s consultation response in full, go to:

About the author: Stuart Fairlie is Technical & Operations Director, Elmhurst Energy



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