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 this standard excludes most of the qualified, experienced and quality assured specialists 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.
A risk to good green jobs
All commercial buildings in the UK require Energy Performance Certificates (EPCs) at the point when they are constructed, sold or let.
The role of the NDEA is predominantly site based and involves the collection of commercial property data concerning construction details, glazing, heating, ventilation, air conditioning, lighting and much more. NDEAs are trained to collect and enter this data into approved Simplified Building Energy Model (SBEM) software which is used to calculate the energy performance of the property and to produce an EPC.
At level 3, the NDEA qualification covers everything required to conduct an energy assessment of an existing commercial building with common characteristics and a simple air-conditioning system. At level 4, it covers buildings which have more complex heating, ventilation and air-conditioning systems. The level 4 diploma also equips the NDEA to produce EPCs for new build commercial buildings.
All of this is needed for PAS 2038, and an additional course can quickly upskill NDEAs and Display Energy Certificate Assessors with any other PAS 2038 specific knowledge, guaranteeing the much-needed human resources and quality assured expertise to deliver this scheme.
That’s why we believe so strongly that 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.
Reinventing the wheel
The draft PAS 2038 seems to be ‘reinventing the wheel’ where there is already a major energy assessment industry to deliver the requirements.
Indeed, 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.
Staying consistent
We also believe that the proposed PAS 2038 needs to make use of SBEM – the regulated, Government-approved methodology which embodies the National Calculation Method that is already used to underpin other energy efficiency regulations and legislation.
SBEM calculations provide authentic data on the context and energy performance of a building, but strangely there is no inclusion of SBEM calculations within the draft PAS.
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 is a legal, approved and regulated assessment method used to identify the in-use energy consumption of a building. It is already written into the schema of UK energy assessment. Yet the current draft PAS is promoting a different occupational rating model.
There is no logic to this. 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.
Wait and see
Elmhurst’s members made their views very clear and we have fed those back to BSI. So, for now, we need to wait and 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.
Don’t get me wrong – it is great to see an advancement and focus on non-domestic buildings within PAS 2038. We totally support the aims of this new specification. PAS 2038 could be a very important standard for the non-domestic sector, especially if government adopt it as a prerequisite for grant support.
The deep retrofit approach of assessing the needs of the building and the occupant are equally applicable to commercial buildings as they are domestic. With the move to zero carbon the demand should be high. The country will need competent assessors who already enjoy good business links with commercial building owners, who can help build the market, promote the benefits, and who have the knowledge, skills, experience and tools to undertake such retrofits.
So, we will be fighting to ensure that the skills of the professionals already working in this market are recognised, good green jobs are retained, and that the industry builds upon what it has already delivered, rather than reinventing the wheel.
Stuart Fairlie is Technical and Operations Director at Elmhurst Energy
