The one thing you can guarantee is that nothing stays the same for long in domestic energy efficiency. Whether its policy, scheme rules or Technical Monitoring Question Sets, the only thing that is constant is change. And it’s because of that rapid rate of change, it’s more important than ever we stay one step ahead.
As a Technical Monitoring Agent and member of ATMA, we often have the benefit of being consulted on changes, observe how the supply chain react before seeing the end result from a compliance perspective when we inspect the work. This can be both enlightening and frustrating, particularly if we are proven to be correct in relation to avoidable negative end results. We refer to these as ‘unintended consequences’ which emanate from the choices we make when insulating buildings. This same phenomenon exists at a macro level when we set new policy or apply new rules or restrictions.
Policy decisions have long driven the direction of travel in the domestic energy efficiency sector and so they should. Carefully thought out strategies to drive the industry forward and enable effective de-carbonisation of households is vital. However, as we have seen with examples such as the loophole in ECO3 legislation that allowed the boiler replacement cap in ECO3 to be disregarded, when installing a qualifying insulation measure (such as Underfloor Insulation) alongside it. These unintended consequences have dramatic impacts on the measure mix which can rapidly alter:
- Material purchasing trends
- The skill sets required to deliver ECO measures
- Technical Monitoring Results (generally as less popular measures become more main- stream we see poorer compliance as install teams take time to get to grips with a new measure)
- How effective we are at approaching domestic retrofit with a whole-house approach.
So, what’s the next big change?
The biggest immediate change we see is a dramatic reduction in the number of Internal Wall Insulation (IWI) measures installed under the remainder of ECO3. Prior to the COVID-19 pandemic solid wall insulation contributed to around 12,000 ECO measures per month, with about half of these being IWI. The imminent change in ECO3 to only permit IWI to be installed where 100% of the external heat loss walls are treated (including kitchens and bathrooms) will dramatically reduce the number of measures installed.
The short-term temporary effect will be to drive these measures into the Green Home Grant Voucher Scheme (GHGVS). Why? Because policies on this measure specific ruling are not aligned. The GHGVS – whilst demanding greater attention is paid to more risky measures such as IWI by requiring compliance with PAS2035 still allows only part of the property to be treated, as long as the remaining areas (For example kitchens and bathrooms) are included in the Medium-term plan for the dwelling.
What does this mean for IWI in ECO3?
Initially we expect IWI measures to continue to flow through, as policy change always takes time to filter through, with the likely result being an increase in non-compliant measures. Of course, there will be some electrically heated properties, particularly in the private rented sector that attract enough funding to replace relatively small or modest existing kitchens and bathrooms. Other than that, until we see an increase in ECO funding to enable the cost of replacing existing kitchens and bathrooms to be absorbed, we anticipate IWI will largely disappear from the measure mix.
With that, there will no doubt be some pain ahead along with plenty of frustration, resistance then eventually acceptance and adaption. The Kubler-Ross change curve comes to mind; http://changemanagementinsight.com/kubler-ross-change-curve-model/
There will also be confusion and no doubt some challenge back to regulators and policy makers as the application of different rules under different schemes is difficult to comprehend. It also raises the question over why IWI can be delivered under PAS2035 as part of the Whole Dwelling Medium-term Improvement Plan under GHGVS but not under ECO? The Retrofit Co-ordinator is certainly going to earn his money in the coming months and be left with some interesting dilemmas.
For what it’s worth, moving to a position where the whole house is treated to avoid issues with thermal bridging and the challenges of sealing edges and junctions (particularly where IWI meets wet rooms that aren’t being treated) is one that THS absolutely support, where practicable. However, to implement it now, out of sequence with the simultaneous tacit approval for omitting areas under the GHGVS will at best cause confusion. At worst it will result in non-compliant installations that need to be re-visited and remediated at great cost or even un-installed completely where bathroom fittings cannot be removed and replaced.
When it comes to ongoing regulatory change, there may well be a bumpy road ahead! We might just have to hold onto those hats a bit more tightly over the coming months but at THS we here to help you every step of the way. For advice and support on how to reduce the risk of Technical Monitoring fails, or for information on how IWIcheck can support your compliance with PAS2030:2019, contact us firstname.lastname@example.org