Energy Efficiency Consultation - A Welsh response

Welsh Government is consulting at the moment with the wider public about energy efficiency and their new strategy. Thankfully we now have the Future Generations Act and this means that we should NOT go blindly down the usual roots of using rubbish drivers like rdSAP, U values calculators etc. In Wales we MUST take into account issues like Health, Prosperity, Economic Development, Our Place in the Wider World etc.

So we stand a chance of getting it right (or at least better than we have for the past decade or so). The consultation document is available from the Welsh Government website (direct link given, or reference WG25502) or use this web address:
http://gov.wales/docs/desh/consultation/150617-draft-energy-efficiency-strategy-en.pdf

My comments are driven by the latest research that has been made available to DECC to organisations like BRE (Buildings Research Establishment), STBA (Sustainable Traditional Buildings Alliance), UCL (University College London). So Government and DECC know the issues around EPCs, rdSAP, Green Deal, Thermal Bridging, U value calculators etc. BRE already have demonstrated 126 unintended consequences associated with 'improvements' to solid walls!

However, it is a huge political issue as so much has been invested in these inaccurate and potentially dangerous tools. Welsh Government can choose (to a certain extent) to be BETTER than the UK Gov and really lead the way to a more sustainable future, but it will take courage. However there are lots of long term benefits to putting Wales at the vanguard of the energy efficient / sustainable building world.

As far as the consultation document is concerned my thoughts are:

5.1 Overcoming Barriers
1.1 Improved Information
- We think that giving people really good advice is important, however it needs to be based on RISK and a good understanding of the actual house / life style. This requires trained people who understand building types, building pathology, the limitations of EPCs, moisture, etc.
1.2 Work with others to encourage energy efficiency
- Again this is fine as long as those people have the time / knowledge to give really good individualised advice that highlights risk and takes into account individual circumstances
1.4 Providing Free Energy Efficiency Assessments to Low Income Families
- The EPC tools used are not reliable for many house types in Wales and certainly gives generic advice that needs interpretation. Luring people in with unrealistic savings and also high risk measures will just create situations where the poorest might be done a serious mis-service.
1.5 Continue to provide advice
- The NEST service is again driven by the unreliable EPC system and so needs to be adapted. It should also look at the wider issue of health, Internal Air Quality (IAQ) etc.
1.6 Making Energy Efficiency easier for people
- We must start with the fact that many energy efficiency measures are NOT easy. We need to give people confidence by providing good and rounded advice that highlights risk and how to minimise them. Honesty is the best policy here.
1.7 Ensuring that the PRS (Private Rented Sector) meet their obligations
- Again we are using EPCs that give advice that is poor, inaccurate and will encourage the cheapest and easiest roots to a E rating. Some improvements that give E's will be detrimental to health of occupants and also not deliver the actual savings. We need to be smarter and to ensure that appropriate guidance is given to minimise this risk. This means appropriate recommendations need to be given. At present the EPC guidance does not give 'clever' advice and this is misleading.
1.8 Review Part L of Building Regulations
- Again we need to ensure that we give lower risk advice / guidance. Pre 1919 buildings need to have better data and we need to consider issues like reverse condensation, maintaining breathable walls, moisture levels etc. We also need to link in Ventilation into the advice to minimise risk to these older properties. The use of EPCs should also be re-assessed and the issues surrounding detailing / thermal bridging etc.
1.9 Drive achievement of the WHQS
- Given the costs associated with continual upgrades should each property be assessed in a manner that makes it as good as it can be (with due diligence to health of the occupants, building structure etc). This might mean that one building at SAP 60, whilst others achieve 85! Having a purely arbitrary level of 65 might cause a lot of problems that will ultimately cost more and also not give the results expected.
1.10 Align community based activity
- Communities need to give accurate advice and this can only be achieved by understanding houses. Whilst people can help drive interest we should rely on trained specialists using the right tools to give the actual individualised advice
1.11 Provide advice to businesses etc
- Each property is different and so using showcases can encourage uptake, but each property needs to be assessed individually and so care is needed not to promote solutions that are not appropriate to all buildings.
1.12 Integrate support into wider business advice
- Fine, but it needs to be good advice and support
1.13 Work with large businesses
We need to look at how we can use large industrial waste heat can be used for community benefit. District heating schemes, linking heat exporters with importers etc. Planning needs to be involved and encouraged to think strategically.
1.15 Increased support via Green Growth Wales
- Support needs to build on a strategic approach to support relevant industries that provide low risk solutions to energy efficiency etc. Wood fibre should be a standard specification product for many Welsh houses and it needs to have the backing of WG  and GGW in order to find its market.
1.16 Advice in public sector
- We need to give low risk advice that is tailored to each building
1.18 Drive efficient use of public purse
- As 1.15 we need to ensure that we develop industries that provide us with low risk solutions

5.2 Supply Chain Development
2.1 Support for installers to diversify etc.
- All installers MUST have training in Underpinning Knowledge of buildings. Recognising building types, understanding how they worker, common maintenance problems, the effects that changes / improvements might have. They must also be able to justify and decisions and the rationale that underpins it.
2.2 Strengthen support for supply chain development
- Again we need to have correct specification based on a more holistic approach, for example health considerations as well as energy efficiency. This means development / use of different materials / products that are currently used. Training and robust detailing driven by Government needs to used to drive this development.
2.3 Support supply chain through WG programmes
- This is key and needs to be driven by RISK assessment (via STBA work) and a HOLISTIC stance that covers FGA requirements. So addressing moisture, Internal Air Quality etc needs to be a WG specification criteria and then this is backed up by contracts that encourage adoption and hence provide a market for newer, better, natural and local products.
2.4 Quality of delivery
- On paper PAS2030 and other warranties offer protection, but in the real world they are either not tested legally, or are pretty worthless due to the complexities of building physics. So we must use RISK assessment rather than reliance on worthless paper comfort blankets. We must address the lack of underpinning knowledge in the construction industry. Builders MUST understand basic building physics, material compatibility issues, common 'improvement' issues etc. Ideally any builder working should have a minimum qualification to be able to do the work and anything done on a solid wall building needs to have additional modules completed and passed.
2.5 Entrepreneurship
- In order to get the right products made we need entrepreneurs to lead on this, BUT they do need to have the support from the specification teams in WG, Local Councils, Housing Associations in order to free up investment monies.

5.3 Skills and Education
3.1 Skills that respond to local need
- In Wales we have the oldest building stock in the whole world. We need to develop specialist skills to work on our older properties. We need to understand them, to know how they were made, how they have been changed over time, what materials have been used, how these materials inter-relate, how we live in buildings and how this has changed building physics. We MUST become specialists in sustainable retrofit. This means upskilling the existing workforce and also ensuring that the new trainees are filled with underpinning knowledge.
- We also want to have the lowest carbon new builds and so again we need to have people trained in concepts like Bio Solar Haus, Passive House, Ty Ynnos etc. They also need hands-on training in practical applications like airtightness, ventilation etc.
3.2 Mainstream provision of skills
- All builders should have the relevant qualification for the work that they do. Pre 1919 houses need specialist knowledge and skills, System Built houses again need different skill sets. At present anyone can call themselves a builder and do work, we need to have better control over who does what to our housing stock.
- All school children should have modules that cover houses. People need to understand their homes and where things are for a whole range of reasons. Secondary schools and Primary can start to address this relatively easily through ESDGC.
3.3 Post 16 training and education
The vast majority of the construction industry is based around new build. We need to ensure that we cover maintenance, building history, materials etc as well as underpinning knowledge on building physics in all courses.
3.4 Enhanced employer engagement
- One of the things that is really difficult to manage is that old habits die hard and so many in business today will only pass on old thinking and old ways of doing things. This is fine on modern buildings, but on older properties it is dangerous and high risk. So again we need to manage employers so that they are appropriately qualified for pre 1919 work if they are taking on apprenticeships.
3.5 Business capability
- CITB have developed new Upskilling courses for pre 1919 energy efficiency work that should be adopted by WG to help ensure that 'new' knowledge is widely understood and used.
3.6 Capital Investment in 21st Century Schools
- Schools must also work cover health, safety, noise, adequate space, ease of use etc as well as energy.

5.4 Innovation
4.1 Support new products and services
- We can all benefit from using new techniques like Bio Solar House and Passive House, but we can make these Welsh as well by using our national natural resources. This should be a priority. Having new zero carbon Welsh Vernacular is one way forward.
- All new products should be designed to further the aims of FGA rather than just energy efficiency.
- Major new products (like wood fibre insulation) must be supported by specifications in contracts from WG and other public sector bodies.
4.3 Energy efficiency in public sector
- The current research needs to inform this, so that we encourage products that fulfill all FGA criteria. Products that are encouraged need to be healthy, low carbon, local etc.
4.4 Smart Living demonstrations
- These should be used to help inform people about their houses and how to manage risk.
4.5 Shared Learning
- Always important, but context is important.
4.6 Innovation on WG programmes
- WG needs to be wise in its work to ensure that it is appropriate, low risk etc and also encourages the right type of innovation. We can be a UK leader here and show how smart we can be by not storing up problems for the future.

5.5 Finance
5.1 Information of financial support for householder
- This is fine, but we need to make sure that the right type of support is available. No point taking up grants to undertake EWI where it is not appropriate.
5.2 WG Investment
- rdSAP and other tools push us in the wrong direction for older buildings and so we MUST be better than the tools that we use. We made them, we can change / adapt them to make them better suited for use. We must not be driven by funding, but have the strength of character to say what we want / need and then for the money to follow that.
5.3 Loan funding
- Any funding MUST be linked to a risk assessment based on best practice. Loans must have low risk works associated with them so that people are not faced with long term maintenance etc associated with poor initial specification.
- We must use the best techniques / skills / materials etc to bring houses back into being homes. No point doing unsustainable face lifts.
5.4 Leverage
- Funds that allow us to work sustainably on our buildings should be used. If it is not right for Wales, then don't use it. Mistakes can take a long time to materialise and then who will pick up the bills?
5.6 - 5.8 Finance for business
- We must get specification etc right to minimise long term costs
5.10 Energy Performance Contracts
- EPC's are NOT fit for use on 1/3 of our stock. rdSAP and SBEM are NOT good tools. DECC, BRE, STBA and many other know this. WG has been told. EPCs are dangerous and MUST not be used in isolation. Pre 1919 buildings are most notably at risk. I cannot stress this enough. We should be using other tools in partnership with EPCs and we must have assessment criteria that take into account IAQ, Moisture content, health, noise etc.

Impact Assessment

Where is the Health Impact Assessment???

The major impact of the strategy at the moment is to put a third of all houses and their occupants in Wales at risk!

The key risks are:

• Creation of major thermal bridges in houses (environment & economic)
• Creation of conditions for damp and mould in houses (environment, health & economic)
• Structural damage due to water ingress (environment & economic)
• Trapping moisture behind External Wall Insulation (environment & economic)
• Creation of chronic health problems esp. respiratory illnesses (health & economic)
• Not getting the savings / carbon saving that are projected (economic)
• Long term maintenance costs (environment & economic)
• Costly insurance claims or high costs for owners in stripping out / off 'improvements' (environment & economic)
• Wales losing it's character buildings and part of its identity (environment & culture)
• No major economic change as work will go to larger companies (economic)
• No economic advantage by having a more informed workforce (education & economic)
• No new innovative industries that put Wales ahead of the curve (economic)

There are more ....

Other issues

There are a wide range of topics / issues that fall out of this. We MUST have a new modus operandi and this is a key document to change this. Our built environment is AT RISK thanks to the blinkered race for energy efficiency, we MUST look holistically both for the sake of the FGA, but also for the future of our built environment.

Tools like rdSAP need to work in conjunction with MOISTURE tools. Moisture tools also need to be based on REAL WORLD situations not the current tests that actually state that they are not fit for purpose for 'in service' conditions. STBA (& soon BRE) work for DECC on solid walls demonstrates that we are storing up problems by using inappropriate test regimes for moisture / damp.

Health NEEDS to be part of this. We spend so much time indoors we need to ensure that the internal environment is as good as it can be, both for the inhabitants and the building structure. We need to measure and value IAQ, moisture levels, humidity and noise if we are to have sustainable buildings.

Wales MUST opt for low risk solutions in the immediate future and this might be focused on things like renewable energy generation solutions rather than energy efficiency. This might be seen as tackling the wrong end of the energy pyramid (and that would be correct), however we must focus on risk, as it is very easy to get it wrong especially when we have an ill informed construction industry and populace. We need to address education / training / awareness first so that we get it right. So initially focusing on low risk activities allows us to work whilst also getting prepared for the more complex structural works.