Our draft Heat in Buildings Strategy – published alongside this consultation - builds on the 2018 Energy Efficient Scotland Route Map And the 2015 Heat Policy Statement, And brings together our ambitions on energy efficiency And heat decarbonisation into a single framework. It sets out a series of policies And actions on energy efficiency And heat decarbonisation including strengthened action to deliver on our National Infrastructure Priority for Energy Efficiency. It considers whole-system energy issues And how these are to be managed over the course of the transition. The draft strategy outlines the scale of the economic opportunity presented And identifies the measures necessary to realise this And to ensure a Just Transition, one in which the benefits of the transition are shared And no one is left behind.
This can only be achieved if there is a robust supply chain in place with the capacity And capability to deliver on our vision, to improve the well-being of people living in Scotland And to create sustainable And inclusive growth. We estimate there are around 13,000 people employed in the energy efficiency And low carbon/renewable heat sector in Scotland with the sector having an annual turnover of £2.4 billion.
Our Heat in Buildings Programme is the primary vehicle for reducing energy demand And carbon emissions from Scotland's existing buildings, And for eliminating poor energy efficiency as a driver of fuel poverty. Delivering on our targets for energy efficiency has the potential to support substantial employment opportunities And build Scotland's supply chain. It has been estimated that this will require investment of £10 billion over its lifetime And that every £100 million spent on energy efficiency improvements supports approximately 1,200 fulltime equivalent jobs across the Scottish economy.
Given the scale of the challenge, as set out in our draft Strategy, we expect the supply chain will need to grow significantly over the coming years. To help achieve this we made the following commitments in our draft Strategy And Programme for Government 2020-21:
- Developing And implementing a supply chain action plan in partnership with our enterprise agencies by end of 2021 to support the growth And preparedness of the zero And low emissions heat supply chain.
- Providing capital investment for Scottish colleges for equipment to deliver training for energy efficiency And microgeneration.
- Ensure the supply chain can benefit from the support available from our National Transition Training Fund, the Flexible Workforce Training Fund And the Young Persons Guarantee.
In addition, we have established a group of experts to help the Scottish Government explore the potential of a Heat Pump Sector Deal. Through working with this group, we aim to understand how industry And government can work together to set a clear pathway for accelerated deployment of heat pumps. The group will make recommendations to the Scottish Government by summer 2021.
2.2 Short Life Working Group on Quality Assurance
Scottish Ministers agreed to convene a Short Life Working Group (SLWG) in 2018 to focus on the quality, skills, supply chain And consumer protection requirements of energy efficiency And heat decarbonisation And to build upon the quality assurance principles as set out in our Energy Efficient Scotland Route Map (2018).
This group included representatives from across industry, consumer organisations And enterprise And skills agencies. A full list of member organisations can be found in Annex A of this consultation. The role of the Scottish Government in the group was to facilitate the discussions by providing administrative And secretariat support.
Recommendations of the SLWG on Quality Assurance
In March 2019, the group published their final report with 19 recommendations for developing quality assurance for Energy Efficient Scotland (including heat) which included a number of recommendations in relation to roles And skills including:
Recommendation 1. There should be Quality Assurance criteria developed which detail the key mandatory requirements for suppliers wishing to participate in Energy Efficient Scotland.
Recommendation 2. There should be a Quality Mark for Energy Efficient Scotland And suppliers wishing to take part in the Programme will have to demonstrate that they meet all of the requirements (set out in Recommendation 1) through a robust vetting And verification process to achieve the Quality Mark. All approved suppliers should be listed on a publicly available Directory And where possible the use of operative ID cards should be considered.
Recommendation 5. A new designer role should be considered to ensure that that a whole building approach is taken And that only the most appropriate improvements are applied in practice.
Recommendation 7. Installations under Energy Efficient Scotland must be based on skills And competencies, And a skills And qualifications matrix should be developed And clearly communicated to the supply chain to reflect this.
Recommendation 8. The skills And competency requirements of the designer role should be determined And an analysis of current capacity within the workforce should be undertaken.
Subsequently, all 19 of the recommendations were included in our Energy Efficient Scotland consultation which was published in May 2019. In December 2019 we published our response to this consultation.
Consultation on the SLWG Recommendations – What you told us
Respondents to our 2019 Energy Efficient Scotland consultation noted their broad agreement, or agreement in principle, with the recommendations, which were described as welcome, relevant And comprehensive. It was also suggested that more detail was needed on the recommendations And how they would be implemented.
When asked about the recommendation to have a quality mark in Scotland, respondents argued that since any Energy Company Obligation (ECO) work in Scotland has to be carried out by a business that is registered with TrustMark And has demonstrated compliance with PAS 2030 And PAS 2035, it would make sense for the supply chain in Scotland to be aligned with these requirements. Furthermore, that establishing separate standards for Scotland could make it difficult for Scottish contractors to work elsewhere in the UK, And vice versa. Rather than establish a separate scheme, it was argued there should be a single assurance process And an agreement which confers approval on one scheme that meets the core standards of another. Additional requirements could be added to address any issues identified by the Scottish Government And the SLWG.
For recommendation 7 on skills, respondents argued that the competencies required to install energy efficiency measures are already specified in the National Occupational StAndard which forms the basis of vocational qualifications such as 'Insulation And Building Treatments'. Other qualifications, such as the Award in Energy Efficiency Measures for Older And Traditional Buildings should also be used to augment knowledge.
With respect to the proposed skills And qualifications matrix, respondents suggested that this should be developed in collaboration with industry And may vary depending on the energy efficiency measures being installed.
The new designer role was welcomed by respondents who commented specifically on Recommendation 5, although the retrofit co-ordinator role set out in PAS 2035 was also highlighted. Good quality consumer advice from an impartial source was suggested to be invaluable, since this may otherwise fall to competing technology specialists.
We have listened to your feedback And we believe the adoption of PAS 2035/30 for our programmes And the development of an installer skills matrix address this.
Building on Existing Standards – UK retrofit standards
In December 2016, the UK Government published `Each Home Counts' an independent review of consumer advice, protection, standards And enforcement for energy efficiency And microgeneration. In June 2019, the British StAndards Institution (BSI) published a new retrofit standard for energy efficiency known as the Publicly Available Specification (PAS) 2035. This standard covers the entire energy efficiency retrofit process in homes, from initial assessment And design to installation And evaluation And incorporates the updated PAS 2030: 2019 installer standard. Together they are known as PAS 2035/30: 2019.
These standards incorporate a number of well-defined roles for retrofit work including: retrofit coordinator, assessor, designer, installer And evaluator. Competency requirements are also listed for these.
BSI are also developing retrofit standards for non-domestic buildings (referred to as PAS 2038) but these are still at an early stage of development.
For microgeneration, industry standards have been available for some time And continue to evolve. These standards are provided by the Microgeneration Certification Scheme (MCS) And are separate to the BSI PAS 2035/30 standards.
2.3 Developing the installer skills matrix
Energy Skills Partnership (ESP) – part of the Scottish Colleges network - was commissioned to deliver recommendation 7 for installers And set up a Skills Group to achieve this. This group included all the sector skills bodies for construction, heating And electrical, trade bodies, Scottish colleges, skills agencies And other stakeholders. The full list can be found in Annex B.
The output of this group was a skills matrix that outlines the recommended minimum qualifications, with recognition of Recognition of Prior Learning (RPL), for the various trades (e.g. plumbers/heating engineers) broken down by measure (e.g. air source heat pumps). Further details on this can be found in the installer requirements section of this consultation. The members of the Skills Group were very positive about the development of the skills matrix And we plan to discuss the future direction of this group as we are keen to monitor skills requirements as our programmes develop.
This skills matrix is also expected to form a key part of our broader Climate Emergency Skills Action Plan which was published alongside our Climate Change Plan update in December 2020.
2.4 Purpose of this consultation
The purpose of this consultation is to seek views on our proposals for energy efficiency, zero emissions And low carbon heating systems, microgeneration And heat network skills requirements. Once implemented, these skills requirements will create a best practice standard for the sector, And will be a minimum requirement for Scottish Government-supported programmes for Scottish Government programmes.
Through this consultation our key proposals are:
- The installer skills matrix developed by the sector skills bodies, industry And other key stakeholders in Scotland is adopted And fully integrated into the British StAndards Institution (BSI) Publically Available Specification (PAS) 2030 installer standards And Microgeneration Certification Scheme (MCS) installer standards to reflect Scotland's skills needs.
- To adopt the BSI PAS 2035 retrofit standards for Scotland And the associated skills And competency requirements for other retrofit roles where we will work with skills agencies including the Scottish Qualifications Authority (SQA) And Skills Development Scotland (SDS) to consider the need for qualifications And/or further training in Scotland for the these roles, particularly where no qualifications currently exist in Scotland.
We are also seeking views on the impact these requirements will have on the Scottish supply chain, particularly in remote rural And island areas.
Once set these skills requirements will complement both the capital investment we are making in Scottish colleges And the skills funding announced in our recent Programme for Government.
As the retrofit standards for non-domestic are currently under development (PAS 2038), this consultation will focus primarily, though not exclusively, on retrofit skills for homes though as acknowledged at the start we believe some of these skill requirements will also be relevant for new-build housing And in certain circumstances (e.g. installations) non-domestic buildings. However, we will work closely with BSI to ensure Scottish skill requirements are factored in to the non-domestic retrofit standards And all relevant stakeholders are consulted on these.
We have also produced a partial Business And Regulatory Impact Assessment that sits alongside this consultation And can be found on the same page on our website.
2.5 How to respond
You will find consultation questions at key points throughout this document requesting feedback on different elements of our skill proposals. We invite you to respond to these questions by 30th April 2021. We will use the consultation responses to inform the skills requirements for our programmes in Scotland And will work with the British StAndards Institution, the Microgeneration Certification Scheme And stakeholders involved with developing heat network skills to achieve this. We will also publish our response to this consultation as part of our supply chain development programme And action plan as announced in our draft Heat in Buildings Strategy.
Please respond to this consultation using the Scottish Government's consultation hub, Citizen Space: https://consult.gov.scot/energy-And-climate-change-directorate/skill-requirements-for-energy-efficiency-homes/
You can save And return to your responses while the consultation is still open. Please ensure that consultation responses are submitted before the closing date of 30th April 2021.
If you are unable to respond using our consultation hub, please complete the Respondent Information Form (provided at Annex C) And send to:
Following the closing date, all responses will be analysed And considered along with any other available evidence. The Scottish Government will publish responses, where respondents have given permission for their response to be made public, And a report summarising responses will also be made available.
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