Heat and Energy Efficiency Technical Suitability Assessment: consultation analysis

Q1 Value in Developing a HEETSA

Most of the 80 respondents who answered the question supported the development of a HEETSA. 63 respondents (79%) expressed support, nine opposed the development of HEETSA (12%) and eight (10%) did not express a clear opinion.

This overall support was evident among both individual respondents and organisations. Nonetheless, organisations were more supportive than individuals. Among the 70 responses from organisations, 52 (84%) endorsed the development of HEETSA, while only four (6%) opposed it. In contrast, of the 18 individual respondents, 11 (61%) were in favour and five (28%) were against. For each organisation type, the majority of respondents were supportive.

Given the broad nature of this question, the themes from the open text comments align with many points raised from later more-specific questions. The responses received from the later questions provide greater detail.

Reasons for supporting

Respondents who supported the development of HEETSA provided a range of reasons, which can be grouped under five key themes explored in more detail below. There is some overlap between these themes, but they provide a good way to present the feedback.

1. Help ensure the quality of assessors.

2. Improve the quality and robustness of the assessment methodologies.

3. Deliver a better service to consumers.

4. Support public objectives around decarbonisation and tackling fuel poverty.

5. An opportunity to strengthen and support the retrofit profession.

Quality of Assessors

The most common reason for supporting HEETSA was that it is expected to protect consumers through assuring the quality of HEETSA assessors. This aligns with some respondents reporting a lack of trust in the retrofit profession, due to cases of unsuitable measures being installed and poor quality of work. HEETSA was considered to increase consumer trust in retrofit.

The following more particular points were raised in relation to this.

• A few respondents thought HEETSA could provide confidence in the qualifications of assessors. Indeed, amidst a recognition that knowledge in retrofit is improving, a few respondents also reported a lack of knowledge amongst trades people particularly with regards to building physics and the way measures interact when combined. A few respondents actively requested that the development of HEETSA should drive robust skillsets, with requirements for qualifications of HEETSA assessors, and plans for upskilling the workforce with clear training pathways.
• There were a few respondents who identified that a key issue of existing retrofit assessment options is the lack of impartial advice. These respondents stressed that often assessments are conducted by installers interested in promoting particular products. There was also an issue with advisors from government-funded schemes providing limited advice, potentially because their advice is restricted to measures specifically covered by the scheme. On a similar note, some respondents mentioned the EPC as the main source of impartial advice but it is considered inadequate and not specific to the property. HEETSA is as an opportunity to deliver tailored and impartial advice.
• Finally, a few respondents approved greater government oversight to ensure quality. This aligned with feedback from a few respondents that existing retrofit assessments lacked accountability processes. Some respondents expressed hopes to see a fully controlled enforcement with accreditation, mandated training, established standards of reporting, auditing and mechanisms for redress.

Improved assessment methodology

Some respondents supported the development of a standardised approach to retrofit assessments in response to a poorly coordinated retrofit assessment landscape. This is also backed up by a few respondents who commented on the inconsistent quality of current assessments, attributing this to fragmented knowledge and guidance available to practitioners.

Some respondents supported the proposed holistic approach, tailored to each building, the local context and the specific occupants’ needs. Some respondents specifically supported the focus on more complex property types such as heritage buildings, rural and pre-1919 buildings, tenement and communal buildings.

Other comments on the opportunity HEETSA offers to improve assessment methodologies were as follows:

• Some respondents hoped that HEETSA would promote maintenance first principles. This included how occupants should use and maintain their buildings.
• A few stressed the importance of reported predictions (e.g. cost savings from retrofit works) to be grounded in accurate estimates. They hope to see measurement and monitoring options included.
• A few raised opportunities emerging from a decarbonised grid. For example, photovoltaics combined with battery storage technologies. Additionally, the potential of smart meters to contribute towards behavioural changes and unlocking cost-effective tariffs in combination with low-carbon heating.

Improved consumer service

Some respondents believed HEETSA could provide better quality advice to consumers. Of note, these respondents supported the proposed assessment approach which was perceived as being more tailored to the occupants and better enabling them to make decisions suited to their circumstances. Some also referenced the maintenance first approach and the opportunity to educate occupants about behavioural changes and how to maintain their buildings.

A few respondents noted a lack of education on retrofit amongst the public. HEETSA was seen as an opportunity to improve communication and education on retrofit measures by carefully designing the standardised HEETSA output report.

There were a few respondents who also saw HEETSA as providing an opportunity to streamline processes, by integrating with other government policies, funding streams and delivery mechanism. HEETSA was viewed as a critical tool, particularly in the context of the consultation on a Private Rented Sector Minimum Energy Efficiency Standard (PRS MEES) and the associated need to demonstrate eligibility for exemptions. Additionally, a few respondents highlighted low awareness of existing funding mechanisms and how to access them.

Other suggestions recommended by a few respondents for enhancing the service provided to consumers included:

• Providing clarity on risk and insurance options available in the industry when procuring and carrying out building repair, maintenance and improvements.
• Communicating opportunities for community-level engagement and action for buildings with shared occupancy and addressing cost-sharing arrangements.

Support public objectives

Some respondents expressed support in HEETSA for its potential to back a strong national strategy across Scotland for decarbonising homes and addressing fuel poverty. It should promote a more detailed and coordinated effort to improve properties to the best feasible standards.

A few respondents believe it will enable better allocation of public resources. These respondents also expect it will support the development of new financial mechanisms to fund assessment and measures uptake.

Support retrofit professionals

There were a few respondents in favour of HEETSA who see it as an opportunity to grow the retrofit market. HEETSA should promote the uptake of measures through providing confidence for private investment and provide support for upskilling the workforce.

Reasons for opposing

There were a few respondents who perceived HEETSA as unnecessary given existing assessment methods such as PAS 2035 and BS EN 40104. They preferred building upon and enforcing existing assessment protocols as opposed to creating a new standard.

A few respondents considered the proposed level of government oversight as costly and unnecessary. They recommended market-driven alternatives to support the retrofit sector, including:

• undertaking amendments to funding and procurement regimes to favour independent and holistic advice,
• fostering knowledge sharing initiatives,
• undertaking government-led promotion campaigns, and
• regulating against poor advice from unqualified retrofit assessors.

Finally, a few respondents rejected the development of HEETSA due to broader objections to any form of government control.

Other concerns

A concern raised by some supporters and opponents of HEETSA was whether the proposed approach offers a genuine improvement over existing ones. Some respondents warned against trying to “reinvent the wheel”. It would be better to integrate existing approaches and focus on improving upon their shortcomings as opposed to developing a new standard from scratch.

Similarly, a few respondents recognised the increased knowledge and skills in the retrofit landscape, with practitioners already delivering tailored solutions. In this regard, it was suggested that HEETSA should build upon existing know-how and skillsets.

Another concern from a few respondents was excluding installers from the assessment process. They recognised the potential for biased advice if installers conduct assessments for the feasibility of different measures. Nonetheless, the following points were raised highlighting the risks of excluding designers and installers from the HEETSA process.

• Certain feasibility criteria can only be identified once installation works begin, as structural issues may be hidden.
• There are limitations to establishing the cost of measures without the involvement of designers and installers.
• HEETSA does not cover risks associated with poor installations and therefore cannot fulfil its aim of completely protecting consumers.
• Advice delivered through HEETSA may be perceived as less authoritative. This is especially when it contradicts guidance from those who will install measures in practice.

A few respondents worried that the HEETSA would be too prescriptive and lack flexibility regarding the specific context and needs of consumers. HEETSA assessors should be able to tailor their service and advice to the consumer. Consumers should have the choice over what they implement or not, and in which order. On the other hand, a few other respondents appeared to support a standardised approach, and even called for dedicated software to be developed to support this approach.

Respondents raised concerns about the practical feasibility of the scheme.

• The cost of assessments was identified as a major barrier to uptake by some respondents, especially given that free advice from installers is currently available. While there is recognition that free advice may lack quality, comments suggest consumers tend to choose the lowest-cost option.
• There were also concerns by some respondents about the deliverability of the scheme given the complexity of the proposal and short timeline to roll-out in 2027.
• A few respondents highlighted additional worries focused on the market capacity to carry out HEETSA assessments:
  • the existing skills shortage and potential additional training requirements,
  • increased strain on the existing workforce, and
  • added regulatory burden could hinder independent advice services in a market that is struggling to develop. Also, it could become a barrier to innovation if the standard fails to evolve with new materials and technologies.

A few respondents were concerned with inappropriate measures being installed outside of government assured retrofit schemes. In such cases there may be no requirement for a HEETSA to be carried out. They encouraged the Scottish Government to consider other methods to protect consumers in such cases.

There were a few respondents who expressed concerns with current tenement laws. They were viewed as a barrier to implementing improvement measures potentially recommended by a HEETSA e.g. communal solutions.

Finally, a few respondents suggested the proposal was confusing. They requested further clarifications on the role of existing protocols and methodologies within HEETSA. They were also unclear on how the scheme would be implemented in practice. In this regard, respondents suggested a trial period and further stakeholder engagement.

Additional comments from the Workshops

Additional concerns were raised during the workshops.

• Supply chain limitations in rural and remote areas. This may hinder the implementation and maintenance of recommended measures.
• Introducing a new standard would bring confusion. It would make procurement more difficult for schemes like the Energy Company Obligation (ECO).

The workshops also identified the following points about the HEETSA methodology.

• HEETSA is an opportunity to promote smart technologies such as Building Energy Management Systems (particularly with regards to non-domestic buildings).
• There is a lack of focus on hot water use and systems in the proposal.
• To consider alignment with planned district heat networks. Recommendations should be complementary to and not conflict with future infrastructure plans.
• Include risk profiling for recommended measures, both individually and any interdependence as part of implementing a package of measures. A suggested tool was the Sustainable Traditional Buildings Alliance’s (STBA) retrofit wheel.
• Clarification is needed on the types of buildings that HEETSA will cover. Specifically, whether it will include both domestic and non-domestic properties.