Energy efficiency, zero emissions and low carbon heating systems, microgeneration and heat networks - skills requirements: consultation analysis

4. PAS 2035 Requirements for Other Roles

Context

4.1 PAS 2035/30 covers a number of specific roles involved with retrofit work. PAS 2030 covers the installer requirements and PAS 2035 covers skills requirements for other roles.

4.2 Figure 2 in the Consultation Document (Page 11) summarises PAS 2035/30 in terms of the roles, including the new Retrofit Coordinator which is a critical component of the new standards. The Consultation Document provides an overview of the following roles, alongside more detailed proposals on competency requirements:

• Retrofit Coordinator. The Retrofit Coordinator could also be the advisor, assessor, designer, or evaluator.
• Retrofit Assessor.
• Retrofit Designer
• Retrofit Evaluator.
• Any person delivering retrofit advice.

4.3 The Scottish Government will work closely with Scottish colleges to deliver training and qualifications in line with the proposed competency requirements.

Question 4

What are your views on the competency requirements for the retrofit coordinator, advisor, assessor, designer and evaluator roles?

4.4 The vast majority of respondents answered Question 4 and provided views on the competency requirements for the retrofit coordinator, advisor, assessor, designer and evaluator roles (85%). The remainder left the question blank (15%). There was a mix of more general feedback as well as commentary on the different roles.

Competency requirements are essential

4.5 Overall, competency requirements were viewed as essential, and this was reflected in a variety of comments, including the following:

• "An absolute must. There should be a large degree of comfort for the buyer of this service that the appointed team know what they are doing. There should be certification that includes x hours of onsite work in a project and a requirement through CPD to maintain current knowledge". (West of Scotland Housing Association).
• "Roles should have minimum competency requirements to protect the client, householder and public pound". (Falkirk Council).
• "Kingspan welcomes greater focus on these roles to support a holistic approach to renovation. However, we do advocate for a 'fabric first' approach and therefore would emphasise that this should be at the forefront of recommendations for these roles". (Kingspan Insulation Ltd).
• "The ADE is supportive of the ambition to align qualifications with the mandatory competency requirements set out in PAS2035, but would urge further work with industry and training providers to ensure all options for retrofit/low carbon heat and considered through training and development". (The Association for Decentralised Energy).
• "It is encouraging to see that the Scottish Government has acknowledged the need for specialised training when working with Older and Traditional Buildings. Many rural properties fall within this category, and many contractors do not have the required training or knowledge to ensure all installations are sympathetic to the building's needs. The requirement for contractors to hold a qualification specifically tailored to these properties will help to resolve this issue". (Scottish Land and Estates)
• "…it is very important that (a) competence is demonstrated, (b) it should be assessed regularly to ensure it is up to date, and (c) this should be done by a suitably accredited (e.g. by UKAS) third-party certification body. (United Kingdom Accreditation Service).
• "It is considered that the competency requirements for these roles is crucial for effective application of the standards. The level of training required needs to provide a level of comfort in order to ensure competency and consistency. Those carrying out these roles will need to have an in-depth understanding of technologies, methods of construction and how they all work in conjunction within a property". (Perth & Kinross Council Housing Improvements)

Key points to note

4.6 A variety of points were raised through the consultation responses that relate to a number of the roles specified in the Consultation Document.

Supply side issues

• There was agreement that the roles listed are not necessarily individual persons. There was feedback that many individuals train for multiple roles (e.g. Retrofit Assessors also gain Retrofit Coordinator qualifications). Aligned to this, Built Environment Forum Scotland commented that "if this were to be the case, is there the temptation that Risk Assessments could be downgraded/diminished to ensure the work can be carried out by those less qualified?
• That it was important that, for all aspects of retrofit, "standards for all roles must be fit for purpose and independently assessed" (i.e. building on quality assurance principles, particularly consumer protection).
• It was suggested that competencies common to all roles might include, for example: understand broad construction processes (e.g. design, procurement, programme delivery); be familiar with construction roles and responsibilities; understand current/future energy efficiency technologies available; willingness to engage and communicate delivery challenges; surveying skills; comprehensive report writing skills; quality assurance; willingness to share skills and provide training opportunities; commit to availability within programme delivery timescales; understand grant funding opportunities.
• It is desirable that the roles have training and/or experience in the "practicalities of construction" to ensure their recommendations are pragmatic and implementable by the tradespeople who carry out the work.
• The roles would require an understanding of the "importance of undertaking heat loss calculations" to ensure that systems are appropriately sized. As well as an understanding the need to lower flow temperatures as part of a heating system replacement.
• It was suggested that further thinking would be required around the levels of competency specifically on "topics such as energy efficiency and sustainability".
• A key point raised was that there is a lack of approved training centres across the UK, and particularly in Scotland. A connected point, was that other organisations, over and above colleges, could offer training towards the competency requirements, and it was suggested that this could be explored further. The importance of ensuring any academic or practical training/qualifications was "thorough and rigorously vetted" was also emphasised.
• A constraint identified was the current availability of "suitably qualified people in Scotland to undertake certain roles". Further, it was noted that some roles (e.g. Retrofit Coordinator, Retrofit Assessor) "might be hard to fill due to the level of knowledge, competency and understanding of multiple industry disciplines required", and also might not be cost effective for micro businesses.
• A concern raised was that that the "volume of competency requirements for each role had the potential to disadvantage micro businesses". Further, it was considered important that the introduction of any scheme or specification "should not limit opportunity for micro and SME businesses".

Wider points

• It was suggested that lessons could be learned from the "inadequacies" of the current assessment methods used to measure performance of traditional buildings (EPC), to ensure "systemic mistakes are not repeated".
• A further proposal was that the Scottish Government could work with professional bodies (e.g. The Royal Institution of Chartered Surveyors - RICS) to "ensure the supply chain is developed". For example, it was noted that "many more accredited Building Surveyors will be required in Scotland if aspirations are to be met".
• A "fabric first approach" should be advocated at all times.
• Assurance would need to be provided that "Whole Dwelling Assessment" would include maintenance assessment of the current state of the dwelling. Without this any interventions will not produce the outcomes, whether they are occupant comfort and health, cost, or climate impact, as expected.
• As PAS 2035 is a UK wide document, a comment was that "much wider consultation and agreement would be required to write them into the standard".

Feedback on the different roles

4.7 Much of the wider commentary related to one or more of the roles, and this is considered at a high level below.

Retrofit Coordinator

4.8 Common feedback on the Retrofit Coordinator was that this role would be key –- and would require broad knowledge and practical experience in working in refurbishment, renovation, whole house retrofit, and new build construction.

4.9 National Insulation Association emphasised the importance of this role in terms of "…managing a retrofit project from start to finish". The same organisation added that "a Retrofit Co-ordinator, alongside other roles such as the Retrofit Designer can help to ensure that appropriate measures are installed to high quality standards and crucially, that these are correctly sequenced in accordance with a fabric first approach". Retrofit Co-ordinators are professionally accountable for protecting the homeowner and public interests and to this end, it is important that they are suitably qualified".

4.10 Kingspan Insulation Ltd commented that the Retrofit Coordinator would play an important role in ensuring "there are no unintended consequences associated with renovation works which includes the appropriate phasing and co-ordination of improvements and the junctions and interactions that exist between them". Further, this role was also needed to make sure that "the measures work together in harmony and support the wider decarbonisation objectives as well as ensuring affordability and energy security".

4.11 The Association for Decentralised Energy and MCS Charitable Foundation and MCS Service Company Ltd noted that Retrofit Coordinators "must also be aware of the relevant local decarbonisation strategies driven by Local Heat and Energy Efficiency Strategies (LHEES) and work on behalf of local authorities to drive consumer buy in". This was viewed as important to help ensure success across the other roles.

4.12 A common point raised was that the approved course for the Retrofit Coordinator was currently only available from one education provider in England, and that this posed a number of challenges within a Scottish context. Various points raised are reflected in the respondent quotes below.

"Diploma in Retrofit co-ordinator etc is currently only awarded by one awarding body across the UK which severely limits the ability to obtain PAS2035. There needs to be a range of different awarding bodies delivering the same qualification to the same standard. There needs to be National Occupational Standards (NOS) for the various roles". Construction Industry Training Board

"As a company we have grasped the nettle and have put staff through the coordinator and assessor courses and are concerned that it has just recently been suggested that the coordinators course (the only one available in the UK) will not be recognised in Scotland! This has put us off seeking competency training down south for our operatives". BCA Insulation Limited

"..achieving this qualification in the short term requires a number of prerequisites and time to achieve qualification. This may make this role unachievable in the short to medium term due to limited availability of suitably qualified personnel". (Individual).

"The Retrofit Coordinator role could also be fulfilled by those undertaking training on the retrofit pathway in Construction Site Management, the NOS for which have recently been developed. As all existing training for retrofit coordinators is delivered in England, it will be important to establish how suitable this is for Scottish building types, and to tailor accordingly. There are also question marks around whether the training for Retrofit Coordinators is sufficiently in depth to allow all the functions of the role to be met, and Scottish Government may want to investigate this further". Historic Environment Scotland

4.13 It was therefore considered vitally important to avoid a "shortage of coordinators that are fully qualified and able to undertake this work".

4.14 The commitment made by the Scottish Government to work with organisations, including the SQA and SDS, to consider the need for qualifications and/or further training in Scotland, particularly where no qualifications currently exist, was welcomed. There was also a request for this to be progressed as soon as is practically possible.

"Whilst this commitment is welcomed, and we recognise that centres such as the Retrofit Academy in England do have an e–learning programme, we would like to see the Scottish Government's commitment to build training provision delivered upon as rapidly as possible.

The new ECO requirements due to be implemented from 1st July (for ECO, PAS 2035/PAS 2030:2019 will become mandatory) will lead to an increasing demand for retrofit co-ordinators, which further emphasises the need for training additional retrofit co-ordinators. A lack of training provision could negatively impact the delivery of retrofit schemes and could undermine quality". National Insulation Association

4.15 Tighean Innse Gall posed a question around why RPL was not included for the Retrofit Coordinator role, as the organisation further expanded on below:

"….this has created a very select market if not a monopoly for the Retrofit Academy in selling their course. Surely experienced professionals with particular relevant skills can upskill quicker. If this is not recognised then we would think this will simply disenfranchise part of the experienced existing supply chain which we surely want to encourage not discourage from participating in this process".

4.16 OFTEC noted that "For a single measure installation (i.e. heating) it must be the installer who provides these functions….Only on complex, multi-trade projects would a fully qualified Retrofit Coordinator be mandatory".

4.17 NIBE Energy Systems UK considered the Retrofit Coordinator role "should be independent and provide oversight of the project including post-completion evaluation".

4.18 Sustainable Energy Association agreed with "the recommendation from the Construction Industry Training Board that a Clerk of Works role should be explored, responsible for overall quality of the retrofit, over and above the retrofit coordinator role". It added that "while it's the responsibility of each role to ensure quality, the Clerk of Works is responsible for all quality and the interaction between the roles. They oversee the duties such as performing regular inspections and comparing completed work with original designs. This additional level of oversight is key for successful delivery of Energy Efficient Scotland".

Retrofit Assessor

4.19 A common theme was that it was important to put in place processes to make certain "installation quality is ensured". Here, the role of Retrofit Assessor was welcomed, as it would play a "key role in conducting assessments and providing the Retrofit Coordinator with the data required to inform decision-making", and could "provide a further incentive for high quality installations".

4.20 Further, Kingspan Insulation Ltd commented that the Retrofit Assessor would be essential for ensuring that quality is "not lost across the skills matrix, and that installers and training providers are held accountable to the standards". They elaborated further, as outlined below.

"We would emphasise that all buildings must be assessed individually, and the assessor should have an in-depth knowledge of building design regarding materials, age, use etc. so they can make the most effective assessment and gather sufficiently detailed information to allow a designer to develop appropriate proposals for improvement.

The output will be an Assessment Report which will provide a Retrofit Designer with sufficient information to be able to develop recommendations for immediate action and for a medium-term improvement plan as required by PAS 2035 that reflects the Householders' / occupants' / landlords wishes and any identified constraints and that can allow for improvement option evaluation. It is important that an assessment does not just generate lots of data, but that it is targeted, usable, and useful for a designer, with the assessment process focused on the information that might be needed by a designer including identifying defects, design challenges and considering what might be required to be captured for the purposes of assessing the potential for future improvements". Kingspan Insulation Ltd

4.21 Risk was commonly mentioned – for example "it is logical to specify competency requirements dependent upon the risk grade of the project". In particular, "an underestimation of the risk could lead to individuals on site lacking key competencies which could have implications for installation quality, whilst an overestimation of risk could lead to projects being over resourced, with excessive project costs".

4.22 Further, it was considered "reasonable and necessary" that special consideration was given to the competency requirements required for the assessment of retrofit protected buildings. For example, "there is a need to consider how unintended consequences are managed and mitigated against, as traditional methods may not be appropriate". Related points are reflected in respondent quotes below.

"The problem arises with additional qualification associated with protected buildings which require supplementary qualifications in "Energy efficiency measures for older and traditional buildings" which is no longer available in Scotland. It may be possible to obtain the English equivalent qualification assuming it is fully transferable for use on listed/traditional Scottish building construction". Individual

"It is encouraging to see....the need for specialised training when working with Older and Traditional Buildings. Many rural properties fall within this category, and many contractors do not have the required training or knowledge to ensure all installations are sympathetic to the building's needs. The requirement for contractors to hold a qualification specifically tailored to these properties will help to resolve this issue". Scottish Land and Estates

"It is clearly very important for heritage buildings that everyone dealing with them has the necessary skills to fit them for a greener tomorrow. It seems unlikely that the Scottish Government has got there yet. We recommend greater collaboration with Historic Environment Scotland". The Architectural Heritage Society of Scotland

4.23 There was acknowledgement that "for retrofit there are multiple issues that have to be considered from technical and operational parameters of technology to the structural engineering and building fabric specialists". This was further reflected on as follows.

"…we suggest that retrofit assessor recommendations should not be based on the recommendations of an energy advisor but by a team that includes an advisor, engineer and architectural technician. Therefore, the structure forwarded in the consultation would be more effective if the retrofit coordinator and energy advisor were the same individual. As things stand in the proposals the energy advisor will merely deliver the poor advice generated by the EPC process…. the Scottish Government have already recognised the shortcomings of EPCs and, as a minimum, the need to revise the model used, if not the whole system". The joint response from The Energy Poverty Research Initiative, Common Weal, The Built Environment Asset Management Centre, Glasgow Caledonian University

Retrofit Designer

4.24 Feedback also highlighted the specialist knowledge that a Retrofit Designer would require, and that the role would be "critical to the delivery of high-quality installations and ensuring that unintended consequences are minimised through appropriate specification and design detailing".

"This role is of the upmost importance as a retrofit designer will need to have specialised knowledge of all aspects of building pathology and of low carbon technologies, in order to be able to assess each building individually and decide upon possible pathways for that building - not all properties will be appropriate for all interventions, particularly where traditional buildings might have issues of construction or heritage and as such, appropriateness of interventions must be carefully considered". Kingspan Insulation Ltd

4.25 For example, there was feedback that the Retrofit Designer would require to be aware of the following:

• The range of low carbon solutions available to decide on the best integrations of technologies for homes individually.
• The current state of play in the low carbon market.
• Available financial support mechanisms.
• Ancillary and advisory services.
• Qualified installers.

4.26 Build Environment Forum Scotland commented on the wording used in the Consultation Document in relation to the Retrofit Designer role for properties of Risk Grade C, and noted that it is inconsistent with the previous categories and also the requirements PAS 2035, which requires a progressive increase in qualification through each grade of risk. Alternative wording was suggested:

"There is a danger that the current wording will result in a reduction in standards, and will result in a significant increase in inappropriate retrofit measures and failures. The current wording suggest that conservation expertise is optional for high-risk buildings.

This should therefore be changed to reflect the actual requirements of PAS 2035, and the wording as it currently appears "Risk grade C – same as risk B but for traditionally constructed buildings can also include:…Should be changed to: "For projects assessed as risk grade C, and to which the requirements of Path C apply, and the building to be improved (or any part of it) is traditionally constructed or protected, the Retrofit Designer shall also be accredited or certified in building conservation…"

4.27 SELECT (and others) made reference to competent person registration/schemes (e.g. the competence for Retrofit Designer lists holding competent person registration for oil heating), as elaborated further below.

"Competent Person Schemes are not applicable in Scotland. While some organisations may offer registration with such schemes, this is for work carried out in England & Wales only. The requirement for MCS registration for microgeneration installations is also not needed. The Requirements for the UK Smart Export Guarantee states: "applicants will be asked to demonstrate that their installation and installer are suitably certified. You may have an installation certificate to demonstrate this. This may be a Microgeneration Certification Scheme (MCS) certificate, but the SEG also recognises that other schemes may be equivalent to MCS. If you do not have an MCS certificate, your installation and installer should be accredited in accordance with EN 45011 or EN ISO/IEC 17065:2012. You should speak to your chosen SEG licensee to understand exactly what information they need from you." The requirements for retrofit microgeneration designs should match that of the Smart Export Guarantee". SELECT

"…the PAS 2035 does not ensure that individuals are competent and given the levels of risk to assets, there is also a need for understanding the different levels of competency. One way to address this is through competency schemes which help provide a future model for the robustness needed in demonstrating competency in retrofitting and we believe this should be incorporated into these role requirements. The Chartered Institute of Building have been working to address competency standards for sustainability and energy efficiency through a Building Conservation Certification Scheme. Applicants are required to demonstrate their competence against the International Council on Monuments and Sites Training and Education Guidelines based on their experience and qualifications.

There are three levels of competence to provide individuals at every level the opportunity of furthering their career in building conservation, these are: Registered, Proficient and Certified. Those at the 'certified' level are recognised by a growing number of organisations that require certified experts in conservation. For traditional buildings, such as listed buildings, we feel that individuals should be at the 'certified' level in order to demonstrate competence. Additionally, those providing training concerning traditional buildings should be certified as well". The Chartered Institute of Building

4.28 An individual respondent commented that a key consideration would be "the availability of suitably qualified people in Scotland to undertake the Retrofit Designer role especially where designer also requires to be an accredited member of a recognised building conservation body sponsored by recognised organisation". It went on to add that "there would be limited qualified people in the UK to undertake this role, and fewer in Scotland".

Retrofit Evaluator

4.29 The Retrofit Evaluator was also considered an important role in the retrofit process, for example it was noted that they:

• Would be able to assess the effectiveness of a project and gather numerical, quantifiable data to validate the chosen approach – "Proper evaluation allows for development of new knowledge and understanding of building performance and can help to improve future recommendations".
• Could cover a variety of purposes, including considering: the health and wellbeing of occupants and building fabric (e.g. indoor air quality, temperature, structural moisture); the environmental performance of the building in use (e.g. energy consumption and operational CO2 emissions); the utilisation of the building (e.g. access to guidance and explanation of controls and operation, future maintenance needs); the cost of operation/occupancy (e.g. performance of the envelope and the services installed); and any differences between intended and delivered performance.
• Must have the skills required to understand why a project has not been delivered as expected in the event that a basic assessment indicates that a project does not meet required standards.
• Must be aware of standards and initiatives that drive greater performance. One such standard is EnerPHit and the Passivhaus approach that aims to reduce the demand for heating, by improving the efficiency of the building fabric, such that the same level of thermal comfort can be attained with reduced heating provision.

4.30 Some wider points noted included:

• Tighean Innse Gall posed a question around why the Retrofit Evaluator role would require to also hold the Scottish Level 6 Award in Energy Efficiency Measures for Older And Traditional Buildings if they are "only working on stock that is post-1919".
• An individual noted that the evaluator role "should be more independent, creating better checks and balances".

Retrofit Advisor

4.31 Retrofit Advisors were considered important given the role they would play in the "delivery of independent advice to homeowners".

"…we welcome inclusion of the City and Guilds Energy Awareness Training as this aligns with the requirements upon advisors working for Home Energy Scotland". National Insulation Association

4.32 Kingspan Insulation Ltd highlighted that there was a "significant difference between general advice and targeted advice". Further, given the relatively low level of awareness among the general public towards low carbon technologies and confidence in how these work, the organisation also emphasised the essential role the Retrofit Advisor would play in "education and ensuring confidence from customers in their choices for a low carbon option". The importance of "softer" skills such as customer engagement and communication was emphasised.

"Understanding of heat pump technologies and the opportunity for installation is low amongst the general public and even across some parts of the sector. There are many myths about heat pumps which need to be addressed. There is therefore a need to ensure that those advising homeowners are literate on this subject and able to provide high quality, independent advice to consumers. Knowledge transfer between the above job types will therefore be important".

4.33 The National Trust for Scotland commented that those who deliver advice on retrofitting and energy efficiency should be "trained to a minimum standard on the characteristics of pre-1919 buildings so they can offer clients efficacious advice on products and techniques".

4.34 Built Environment Forum Scotland noted "serious concerns" relating to current narrative on the role of the Retrofit Advisor, and considered this to be the "least well-regulated step in the chain". It went on to add that:

"This could lead to a poor outcomes for clients as initial advice vs. co-ordination/action roles could be at odds. Advice role also appears to include no current understanding of advice in relation to traditional buildings. There is mention of that happening "as PAS2035 develops". Given the scale of the pre-1919 estate in Scotland (19% of building stock), this needs to be included from the start, not bolted-on at a later date. As advice may well be the first step for many, the steps within this plan do not build confidence and clarity for home-owners and could fail to support high levels of consumer confidence".

4.35 More widely, both The Royal Incorporation of Architects in Scotland and The Architectural Heritage Society of Scotland commented that:

"It would be preferable for the Scottish Government to develop its own set of standards and make them available without charge on their own website, (as Historic Environment Scotland has done with their own Technical Standards and guidance). British Standards Institution publications are expensive and we are concerned that small and medium sized businesses do not have access to them".