Energy Efficient Scotland development: consultation analysis

Supply chain

Impact on Supply chain: skills and capacity

To develop a set of actions to achieve and fully implement a robust quality assurance framework for Energy Efficient Scotland that reflected the needs and views of the Scottish supply chain, an industry-led Short Life Working Group (SLWG) was set up. This included representatives from across industry, consumer organisations and enterprise and skills agencies. The Group met throughout 2018 and considered quality, skills and capacity, consumer protection, the non-domestic sector and procurement.

Overall, the Group made 19 recommendations for Energy Efficient Scotland and these are summarised in the consultation paper^[8].

The Scottish Government is considering the recommendations in the context of the development of other key elements of the Programme and will revisit all of the recommendations in due course. In order to engage more widely on the Group’s findings, the consultation poses three questions: on the recommendations for quality control and consumer protection, on how these objectives can be achieved while allowing maximum participation from suppliers, and on the role of the Scottish Government in ensuring quality criteria are met.

Question 10 - The Short Life Working Group have made recommendations which they believe represent the actions required to ensure that Energy Efficient Scotland will achieve consistently high levels of quality, health and safety and consumer protection. Do you agree? If not, what more or less should be done?

Responses to Question 10 by respondent type are set out in Table 3 below.

Among those respondents who answered the question, a majority - 63% - agreed with the SLWG’s recommendations, while 37% did not. ‘Organisational’ respondents were more likely to consider the recommendations to be correct than were ‘individual’ respondents, at 72% and 50% respectively. However, 38% of respondents did not answer the closed element. 

Table 5: Question 10 - Responses by type of respondent.

	Yes	No	Not answered	Total
Organisations:
Academic	1		2	3
Building component manufacturers/services	4	2	4	10
Energy related private sector	5		8	13
Local authority or interagency partnership	11	2	3	16
Other		1		1
Private landlord or property management		3	3	6
Professional or representative body	5	4	7	16
Public sector or body - other			2	2
SG delivery partner	2		1	3
Third sector	3		2	5
Total organisations	31	12	32	75
% of organisations answering	72%	28%
Individuals	14	14	12	40
% of individuals answering	50%	50%
All respondents	45	26	44	115
% of all respondents	39%	23%	38%
% of all those answering	63%	37%

There were 74 further comments at Question 10, the majority coming from respondents who had agreed at the closed element, but who went on to add qualifications or further suggestions. Several of the most extensive contributions were from respondents who did not answer the closed element. After a general summary, the analysis below is therefore arranged primarily according to the recommendation or topic referenced rather than by the respondent’s answer at the closed question. 

Some respondents noted their broad agreement, or agreement in principle, with the recommendations which were described as welcome, relevant and comprehensive. It was also suggested, however, that more detail is needed, that there is no indication of how the recommendations will be implemented, or that further details on targets or guidelines for delivery would be welcome. In terms of scope, it was argued that the SLWG’s discussions were largely focused on the self-funding market, and that there needs to be consistency of approach across all residential sectors, or that there is currently too great a focus on installation and that a quality assurance framework should cover the whole process: ‘planning, doing and checking’. Another general point was a call for a single national delivery body to oversee works carried out as part of Energy Efficient Scotland.

It was also reported that 47% of reported nuisance calls in Scotland in 2018 related to mis-selling and cold calling about energy efficiency products and that combined with relatively low levels of awareness about consumer rights and protections, this underlines the need for a quality assurance framework and easily accessible system of redress.

Some respondents who did not agree with the SLWG’s recommendations made comments relating to wider aspects of Energy Efficient Scotland or remarked on previous bad practice, lack of enforcement, or lack of redress. Others expressed disagreement with aspects of specific recommendations or identified significant additional content that they felt should be included, such as innovative alternatives to conventional retrofit using an industrialised approach, or proper recognition of the importance of consumer information and contractual issues.

More general comments on the SLWG included the need for the Federation of Petroleum Suppliers and OFTEC to be involved with the SLWG since, in their view, they are well placed to address a number of relevant issues. It was also suggested that the SLWG has placed too much faith in use of modelled data to deliver the objectives of Energy Efficient Scotland and that Scottish Government Delivery Partners who are members of the group may have a conflict of interest in this respect.

SLWG recommendations

Quality

Recommendation 1. There should be Quality Assurance criteria developed which detail the key mandatory requirements for suppliers wishing to participate in Energy Efficient Scotland.

Relatively few respondents commented specifically on Recommendation 1. While there was agreement with the development of Quality Assurance criteria, it was argued that creating consumer confidence requires that these criteria and the proposed Quality Mark (Recommendation 2) are meaningful and offer significant protection. If the Quality Mark does not insist on specific model terms as a condition of membership, it was suggested the quality assurance scheme will need to audit terms submitted.

There was support for Quality Assurance criteria to be presented in a central, comprehensive and accessible format, and for clear messaging to consumers.

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 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 2 attracted the most comments at Question 10. Many of those who commented directly on this recommendation noted their support for a Quality Mark. Many, a small number of whom were amongst those offering general support, highlighted issues around alignment with, or avoiding duplication of, UK-wide standards. These were that any approach should:

• Be UK wide.
• Align standards to PAS2030, PAS2035 and TrustMark in line with the Each Home Counts Review, and avoid duplication that leads to additional burden for suppliers. ‘Energy related private sector’ respondents in particular made this point.
• Not lead to increased costs to small businesses.

In particular, it was argued that since any ECO work in Scotland has to be carried out by a business that is registered with TrustMark and has demonstrated compliance with PAS2030 and PA2035, it would make sense to for the supply chain in Scotland to be aligned with these requirements. Further, 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.

It was also suggested that a Quality Mark should not try to create a one-size-fits-all list of requirements, but rather should take a principles-based approach that sets high-level requirements and then allows companies to demonstrate how these requirements are met.

Clarification was sought as to how quality of work that is sub-contracted by accredited installers would be assessed and whether consumers would be protected, and it was suggested suppliers delivering measures outside Energy Efficient Scotland should also be encouraged to adhere to the same criteria.

Other points on Recommendation 2 were that:

• Communication of the Quality Mark criteria and consistency of the message being delivered will be key to success. It was reported that consumers are not aware of the existence of quality marks or the benefits of using companies who are registered under them.
• Clarification is needed as to the organisation(s) which will be vetting and investigating suppliers, and how the robustness of the system can be ensured. It was argued that the scheme must be prepared to exclude companies from the market and be able to defend those decisions. A publicly available Directory of Suppliers could include results from independent inspections and provide information on those suppliers who are subject to sanctions.
• Information is needed on whether there will be an appeals process for installers and how such a process would operate.
• ID cards could detail skills, training and competencies achieved.

Concerns were raised, however, that Recommendations 2 and 3 appear contradictory and that a ‘robust vetting and verification process’ will inevitably lead to bureaucracy and cost to SMEs and microbusinesses.

It was also argued that there may be insufficient time to set up the type of scheme envisaged for accreditation if the acceleration of Energy Efficient Scotland is agreed.

Finally, there was a view that more badges do not provide better quality and that it would be far better to have a 100% post install monitoring system.

Recommendation 3. The verification process must not place an undue administrative or financial burden on SMEs, particularly micro-businesses.

As noted with respect to Recommendation 2, it was argued that there is a risk that the type of verification process envisaged will impact on small and microbusinesses, and it was also suggested that, in general, suppliers would rather use existing processes than adopt novel frameworks. It was also argued, however, that the Scottish Government should focus on the primary objective of ensuring work is of a high standard and customers are protected.

Issues associated with small and microbusinesses were seen as having particular significance in rural and island areas, where much of the supply chain is made up of such companies. The lower availability of work in these areas means businesses may be unable to justify the costs involved in accreditation, with a negative impact on delivery of measures and on the local economy. Suggestions were that:

• Some consideration of rural/island proofing is needed to ensure a level playing field.
• While being constructed to ensure consistent standard, the process must be flexible enough to cater for different business models.
• A staged accreditation system could be considered, to allow micro-businesses access to particular markets while focusing on maintaining universally high standards.

It was queried whether the time allowed for suppliers to complete the Quality Assurance criteria is to be different for different sized businesses or locations and how suppliers would be supported through the process.

It was also argued that as the cost of being accredited with the Quality Mark is likely to impact SMEs, a vetting scheme provided by a not-for-profit organisation could help to support a level playing field for suppliers. Otherwise, it was suggested, there may be a tendency for suppliers to become members of those schemes that are cheapest and easiest to join.

Recommendation 4. Define what success looks like in terms of quality for the building, consumer and funder, and set specifications for the final output of work.

Comments on Recommendation 4 included that this is welcome and will both help to build a trusted market, and help consumers and funders to specify work. While it was seen as important that there should be a holistic view of a building’s requirements, the Scottish Government was also advised to consider how the information about options can be provided so that consumers can make an informed choice.

Specific aspects referred to were: 

• The need for advice to be high quality and property-specific and to include design and specification, as well as best practice installation and aftercare.
• A technical assessment to ensure the measures are suitable for the property concerned and will integrate with other planned or existing measures. It would also check ancillary work that may be needed.

It was also suggested that by considering the household as a whole and not limiting assessment of success to the building, advice and support could be tailored to support behavioural change where necessary. Use of customer satisfaction surveys was also proposed.

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.

The new designer role was welcomed by respondents who commented specifically on Recommendation 5, although the retrofit co-ordinator role set out in PAS2035 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.

Additional points raised were:

• A ‘system designer’ role would be a valuable addition to the building design process, ensuring heating systems are planned holistically and optimised in each case.
• Rather than having a role to ‘ensure that that a whole building approach is taken’, the designer should instead ensure that a whole house approach is considered, leaving the customer to decide the approach taken.
• Additional information and training on the hidden transaction costs associated with design and project co-ordinator roles might be needed.

Recommendation 6. Independent inspections of installations must be carried out as part of Energy Efficient Scotland to ensure quality standards are being consistently met.

Comments on Recommendation 6 included agreement that independent inspections should be carried out, with substandard installations investigated, and that an open and transparent assessment process will ultimately strengthen customer protection.

Other comments:

• In addition to post-installation inspection to ensure quality standards, a pre-installation inspection and verification service would be desirable, helping to ensure measures are feasible, appropriate and cost-effective.
• An audit should be carried out post-install to ensure that the measures have had the desired effect in reducing energy consumption, and to identify additional requirements for user training to maximise potential benefits.
• Consumer protection must cover both technical and contractual issues, and both require audit. Monitoring that focuses only on technical issues will ignore the problem of mis-selling and performance estimates must be examined from the perspective of the consumer contract.
• Inspections should be paid for by the installer and could form a specific element of a quotation.

While two respondents sought clarification on who will provide inspections, a third suggested suitable candidates to be Local Authority Building Control Services, or an accreditation organisation appointed to oversee the Energy Efficient Scotland supply chain.

Other elements seen as important:

• Some form of accreditation and monitoring of standards for inspectors will be required.
• A central collection point for inspection reports would allow monitoring of suppliers who are working across different regions or who are carrying out large numbers of installations that may be high-risk in terms of consumer protection.
• Effective enforcement is needed. It was suggested that under a certification scheme for microgeneration, installers of renewables were certified but little or no follow-up was undertaken to ensure quality of installation. Details of sanctions were requested, and whether temporary sanctions will be imposed during investigations.

Additional suggestions on Quality

Potential roles for other professionals such as architects, surveyors and planners, in the delivery of Energy Efficient Scotland were thought to have been overlooked.

The importance of robust monitoring and enforcement were also highlighted. It was suggested that if given responsibility for delivering these functions, local authorities would require additional resources.

Ongoing maintenance was also identified as being critical to the success of energy efficiency measures and it was argued this must be communicated to the consumer as part of the final handover. 

Skills & capacity

Recommendation 7. Suppliers carrying out installs under Energy Efficient Scotland must meet appropriate skills and competencies. A skills and qualifications matrix should be developed and clearly communicated to the supply chain to reflect this.

Among respondents who commented on Recommendation 7 remarks were often focused on:

• Specific requirements for work on buildings of different types, especially those of traditional construction.
• A need for robust training for EPC assessors, including improvement to assessors’ understanding of different building types, particularly traditional buildings.

It was 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.

To give confidence, it was proposed that a separate independent organisation should carry out assessments or that consideration should be given to how the role of assessor and installer are separated to avoid the potential for mis-selling. Recognition of the importance of training in acceptable selling activities and in contractual issues was also seen as important.

With respect to the proposed skills and qualifications matrix, it was suggested that this should be developed in collaboration with industry and may vary depending on the energy efficiency measures being installed.

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. 

There was a view that Supply Chain Management techniques may be useful for developing frameworks for competencies and responsibilities between different elements of the supply chain, with the aim of promoting a holistic, process-oriented approach. The only other point on Recommendation 8 was that future requirements, such as the need to future-proof housing for low carbon heating, should be taken into account.

Recommendation 9. A mobilisation plan for developing skills for the supply chain should be published to help provide pipeline security and build capacity.

Comments on Recommendation 9 were very limited and included both general agreement, and a view that it will not be possible to develop the supply chain to meet the level of demand projected.

Recommendation 10. Energy Efficient Scotland should be well advertised to the supply chain via roadshows, events, webinars and trade publications.

There were few remarks on Recommendation 10, but those who did comment advised it was very important to advertise Energy Efficient Scotland to the supply chain and to bring potential stakeholders together. Specific events for certain measure types were suggested.

Recommendation 11. Investment in Energy Efficient Scotland must support inclusive economic growth

One respondent noted agreement with Recommendation 11.

Additional suggestions on skills and capacity

A small number of respondents made additional points relating to education and training. It was argued that education and training on the installation and operation of energy efficiency measures, both for college students and existing tradespeople, is an important area missing from the current recommendations. A view was expressed that responsibility for training should be removed from private sector suppliers and placed into the college and further education sector.

Consumer Protection

General comments on Consumer Protection included an observation that this should be at the forefront of all actions, or that mistrust created under previous energy efficiency schemes must not be repeated. It was also noted that:

.. the mandatory nature of the upgrade process will require a high standard of consumer protection since the occupant does not have the option of not upgrading. An ombudsman could be created to allow householders to challenge “poor advice”. This would be beneficial due to the mandatory nature of upgrade actions, which may be expensive and contrary to the householders’ wishes.
Academic respondent

Recommendation 12. There should be a clear, simple and well-defined complaints process with support available for the consumer to navigate the process.

Some respondents who commented on Recommendation 12 agreed that there should be a clear simple and well-defined complaints process, or added that this should include a similar route for redress when things go wrong. Other suggestions were that:

• The complaints process, and the consumer protection offered by the Quality Mark, should be highlighted to consumers.
• There should be clear definition and messaging on when consumers are covered under the EES Programme and its resolution pathway.
• Provisional or temporary sanctions against suppliers should be possible in the event of serious or high-volume complaints. An example was cited of a company being able to continue trading as an authorised Green Deal provider despite numerous complaints.

Clarification was also sought as to which organisation would be responsible for the central complaints register and what the process and timescales for investigation would be. How consistency of decision making across Scotland can be ensured was also raised and suggestions were made for tackling phoenix companies within the sector.

Noting their disappointment with the recommendations on consumer protection, one respondent observed that:

While we agree that the complaints process is important, it is the final stage on a long journey that should have protection at every stage.
Other respondent

It was also suggested that it may be necessary for the Quality Assurance scheme itself to become an Alternative Dispute Resolution (ADR) provider.

Recommendation 13. There should be data sharing between key agencies in Scotland to monitor the frequency and nature of complaints, and identify and deal with non-compliant and rogue companies promptly.

Comments on Recommendation 13 included that a proposal to identify and deal with non-compliant and rogue companies is particularly valuable. Sharing data was thought to be sensible and to bring a number of advantages, with use of a range of data sets seen as essential.

It was argued that data sharing between bodies such as Citizens Advice Scotland and Trading Standards Scotland could help to monitor the frequency and nature of complaints received. The ‘public sector or body – other’ respondent making this point added that in the light of their own role in enforcement and in leading policy on unfair terms, they would like to be able to see complaints on unfair terms issues.

Recommendation 14. Consumers and suppliers should be encouraged or required to enter into a contractual agreement outlining the responsibility of the supplier completing any of the retrofit stages.

Use of contractual agreements was supported, with the argument that it brought distinct advantages to consumers. It was suggested that such agreements could outline and define the responsibility of suppliers, and could simplify the complaints process by making it clear to consumers who to approach in the event that something goes wrong. Use of a recognised template, designed with input from a range of stakeholders including consumer protection organisations, was proposed.

However, the statement that ‘consumers and suppliers should be encouraged or required to enter into a contractual agreement’ was regarded as a cause for serious concern for one respondent. They argued that it is essential that contracts are in place, and that they must be legally sound and fair. The use of Competition & Markets Authority guidance on Unfair Contract Terms Guidance was recommended.

Other points raised:

• Problems when a supplier goes out of business and cannot fulfil its obligations or offer consumer redress must be addressed.
• Multi-occupancy buildings, that may also have mixed tenure, may present particular problems. Where present, providers of factoring services will be involved in interactions between owners and suppliers, but in the absence of a factoring service, owners will need an established means of coordinating to ensure a programme of upgrades to the building meets the required standards.

Recommendation 15. A campaign of awareness raising about Energy Efficient Scotland and energy efficiency retrofit in general should be undertaken during the transition period and beyond.

Raising awareness was seen as essential for both supply chain and homeowners. The potential role of supply chains as ambassadors for energy efficient retrofit was also noted. Proposals included campaigns tailored to address trigger points, barriers and advice requirements for different sectors and communication setting out what Energy Efficient Scotland customers should expect, including information on standards, installation costs, customer service and outcomes. Use of scenario testing to identify consumer detriment was seen as vital, particularly as many sales are likely to be off-premises sales and sales to vulnerable consumers.

Recommendation 16. There should be support and advice for consumers on guarantees and warranties.

Points on Recommendation 16 included a welcome for the advice and protections recommended, and that:

• Minimum standards for guarantees and warranties should apply to both installation and materials, with appropriate cover for defects and liabilities, and these should be clearly communicated to consumers.
• As businesses may cease trading, customers should have access to insurance-backed guarantees (IBGs), signed off by a panel of financial experts and consumer protection advocates. Alternatively, funding could be set aside to provide an ultimate recourse to redress and compensation when all else fails.

A link between guarantee and warranty information and a property’s EPC was also proposed, with a ‘building passport’ of information about the property including maintenance and replacement requirements. It was argued that advice on maintenance and consumer behaviour could also help ensure guarantees and warranties are not invalidated through improper, or lack of, maintenance.

Provision of plain English guides offering accessible and practical advice on how to use the products consumers have had installed were also considered necessary.

There were no specific comments on Recommendations 17 – 19, concerning the Non-domestic sector and Procurement from respondents, although the issues were discussed at the workshops.

Workshops’ perspective

General points about the context in which quality assurance will operate were: There are issues around performance gap and design, and quality assurance is currently poor in this regard. The Passivhaus Planning Package is a better predictor and is more accurate than EPCs. There is a perception at least that some programmes focus too much on cost as opposed to quality. The Scottish Government may want to redefine/define Value for Money. Thought will be needed as to how a possible two-tier system, with a Scottish quality mark for the Programme, sits alongside a UK government supported Trustmark and links to ECO funding. There were suggestions as to other quality assurance schemes or approaches that could be drawn on. These were that: European accreditations may be worth considering as these fit with the Microgeneration Certification Scheme (MCS) and also relate to various IOS standards. The quality assurance requirements for Passivhaus design may offer lessons to be learned. Consideration should be given to how Warmworks carry out inspections.  In terms of how quality assurance might be delivered, it was felt that it will be important to consider the quality assurance mechanisms the market currently offers and that carrying out a gap analysis may be of value. There was also a view that independent inspections are critical. There were concerns that quality assurance-related costs, combined with no guarantees of work, could be a barrier for some and could mean the MCS in particular is seen as inaccessible to SMEs. Also in relation to costs, it was suggested that while the proposed designer role is a positive step it will lead to additional costs for suppliers.  Workshop participants raised concerns about there being sufficient skilled people in place should targets be introduced; the importance of upskilling was emphasised. In terms of possible approaches, comments were that: Recognising existing learning is as a good way to identify skills as requiring qualifications and accreditations, not least because these could be expensive. There is a question around how to incorporate the required learning into the education and vocational supply stream. In particular, how can young people be engaged. Participants thought it important that lessons are learned from Green Deal, and it was reported that Warmworks have a good record. The deposit protection scheme via MCS members was given as an example of a good consumer protection approach. Workshop participants raised concerns about the European Single Procurement Document. There were calls for clarity around some of the questions and that it should be written in plain English.  It was suggested that SMEs are put off by the Public Contracts Scotland website, and the procurement process generally. There was general support for the SLWG recommendations, with a view that joined-up thinking across agencies will be important. It was also thought that one approach across Scotland is not likely to be effective and that different targets and rules should be in place for remote/rural regions for example. There were also calls for a focus on increased localisation and using local services and businesses. It was suggested that the Home Energy Scotland network could be used to help this take place. Another suggestion was that advice should be taken from trade bodies and associations about what is possible and how best to proceed.

Question 11 - Do you have any views on how this can be achieved whilst at the same time ensuring maximum participation from suppliers across Scotland regardless of their size and geographical location?

In total, 69 respondents answered Question 11. Several of the points reflected issues raised at Questions 4 and 10 and are only noted briefly here, where the analysis focuses on the size of suppliers and their geographical location.

Sustained level of demand and funding

Several respondents pointed to the importance of long-term policy, predictable demand and sustained funding in order to create interest within the supply chain and ensure small companies see the benefits of being accredited.

Procurement

A small number of respondents commented on aspects of the procurement process which, it was argued, should be made fairer or more accessible for SMEs and microbusinesses. Specific issues identified were:

• Time frames. Evaluation of Energy Efficient Scotland Phase 1 pilots was reported to have found that short-term funding schemes favour larger contractors who are able to mobilise their workforce at short notice, with the potential to exclude small, local contractors.
• Competition: Pilot evaluation also revealed a view among study participants that work is often won by the same contractor, suggesting greater opportunity for more contractors to participate is needed.
• Achieving lowest cost. The potential tension between economies of scale and awarding small contracts to suppliers was noted, with a suggestion that high quality procurement routes are needed to manage this. It was also suggested that the lowest price tender rarely represents the lowest cost at the end of the job, since variances throughout the contract may be used to make up a shortfall.

It was argued that since local authorities may not have sufficient in-house legal and procurement experts, a hub of procurement expertise should be considered. Delivered via the National Delivery Mechanism and/or specialist procurement organisations, such a hub could support and assist coordination of Energy Efficient Scotland and identify opportunities for shared project delivery.

A mechanism whereby LHEES procurement can favour local businesses was also proposed, with the argument that in the absence of such provision, there will be a drain of installers and assessors to the most populated areas with the risk of increased costs in rural and island areas. It was reported that in some geographical areas, low volumes of work mean incentives or financial support to installers will be needed. Possible additions to the tendering process were also suggested, for example to illustrate how winning work could contribute to the local economy, or that training programmes would provide community benefit outcomes and provide skills in areas which may be suffering a shortage.

Delivery

A national delivery body with responsibility for delivering Energy Efficient Scotland was proposed by two ‘SG delivery partner’ respondents. Successful delivery of the Warmer Homes Scotland scheme was cited as demonstrating how such an approach can ensure maximum participation from the supply chain, regardless of their size and geographic location.

A focus on local delivery and local area based programmes was also suggested, with local authorities seen as well placed to maximise participation within their own areas. Giving particular consideration to delivery in rural and island locations was also advised.

Other suggestions were that:

• Nationally administered supplier/contractor frameworks could be allocated on a regional basis, and be monitored by the local authority in their area with financial support provided by the Scottish Government.
• Rather than attempting to apply a centralised model, areas could be defined according to their similarities, and stakeholders consulted to determine what the impacts are likely to be.

Understanding and supporting local supply chains

The importance of understanding local supply chains was highlighted by a ‘local authority or interagency partnership’ respondent, who described their own work in this respect. They reported finding it hard to identify and contact the local trades’ community and suggested that the creation of a trades’ representative to represent all trades in an area could be a key support mechanism. It was argued this could also contribute to development of a communication campaign targeting local trades. Specific funding to local authorities to help them to gain an accurate picture of the help needed by SMEs was proposed.

Supporting local supply chains was seen as important. A ‘third sector’ respondent noted their own findings that a Scottish energy efficiency scheme which focused efforts on rural areas did well in countering the urban bias of some UK-wide schemes.

Education/training

Respondents noted the importance of education or training, including that by providing training in the trades supporting Energy Efficient Scotland, colleges will assist in strengthening local economies. It was suggested that training requirements across Scotland should be identified, with managed and certified training packages arranged in locations around the country. Suitable training for Trading Standards and Building Control officers should also be available.

It was also argued that appropriate training in energy efficiency retrofit should be required regardless of the geographical location or size of the business involved, and that other sectors within the construction industry would not accept lower standards of training because of a company’s size or location.

Aspects of a Quality Assurance scheme

It was argued that existing procurement frameworks can exclude smaller contractors who do not have resources or time to undertake additional accreditation:

… any new accreditation framework needs to account for the existing skills and qualifications that a range of trades and organisations hold and explore how these can be acknowledged when appropriate and upgraded for entry onto the frameworks.
Academic respondent

Respondents suggested that any scheme should be easy to join to encourage engagement with small local suppliers, that assistance could include funding for training or certification, and that consumer protection schemes should be ‘seen to support legitimate honest business to get things right’. It was also argued that an effective complaints process that removes rogue businesses might encourage those with smaller margins but better working practices.

As at Question 10, several respondents pointed to the benefits of harmonisation of accreditation schemes, with adoption of, or alignment with PAS 2030, PAS 2031, PAS 2035 and TrustMark all proposed. It was suggested that costs associated with duplication of accreditation schemes would have a disproportionate effect in remote and rural areas. While it was noted that a new scheme could provide an opportunity for industry engagement in creating something particularly relevant to Scotland, it was still suggested that equivalency with other schemes would be required.

A small number of respondents referenced the MCS and the Renewable Energy Consumer Code as potential models for a quality assurance scheme for Energy Efficient Scotland. Bringing work into the Building Regulation system was also suggested, with a scheme similar to the current Certification of Design and Construction.

Introduce standards

Several ‘local authority or interagency partnership’ respondents suggested the recommendations should be introduced as standards to be met by suppliers, that there should be a rigorous installer registration scheme, and that a register of assured trades is set up and maintained locally.

Small firms

A small number of respondents suggested measures that might be taken to avoid potential exclusion of SMEs from Energy Efficient Scotland:

• Staged accreditations could be required, with accreditations linked to specific measures or building types.
• Initially, SMEs could work for larger contractors that can meet all accreditation conditions. A requirement to take an SME ‘under their wing’ could be built into a first round of contracts, on completion of which, the SMEs that are assessed as competent could go to take on work directly.

Engagement

Industry bodies and professional organisations were argued to be important, both as a route to engaging with tradespeople, particularly SMEs, but also to ensure that quality standards are achieved. It was suggested that a wide ranging, holistic approach to explain why action is necessary would help to engage with the industry. In terms of stimulating interest in Energy Efficient Scotland, publicity was regarded as important. Regional meetings and roadshows for working groups were described as invaluable, not only making it easier to for companies to participate, but also giving those who travel outside their own region a more rounded picture.

Workshops’ perspectives

Participants felt that any tendering process for contractors should be kept simple, and there were concerns that many suppliers, particularly those at the smaller end of the SME scale, do not have specialist skills needed to deal with tendering. In terms of other features of a tendering process, comments were that it should be clear that quality requirements extend to sub-contractors. Finally, it was noted that the European Single Procurement Document is recognised as a quality check. There was general support for the introduction of a card scheme. Participants raised concerns about the knowledge base of the current workforce. It was noted that, for example, a four-year plumbing course includes little training on renewables. In terms of the future pipeline of skilled people, participants suggested educating children from an early age on the benefits of getting involved with the trades, as well as recognising energy efficiency as an industry. Other issues raised by those attending the workshops were that, while industry itself should not develop the approach to quality assurance, they should work on the project in partnership with the Scottish Government. Specific suggestions for features of a quality assurance approach were:  Renewable heat should have something similar to the Gas Safe Register in terms of a registered card scheme. Any registers developed should be trade body led and people would have to sit a test to get on register. As well as a standardised product approval standard, there needs to be a standardised design tool for renewable heat, and particularly for heat pumps.  In terms of measuring what success looks like, it was suggested that EPCs are unreliable. There was also concerns about the lack of policing and enforcement of EPCs. Participants thought it was important for the Scottish Government to look at monitoring, for example because problems were reported as part of the SEEP pilots. Looking at best practice examples of firms operating in the market to consider lessons learned was also proposed. Workshop participants also considered quality and consumer protection. They raised concerns that there is a lack of understanding around where householders should turn if they experience difficulties. Trading Standards were seen as a likely option, although there was a query as to whether, if so, additional resources need to be made available to those services.  There was also a proposal that additional consumer protection options will be needed, including around advocacy and advice.

Question 12 - What do you think the role of Scottish Government should be in ensuring the quality criteria are consistently met?

In total, 82 respondents answered Question 12. Although some common points were raised, responses at Question 12 were diverse, often reflecting issues and perspectives that respondents had raised at earlier questions. The list below is not exhaustive but pulls together more frequently raised topics. However, all responses are available in their entirety to the Energy Efficient Scotland policy team at the Scottish Government.

Policy and delivery

Key high-level roles were suggested to be providing policy, creating an appropriate legal framework, and having strategic oversight of standards to ensure quality criteria remain fit for purpose. Regulation and monitoring to ensure that quality criteria are met consistently were also suggested.

Differing views were expressed on the degree to which government might be involved in delivery and administration. For example, one respondent suggested:

There should be involvement on some level at least by providing a mechanism for the setting of universal guidelines. The risk of the perception of government interference must be considered.
Energy related private sector respondent

while another commented:

The Council views the Scottish Government as playing a central role in the delivery of Energy Efficient Scotland. The Scottish Government should lead on administering a national framework for suppliers and installers, product eligibility, compliance with manufacturer installation guidance to ensure a consistent approach across the contracting base in Scotland.
Local authority or interagency partnership respondent

It was also suggested that the Scottish Government should set up a national delivery body and work collaboratively with the appointed body to uphold the quality standards of the Programme. Responsibility for developing standards and engaging with relevant agencies should be within the remit of the body overseeing the wider delivery.

An additional proposal was that the Scottish Government should itself report to an independent statutory body such as the Committee on Climate Change.

Other actions suggested were:

• Intervene where there is market failure.
• Implement a compliance procedure with resources for enforcement.

Support for Local authorities

It was argued that while standards could be agreed at a national level to ensure consistency, responsibility for compliance should be devolved to local authorities who would require additional resources. ‘Local authority or interagency partnership’ respondents in particular made the latter point.

An alternative suggestion was that to relieve councils of such responsibilities, a third party could be appointed to carry out this role.

Developing quality assurance

Suggestions on quality assurance included that the Scottish Government should:

• Ensure the requirements of the Quality Mark accreditation are met.
• Provide quality assurance accreditation by a not-for-profit organisation.
• Support existing quality assurance frameworks where possible and avoid duplication that adds to costs. Specific suggestions were: establishing a GB-wide standard; outlining a position on PAS2035; working with the British Standards Institute to establish guidance; promoting TrustMark; and providing clarity on the relationship of Quality Mark to other schemes.
• Develop ‘an entirely distinct Scottish perspective, in effect at the cost of ignoring the UK operational landscape’ but with ‘parity across the UK on a fundamental core level’.
• Establish a system of registration for contractors, a publicly available directory and a formal code of practice for contractors to sign.
• Ensure all traders are members of an approved consumer code.
• Ensure certification bodies are effective in policing the industry.
• Create an audit body for energy assessors.
• Set up a national agency to oversee training and certification.
• Apply consistent quality assurance criteria for all housing sectors.
• Allow landlords to source their own contractors.

Enforcement

‘Individual’ respondents in particular were amongst those who suggested inspections or independent inspections and sanctions for substandard work to be priorities. One ‘building component manufacturers or services’ respondent suggested the Scottish Government should:

...set up a framework where the supply chain knows their work will be checked.
Building component manufacturers or services respondent

Random audits, third party audits, and support for local authorities to undertake audits were all proposed, as were spot checks on completed works and site inspections for live sites, post-install monitoring, and monitoring in use performance.

Complaints procedures

It was suggested there should be independent arbitration or that ADR should be used deal with disputes between consumers and suppliers. Appointment of a regulator or an ombudsman were also proposed, as was a route to redress via the Housing & Property Chamber First-tier Tribunal.

A government backed guarantee or an IBG was argued necessary to protect consumers.

Sharing information

A framework for data sharing between agencies was suggested to identify poor work and manage complaints. It would also provide a mechanism for learning from recurring issues and adjusting the programme accordingly. Other ideas were that:

• Details of directors as well as suppliers should be held centrally to reduce the risk of phoenix companies within the sector.
• Quarterly publication of statistics on numbers of failures, speed of repair, actions taken for redress, and sanctions imposed could be used as part of a marketing campaign for Energy Efficient Scotland.
• Best practice from existing Energy Efficient Scotland projects should be shared and promoted.

Providing advice and information for consumers

Providing advice and information for consumers was considered important, with a specific proposal for a one-stop-shop for access to advice, assessments and a directory of installers; a way to report complaints and to look for redress.

It was suggested that householders should be provided with user guides reflecting realistic outcomes for the products installed, how to use them and how to protect warranties and guarantees. A further suggestion was to give landlords access to  limited EPC software to model their properties and allow better understanding of the most cost-effective measures for improving the performance of a building.

Develop the supply chain

Long term commitment to energy efficiency policy was cited as a condition for market growth and innovation, with policies to drive demand in the self-funded sector noted as drawing suppliers and installers into the quality control programme.

Improve EPC methodology

It was argued EPC methodology must be improved and EPCs validated against actual energy performance data.

Take a different approach

Rather than concentrating on management of traditional approaches to retrofit, it was suggested that the Scottish Government should consider techniques and capacity to deliver net-zero deep retrofit.

Workshops’ perspectives

There was broad support for an approved directory of suppliers, which would include consumer feedback and that this approach could support the early identification of, and action against, rogue companies. In terms of aspects of the process that feed into quality, options given were tidiness, flexibility and causing the minimum of disruption. It was also suggested that a directory could helpfully be set out by region. It was also proposed that any directory could include details on the level of insurance each supplier carries.  There was also support for creating a new designer role. In relation to suppliers accessing funding, comments were that if suppliers do not meet requirements, they should not be able to continue in any programme, and in particular should not be able access any finance for their clients. Other comments were that the quality assurance for Government schemes should comply with PAS 2035 and that the Scottish Government should introduce legislation to support quality assurance. It was also reported that some schemes are already well audited and monitored and have robust processes in place. Participants thought that, while Home Energy Scotland is a one-stop-shop for front end advice, there is no source of advice at the latter stages or after the completion of any installation.  An equivalent offering to answer technical queries during works and checks on the works was proposed. As an example, it was reported that at one point the Scottish Government employed a technical contractor to answer questions connected with having accessed the Warmworks programme. Further comments were that any back-end advice would need to be independent and operate at the national and regional level.