The UK Governments consultation on the regulation of Energy Efficiency in the Private Rental Sector closes today at 11.45 pm and whilst imposing energy efficiency works to such buildings may seem very sensible there are many issues and potential problems. Gaps between predicted and actual energy savings, risk of accelerated deterioration of building fabric and risks to the health of those that occupy retrofitted buildings are all familiar issues to Edwards Hart. Chartered Building Surveyor and Director Edwards Hart, John Edwards said: “Our main concern is the way we assess energy efficiency especially when it comes to traditional buildings which form about forty percent of the private rented sector”. John added: “We may see buildings forced to have retrofit measures that are simply unsuitable and we have many examples of where both solid wall and cavity wall insulation is causing havoc”.
Edwards Hart have advised the UK Government through the consultation process of the need for caution and have raised concerns about a number of critical issues and these are detailed below:
The main concern primarily relates to the process of understanding the energy performance of buildings and in particular those traditionally built. We would agree with the growing evidence that SAP methodology is not fit for purpose in the calculation of the thermal performance of traditional buildings.
There is a lack of knowledge on how traditional buildings perform and therefore how energy efficiency retrofit affects such buildings posing ever increasing risks of unintended consequences and performance gaps between predicted energy savings and actual thermal performance.
Energy efficiency should begin with properly understanding the performance of buildings and making sure we keep them dry and in good repair. This should be the first port of call for works to buildings and is cited in BS 7913: 2013.
All traditional buildings could have character worth protecting regardless of whether they are Listed or have no statutory protection. On that basis we believe that landlords should have the right to refuse measures developed through RdSAP and the Green Deal because of harm to character and that methods of improvement are not technically suitable. RdSAP and the Green Deal do not currently have enough flexibility to exclude measures that are inappropriate or potentially harmful for traditional buildings.
The Building Regulations Part L1B (existing dwellings) 2011 edition as amended 2013 and 2014 acknowledge the potential harm some measures can impose on a traditional building:
Historic and traditional buildings where special consideration may apply
3.8 There are 3 further classes of buildings where special consideration in making reasonable provision for the conservation of fuel or power may apply:
a. buildings which are of architectural and historical interest and which are referred to as a material consideration in a local authority’s development plan or local development framework;
b. buildings which are of architectural and historical interest within national parks, areas of outstanding natural beauty, registered historic parks and gardens, registered battlefields, the curtilages of scheduled ancient monuments, and world heritage sites;
c. buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture.
3.9 When undertaking work on or in connection with a building that falls within one of the classes listed above, the aim should be to improve energy efficiency as far is reasonably practicable. The work should not prejudice the character of the host building or increase the risk of long-term deterioration of the building fabric or fittings.
3.10 The guidance given by English Heritage should be taken into account in determining appropriate energy performance standards for building work in historic buildings.
We believe that the value of the ‘Golden Rule’ is undermined by the fundamental flaws in the assessment process. The RdSAP methodologies on which EPCs are based often produce inaccurate results for buildings of traditional construction. The process fails to consider advice in other very well respected authoritative guidance such as BS 7913:2013: Guide to the conservation of historic buildings. Within section 5.3.1 Sustainability it states:
The most effective way of ensuring energy efficiency and sustainability is to keep historic buildings in good repair so that they last as long as possible, do not need replacement and do not suffer from avoidable decay that would require energy and carbon to rectify. They should provide occupancy in an efficient manner involving minimal production of carbon and use of energy without harming significance or the physical performance of the historic fabric. Using natural ventilation and light, and proper temperature and humidity control for individual rooms are ways of minimizing energy usage that respect the building’s natural characteristics.
Elements such as walls can be over a third less energy efficient if damp. Some energy efficient measures can have an adverse effect on sustainability. The actual energy efficiency of historic buildings and their potential energy efficiency with the addition of energy efficient measures should be taken into account at the outset (see 6.3). The need for energy efficiency and low carbon might also influence the selection of materials and work methods as they can impact on thermal performance and weather resistance. Building materials and products should be sourced and procured in a sustainable manner. The historic building should be regularly inspected….
We believe it to be unacceptable without reliable authoritative independent guidance on measures and performance, to rely on the ‘Golden Rule’ as an indicator of what improvements a landlord should be required to make. Landlords need to be provided with proper unbiased information and advice about improving their buildings specifically relating to age and type of construction. They also need to be provided with advice on the energy efficiency benefits of proper maintenance and repair as cited in BS 7913: 2013.
Rather than streamlining the process for improving properties that fall below band E, we have recommended that there should be more research and funding aimed at improving SAP, RdSAP and EPC’s so that the assessment of these buildings is more accurate resulting in reliable energy efficiency measures that include work to existing building fabric as cited in BS 7913: 2013.
Evidence-based research is required and the STBA’s Green Wheel Retrofit guidance tool and knowledge centre provides the first step in the application of risk management towards energy efficiency retrofit.
There is increasing concern over solid walls and cavity walls. In a response from the Wales Low/Zero Carbon Hub (WLZCH) to the National Assembly for Wales Environment and Sustainability Committee EEFP 21 Inquiry into Energy Efficiency and Fuel Poverty:: “3.5 ……….. Early improvement measures set in place by the UK Government such as the Energy Commitment initiatives have provided improvements, but reported issues have become more widespread as measures introduced in these schemes were not always undertaken with the correct level of assessment or expertise. There are growing instances of cavity walls in Wales being insulated that if assessed using the British Standard should never have been undertaken due to the level of severe exposure in the west of the UK. The issue of solid wall insulation, if not considered correctly has the potential to replicate these problems and issues. There are problems with the solid wall insulation industry, for example there is no national standard for assessment, surveying or installation. The cumulative effect of these short comings can result in properties which are of a construction type where only certain measures are applicable, or are not in a suitable state of repair or water tightness being selected for external wall insulation without due consideration. This can often be attributed to a lack of impartial and easy to understand guidance and the tools necessary to ascertain potential risk. “
We have recommended that the UK Government in the first place considers its own building regulations and the new British Standard BS 7913: 2013 for authoritative guidance and also look at the evidence behind real concerns about risks many of which have been highlighted above. In addition that the UK Government provide a greater focus on the energy efficiency attributes of good repair and maintenance as sustainable means of energy efficiency as cited in BS 7913: 2013, rather than the single track message of ‘measures’. The ‘measures’ should come second.
We have asked the UK Government to note that the continued use of unreliable methods of assessing energy performance will in this instance result in works which carry risk of causing dampness, underachieving on the predicted energy savings and potentially put at risk the health of home occupiers.