Comments and feedback would be appreciated by 28th April via the Forum.
BEFS Draft Response
Built Environment Forum Scotland (BEFS) is an umbrella body for organisations working in the built environment in Scotland. Drawing on extensive expertise in a membership-led forum, BEFS informs, debates and advocates on the strategic issues, opportunities and challenges facing Scotland’s historic and contemporary built environment. BEFS is a member of the Climate Heritage Network steering group.
BEFS sat on the Short Life Working Group on Assessment in relation to Energy Performance Certificates.
BEFS strongly supports the primary focus around retrofit. Our most sustainable, and climate positive buildings are the ones already in existence.
BEFS is aware that the document heavily relies upon (PAS) 2035/30 including: assessment of dwellings for retrofit, identification and evaluation of improvement options. Does this PAS provide the necessary specifications for traditional built/heritage assets?
BEFS strongly supports SLQA group recommendation 5.
Recommendation 5. A new designer role should be considered to ensure that a whole building approach is taken and that only the most appropriate improvements are applied in practice.
Within the skills matrix BEFS notes the consistent use and mandatory nature of SQA Level 3 Award in Energy Efficiency Measures for Older and Traditional Buildings for all work carried out on Pre1919 buildings. Is this enough, is this accurate?
BEFS finds it of note that neither the Skills Investment Plan for Construction, nor for Scotland’s Historic Environment Sector are mentioned within the document. These are integral to meeting the skills needs for all of our built environment and have already been invested in to explore where skills gaps, and shortages, already exist. Without integration of these shortages and skills gaps, and their considered assessment of future need – the outcome will be a disjointed and patchy skills pipeline that serves neither the jobs market, nor our built environment, whilst simultaneously failing to meet climate targets.
Q1a – Do you agree with our proposal to integrate the installer skills matrix into the Publicly Available Specification (PAS) 2030 and Microgeneration Certification Scheme (MCS) installer standards? These appear to be positive and sensible steps. BEFS will integrate any responses to the above questions in relation to the PAS and the SQA3 Award for work on pre1919 buildings.
Q1b Do you agree with our recommendation that manufacturer training should be in addition to, not instead of, these skills requirements? It is essential for consumer confidence that training from manufacturers is additional, not instead of, initial requirements.
Q2 – What are your views on the timing for integrating the installer skills matrix into the PAS 2030 and MCS installer standards? What do you think would be a reasonable timescale for the making the skills matrix mandatory in the standards? No intention to answer.
Q3 – What are your views on how installers can meet these skills requirements, in particular the Recognised Prior Learning (RPL) route? No intention to answer.
Q4 – What are your views on the competency requirements for the retrofit coordinator, advisor, assessor, designer and evaluator roles?
It appears from this document (p12) that the Co-ordinator can be the Assessor, Designer and Evaluator. 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?
BEFS would want assurance that Whole Dwelling Assessment should 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.
Is any assessment or advice planned in relation to use and/or occupant behaviour?
BEFS has serious concerns over Advice giving, as this appears to be the least well-regulated step in the chain. This could lead to a poor outcomes for clients as initial advice v. 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.
Q5 – What are your views on our plans for developing heat network skills? For example are there any gaps in heat network skills that we haven’t identified? No Intention to answer.
Q6a – What impact do you think our skills requirements will have on the energy efficiency, microgeneration and heat networks sector in remote rural and island communities? No intention to answer.
Q6b – What impact do you think our skills requirements will have on the energy efficiency, microgeneration and heat networks sector in Scotland more generally? From a non-technical perspective, any regulations which organisations know they will need to meet, enables skills providers and organisations to plan for the future. Enabling them to put steps in place to attract, train, and deliver the skills required. Without these requirements providers and individuals cannot take steps along appropriate career pathways. A lack of requirement is a blockage in the skills pipeline.
Q7 – What impact do you think our skills requirements will have on competition including training provision, quality, availability or price of any goods or services in a market? No intention to answer
Q8 – What suggestions do you have for how digital technology could be used effectively to meet our skills requirements? No intention to answer
Q9 – Are there any areas of skills we have not covered in this consultation that you think we should consider? There are three areas where BEFS sees additional considerations to be necessary:
- Without data as to the current maintenance, ownership, and existing interventions on the buildings of Scotland, as well as their age and material construction it will be increasingly difficult to plan for skills and materials need across the nation; taking into account regional variations and overlapping this with data in relation to warm homes and fuel poverty enabling most urgent need to be met; and climate targets to be efficiently tackled.
- BEFS would draw attention to the comments we have previously made in relation to EPCs and their lack of ability as currently used to accurately assess many traditionally built dwellings. If we are not starting from an accurate base, the interventions invested in may fail to deliver on economic and ecological targets, as well as potentially being detrimental to occupant health and comfort.
- Roofing is mentioned within the skills matrix from an insulation perspective but the wide range of necessary skills to repair, maintain and intervene on rooves of all kinds is not fully expressed within this document. Seeking opinion from BEFS Members and Associates.
Q10 – What support you think would help the sector achieve these skills requirements? No intention to answer.