Written evidence submitted by TrustMark (RFH0006)
Established in 2005 in conjunction with government, industry bodies and consumer protection groups, TrustMark is a not-for-profit organisation that operates within a master licence agreement issued by the Government’s Department for Business & Trade. As such we operate the only Government Endorsed Quality Scheme for work carried out in or around the home so that the public can find competent tradespeople they can trust.
TrustMark operates through a network of Scheme Providers and Registered Businesses to improve standards and deliver consumer confidence through compliance with high standards of technical competence, customer service and trading practices as set out in our Framework Operating Requirements. These requirements were developed in partnership with government, consumer protection groups and the sector following the Government commissioned Each Home Counts Review published in 2016[1].
We currently licence and audit 38 Scheme Providers with approximately 17,500 Registered Businesses covering 156 different service types. This includes everything from installers of green heating and insulation products to plumbers, electricians and builders to carpet cleaners, landscape gardeners and leadwork specialists.
TrustMark welcomes the Retrofitting Homes for Net Zero call for evidence from the Energy Security and Net Zero Committee and we are delighted to have the opportunity to contribute. As the committee may well already be aware, the Government’s retrofit schemes place requirements for TrustMark registration, and the lodgement of retrofit works into the TrustMark Data Warehouse for assurance, consumer protection, insights, and data sharing purposes.
Due to our registration, assurance and consumer protection functions within the funded retrofit schemes we engage across the breadth of participants and stakeholders. We would like to take the opportunity to reflect to the Committee the common themes that we believe apply here.
TrustMark engages the construction industry beyond just energy efficiency retrofit. We believe that the opportunity created through participation in government retrofit schemes is not widely understood as well as it might be, therefore the supply chain potential is not being fully realised.
Businesses that have not previously participated in government retrofit schemes can lack experience and understanding of the needs of the process requirements and entry points through procurement frameworks. Similarly, they may not be aware of the free support resources available to them such as the Government facilitated RISE service (Retrofit Information, Support and Expertise)[2] or independent consultant type services available, albeit the latter generally come at a price to a business.
Many property owners are not fully aware of the benefits of energy efficiency retrofitting such as energy and carbon saving, health and comfort improvement opportunities. Some may not trust the information available to them based on the complexity of the advice landscape with much being commercially driven or inaccurate. This lack of awareness and trust can lead to low demand for retrofit.
We believe that the path of ‘least resistance’ isn’t widely understood and ‘exploited’. General home improvements such as the replacement of kitchens and bathrooms, rewiring and remodelling etc is within a continual cycle within the nation’s housing stock of all tenures. Were there to be a greater understanding by property owners of the opportunity to blend general home improvement work with true energy efficiency retrofit (particularly in the owner-occupier market), there could be better take up of funded measures. Works could be completed taking best advantage of a period of upheaval and maximise the efficiency of some elements like the use of scaffold, waste disposal arrangements and remediation trades such as plastering and decorative works.
Perhaps the most recognised retrofit standard is PAS 2035[3], as created and maintained by the British Standards Institute, as sponsored by the Department for Energy Security and Net Zero (DESNZ).
Government retrofit schemes call for a standardised level of installer competence and installation process including those required under the Microgeneration Certification Scheme (MCS), PAS 2030 (Specification for the installation of energy efficiency measures in existing dwellings) and compliance to the PAS 2035 process (Retrofitting dwellings for improved energy efficiency – specification and guidance).
A coherent approach and oversight of delivery standards is essential given the complexity of many retrofits in order that quality installation outputs result. During our engagement with the sector, we have experience that businesses can see the requirements as complex, costly and time consuming to achieve and can be unwilling to take on additional certification and process requirements beyond those mandated by Building Regulations alone.
The currently live DESNZ consultation on mid scheme changes to the Energy Company Obligation and Great British Insulation Scheme[4] includes a proposal to introduce an ‘alternative standard’ to PAS 2035 to bring a more compliance cost proportionate delivery of certain simple measures in low-risk contexts. Depending on the consultation outcome, the alternative standard known as TrustMark Licence Plus for the Great British Insulation Scheme will fulfil the more proportionate compliance cost delivery yet maintain a consistent standard of delivery and assurance. We believe that initiatives of this type appropriately applied, could help support bringing down delivery process costs of some energy efficiency measures delivered under the Government retrofit schemes, support greater delivery and still maintain quality and consumer protection.
If a methodology of allowing the existing approaches to recognising trades competency, such as the Government approved Competent Persons Schemes and reliable competency and standards outputs focused Trade Bodies were permitted to feed competent people/organisations in to an overarching retrofit process this could help reduce the barriers that certification is viewed by some to create.
Therefore, we believe that by ensuring businesses deliver within an agreed set of standards with a quality assurance and consumer protection oversight programme, the UK can go a long way to achieving its energy efficiency and low carbon objectives under the funded retrofit schemes.
Notwithstanding our observations within in the previous section, the retrofit supply chain is slowly growing in terms of installer capacity and those supporting them e.g. Retrofit Assessors and Retrofit Coordinators etc. While there is an overall skills gap in the market, we believe the existing workforce and competency mechanisms, including the wider construction sector with multiple layers of transferable skills, can scale to deliver the government’s ambition but will need proportionate and consistent oversight. This could be accelerated where knowledge of the opportunity to participate in the funded retrofit schemes were developed.
Some businesses report hesitancy to invest in new certifications and working methods due to the fixed duration of schemes (or phases), without clearer view of long-term opportunities through successor schemes. That said, within the TrustMark assurance and consumer protection framework and in context of the PAS 2035 defined roles we currently have c. 3,500 Retrofit Assessors, c. 900 Retrofit Coordinators and c. 900 Retrofit Installer businesses. This equates to 100% of those participating under the Government funded retrofit schemes and the Energy Company Obligation.
Specifically, in the area of low carbon/renewable technologies we have c. 2,180 installer businesses registered with TrustMark.
From a wider employment perspective, whilst precise numbers are complex to provide, we understand these businesses either employ or subcontract a range of micro, small and medium sized businesses collectively utilizing in excess of 50,000 trades people to deliver retrofit activity.
The upfront costs of low carbon and renewable technologies are a barrier to mass uptake. The Boiler Upgrade Scheme (BUS), providing up to £7500 upfront grant to help property owners replace fossil fuel heating is clearly a very welcome and valuable funding initiative.
The public require smart financial mechanisms including where the savings help offset the costs to decarbonise or are affordable in other inviting ways. The average cost associated with decarbonising heating, taking account of the need to improve the insulation in many buildings, is still high for many people and properties, even taking into account the grant funding that is available. Therefore, the acceleration of green mortgages and green finance and perhaps linked to the building rather than the person making the initial investment (due to time to realise payback periods against ownership duration) will be important to stimulate the private homeowner market.
TrustMark continues to engage the finance and lending sector in terms of our risk mitigation function with their needs for quality assurance and validation of works funded by private consumer finance. We see supporting mitigating risk for lenders as a key part of them bringing more offers to the market.
Raising awareness about tangible cost savings and the other benefits associated with decarbonised heating can help prompt more people to make the switch. Sharing information on financial support mechanisms can also help.
Providing tax credits or deductions for installing energy-efficient heating systems along with VAT savings, Stamp Duty allowances, can lower the financial impact on homeowners to help incentivise both low carbon and building fabric retrofit.
Consumer protection and assurance methodologies such as those already delivered by TrustMark as a readymade government endorsed solution, is already a key function in helping ensure consumers are mitigated against poor standards of delivery and/or subsequent detriment that drive additional costs, some of which can be considerable in the event of low carbon and building fabric measure installation failures. Consumers should not have to pay twice.
Energy Performance Certificates (EPC) delivered via the current framework do have a value in giving consumers support in high level decision making. It is important that an EPC is considered in context of its intended purpose, including the limitations and assumptions made within the process of creating an EPC.
However, a simple approach to EPC recommendations in isolation without taking into account consumer objectives, advice, evaluation, consideration of those improvements that are actually suitable for a specific building can lead to a number of decision risks not being mitigated. These risks being primarily associated with building exposure, topography, building condition and type, ventilation arrangements and any improvements not being made under a sequenced approach which can in certain situations lead to the potential failure of measures, the selection of inappropriate measures and them being installed in an inappropriate way, or combination.
An EPC does not make recommendations for any remedial works in relation to structural condition or any damp or water ingress issues that would need remediation prior to the commencement of a retrofit project. These type of issues have significant potential to negatively impact on the effectiveness of a retrofit project or create occupant health issues later on.
Certain types of existing building defects and conditions, if not remediated or taken account of, can be exacerbated by retrofitting a building and lead to costly remediation. Examples include, accelerated timber or fabric decay, condensation and mould growth. The latter can lead to serious health implications.
Whilst it is a defined requirement of the Building Regulations existing ventilation or upgrades must be suitable for the retrofit improvements applied in existing dwellings and in context of the property they are made in. This is a critical area when retrofitting buildings and affecting air tightness as the indoor air quality can be negatively impacted upon which, can cause health issues. An EPC alone, does not address the critical element of retrofitting.
As above there is currently an inconsistency offered by the outputs of an EPC and that driven by a whole house approach Retrofit Assessment, appreciating of course they are intended for differing purposes. A whole house process requires building assessment, evaluation of the improvement possibilities and then a design for meeting the improvement project objectives.
An EPC does not include (and was not created to include) all the elements required to drive fully informed decision making which requires the inclusion of other factors such as:
We believe that multiple entry points to skills attainment are required to take account of previous experience, skills and competence.
‘Attract and retain’ should be themes of equipping the workforce. This can be done through highlighting the importance of retrofitting for achieving net-zero targets and promoting the career opportunities in this field that can attract new capacity. Creating purpose and showcasing the role of retrofitting buildings for a sustainable future with a defined career path can inspire more people to join the sector and build careers.
Providing opportunities for the existing workforce to take their transferable skills or gain new skills through short courses and certifications can help meet the demand for skilled specialists.
Training and qualifications are key elements of developing skills. In our experience of assurance oversight of the deliveries it is critical that these elements are taken forward in a way that individuals have the confidence to take their knowledge built from training/qualifications into full industry competent practice. Commonly, the apprenticeship route can deliver this. This approach can also allow the delivery of supervised works that support employers revenue/return on investment from an early stage, whilst practical and technical competence is being built by the individual new to the sector.
For the sake of efficiency and given the breadth of skills required in all the specialist areas it is important that any national skills programme is delivered in such a way that duplication is minimised and that modular deliveries have minimal overlap. For example, where a health and safety module is required it should not be repeated again within technical modules.
Equally important but from a converse viewpoint, through any skills provision and as we embrace the whole house approach it is significant that skills development of single trades has recognition of the interactions with other trades. Traditional trades usually work well together and hand off to each other neatly as they are logically sequenced and are well-practiced. For retrofit trades there are critical interactions and interfaces with each other which need to be recognised and respected so that the risks of unintended consequences to buildings and occupants are minimised.
Achieving skills and competence is just one significant part of the requirement of delivering quality work. As earlier mentioned in our submission, there are numerous routes to obtaining skills and competent deliveries i.e. PAS/MCS certification, Competent Persons Schemes etc.
We have experience of where the systems of communication could be improved to reduce yet further the space that exists where those who are not applying their competence appropriately can move around in a type of ‘no man’s land’ thus potentially avoiding responsibility and accountability for poor actions.
The TrustMark delivered Data Warehouse is a repository where work under the Government funded retrofit schemes and the Energy Company Obligation is lodged and utilized for quality monitoring processes. We use the lodged data to drive our risk-based assurance function to determine the level of in-practice quality being delivered at business level. We are able to apply remediation, escalation and sanctions as processes as necessary.
As part of our appointment to operate the ‘quality mark’ as a major output recommendation of the Each Home Counts review, we are able to effectively share data with the appropriate organizations so that ‘bad actors’ can be tracked to ensure any appropriate improvements are made or that they can be isolated from the sector if deemed appropriate.
Given the emergence of multiple standards within the retrofit sector we have adapted, and can further adapt, our assurance processes to monitor compliant deliveries under multiple standards.
Home heating transition coordination is not one of TrustMark’s key areas of expertise. Nonetheless we have been invited by a number of ‘think tanks’ to be part of the on-going conversation and believe we have a significant role to play in supporting those that will be coordinating the transition both at local and national levels.
TrustMark holds a wealth of national information in our Data Warehouse, and it is primarily driven through the data lodgement requirement incorporated into the Government’s capital funded schemes and the Energy Company obligation. In the last three years, businesses registered with TrustMark for the improvement of energy efficiency within the home have carried out over 750,000 energy efficiency home improvements across the UK.
This ever-growing pool of data has the potential to be utilised and expanded to produce insights into the retrofit work that has been carried out both nationally and at more local level. It determines trends, risks and saturation and could be integrated for further benefit of coordination and tracking the progress toward the net zero transition.
November 2024
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[1] https://assets.publishing.service.gov.uk/media/5a7f1384e5274a2e8ab49f6b/Each_Home_Counts__December_2016_.pdf
[2] https://riseretrofit.org.uk/
[3] https://knowledge.bsigroup.com/products/retrofitting-dwellings-for-improved-energy-efficiency-specification-and-guidance-2?version=standard
[4] https://www.gov.uk/government/consultations/energy-company-obligation-4-and-the-great-british-insulation-scheme-mid-scheme-changes