Knauf Insulation EEH0076

Written evidence submitted by Knauf Insulation


Knauf Insulation is the largest UK supplier of insulation into the New Build housing sector and part of the wider €11bn Knauf Group.  

We have limited our response to the two questions we believe are crucial to unlocking a good outcome in terms of achieving net zero in the UK’s housing stock.

How effective is the EPC rating at measuring energy efficiency? Are there any alternative methodologies that could be used?



“Developers do not have to…test the properties ‘as built’ performance. The house purchaser has no way of knowing…whether the property operates to that energy efficiency standard in reality.”

Energy Efficiency Inquiry Report 2019, BEIS Select Committee

“None of the [Future Homes Standard] proposals will be effective unless ….by the time the Future Homes Standard is introduced, it can be done on an ‘in-use’ energy performance basis.”

Committee on Climate Change, Letter to Rt. Hon. Robert Jenrick MP, Feb 2020









If we want energy efficiency homes, why subsidise insulation and not its impact when installed?














“From day one, Knauf brought a level of quality control we haven’t previously experienced in other retrofit projects. They set out a clear list of steps that needed to be taken to prepare the homes for retrofit, supported the quality control of those works while also designing and overseeing the insulation install works.

The measurement service is the first time we have been offered any certainty that our homes have actually been improved.”


Asset owner in our UK retrofit case study







UK Case Studies


Overview of the Manchester project


The following results were established using Knauf Energy Solutions’ measurement technology which establishes the real performance of each home;



Overview of the Salford project



What additional policy interventions are needed for social housing, leaseholders, landlords and tenants?




How to procure verified performance?




The services to be delivered by the contractor must at least cover the following:

1. Prior monitoring and reporting to the Contracting Authority

The preliminary monitoring presupposes the installation of measuring equipment with energy-related sensors that measure the energy level in the social housing concerned. At least the following energetic parameters will be measured (non-exhaustive list): e.g. temperature, CO2, humidity, gas and / or energy consumption, heating system performance and movement.

In view of the preliminary monitoring to be carried out, it is important that the measuring equipment can be placed in the home in a modest manner, so that its use does not hinder the residents. Thus, the pre-measurement during the reference period leads to representative results on energy consumption and energy efficiency.

The prior monitoring results in a report to the Contracting Authority with insight into the energy consumption and energy efficiency of the social housing


2. Propose solutions and alternatives

Social housing must be treated until they reach (at least) E-level 40. This is the maximum permitted E-level for a new-build home in Flanders today. [the E level is Belgium’s equivalent of SAP which underpins the EPC]

On the basis of an investigation of a specific social home, and the results of the prior monitoring of the same home, the contractor determines which energy savings are necessary in order to achieve the E-level E40 and by means of which interventions this is feasible and in accordance with the measures included in the chart of measurement in appendix 4. It also shows the alternatives in this respect. The Contracting Authority then chooses which measures it wishes to see realized. In this respect, the Contracting Authority undertakes to opt for measures that make the target of E level E40 feasible.



Energy-saving measures means: all measures with a view to reducing energy consumption. The energy-saving measures can consist of works, as well as services, as well as installation of installations and supplies. The contractor is responsible for everything, from the detailed study to the actual implementation.

If it is possible to achieve a better E-level than E40 and the Contracting Authority opts for this, this better E-level must be guaranteed.

More details can be found in the technical provisions (see Title 7 “Technical provisions” accompanying these specifications).]


3. After-monitoring and reporting of energy performance

After the energetic renovation and installation work has been completed, the same equipment as during the previous monitoring is placed in the social housing concerned. The purpose of these post-measurements is to determine to what extent the work carried out leads to an improvement in energy efficiency and energy savings and / or whether the desired E40 level (or better if so agreed) has been reached and the contractor’s result guarantee is satisfactory.

The assignment is all-in. The contractor is responsible for the study and monitoring of social housing, designing, installing, renovating, organizing, managing and ensuring high quality energy efficiency and energy saving works (including installation of installations) for each of the participating social housing units (and apartments), including preparatory and post-intervention work. This also includes obtaining the necessary permits (if necessary), safety coordination (if necessary), etc. The contractor takes account of this “all-in” in its pricing.




Knauf Energy Solutions’ submission to the EU Renovation Wave proposals

The EU’s Renovation Wave proposals come at a time when the digital revolution can help make it a reality, allowing buildings to be transformed from climate villains at the edge of our energy system to climate champions that play an active role in supporting a secure and stable energy system. New digital approaches allow governments, finance providers, owners and tenants to finally know that the promised energy and carbon savings they invested in have been delivered. The same technologies, coupled with low energy buildings, create active homes that can support the grid through services such as peak load shifting. The EU Renovation Wave must ensure that high quality digitally enabled renovations can flourish.


The final quality of an energy efficiency measure is often invisible to the customer, meaning the market struggles to reward quality. This then drives a market dynamic where sub-optimal work often outcompetes quality work, undermining the overall efforts to scale up energy efficiency renovation.  This dynamic is known as “The Market for Lemons” for which George Akerlof won the 2001 Nobel Prize. 


Digitally enabled renovation approaches, that provide highly accurate information on the actual energy efficiency savings delivered, can upend this dynamic. To deliver a major win, the EU Renovation Wave must be structured to ensure “The Market for Quality” displaces the one for lemons, whilst supporting a rapid scale up. Certain key policy elements can make this happen:


1.       Create a Market for Performance, Not Measures: the financing and grant measures of the Renovation Wave should be based on the energy efficiency performance improvements made to buildings, not the tick-box list of measures installed.


2.       Incentivize Performance: the digitalization of the economy makes it inevitable that real performance approaches will supplant the current modelled approaches (e.g. EPCs) as they provide a higher level of accuracy and accountability. Whilst for the renovation of single-family homes these real performance approaches are just getting started, they already have a significant role in larger buildings (e.g. schools and hospitals). EU funding should accelerate this transition by ensuring that real performance approaches get paid a “Quality Premium” in terms of grant finance and loan conditions and by trialing innovative policy approaches, such as feed-out-tariffs and power saving agreements where governments can choose to invest in 400,000 low carbon renovated homes, creating Virtual Energy Infrastructure (defined as: “The metered energy savings removed from the energy system through the deployment of energy efficiency infrastructure”) rather than building a new carbon intensive power plant.


3.       Open up the Market: The current energy system dynamics and state aid rules are not designed for allowing low energy, digitally enabled homes to play their full role in supporting the energy system or for rewarding them for doing so. To allow service providers to be able to offer and monetize these services for homeowners, the energy system needs to be adapted as do state aid rules to ensure that the huge societal benefits that energy efficiency renovation can provide are realized.


Finally More for Less: Supporting digitally enabled renovations can deliver a Renovation Wave that not only scales but is focused on delivering more energy efficiency at a lower cost. It will create a market that rewards performance and incentivizes market actors to drive up quality and drive down costs.

July 2020


[1] "The Market for Lemons: Quality Uncertainty and the Market Mechanism" George Akerlof 1970



[4] Findings of the Independent Review”, Stephanie Barwise QC, 2019