The Government has published a consultation on Energy Company Obligation schemes: Standard Assessment Procedure (SAP) and Reduced Data SAP (RdSAP) amendments. The consultation, in short, proposes that both ECO4 and the Great British Insulation Scheme (GBIS) use the latest versions of the SAP and RdSAP methodology, and covers both schemes for the period of Spring 2024 to March 2026.

SAP Update:

The most recent version of SAP, SAP 10.2, came into force last year and incorporated various changes to the methodology. The updated version has not created issues with the previous version, SAP 2012, which is currently required for ECO4 evidencing. At present, arrangements are in place which enable SAP 2012 to continue to be used across the industry.

To align with the RdSAP changes set out below, the consultation proposes that where a full SAP assessment is used for evidencing in ECO4, legislation is updated to require SAP 10.2. This would include a six-month transition period from the date the updated legislation is introduced, expected in March 2024.

RdSAP Update:

The consultation considers three options for transitional arrangements to account for evidencing of ECO4 and GB Insulation Scheme retrofits where a starting SAP rating assessment occurs before RdSAP 10.2 goes live, but a finishing SAP rating assessment occurs afterwards. The three options are as follows:

Option 1: Flexible Evidencing

In option one, retrofits could be evidenced by either RdSAP 2012 or RdSAP 10.2 for a fixed period of time once RdSAP 10.2 is live. This will likely be a period of 3 months, during which both software versions can be used.

If a post-assessment for an ECO4 or GB Insulation Scheme project is not completed within the proposed window, then the pre assessment for the property would need to be converted into RdSAP 10.2 for evidencing.

This approach would require scheme providers, TrustMark and Ofgem to support multiple versions of RdSAP to be uploaded to their systems for a period.

Option 2: Pre-determined eligibility

In option two, retrofit assessments would need to be evidenced by RdSAP 10.2 once it goes live. However, this option would propose that industry be allowed to prove that, where an ECO4 or GB Insulation Scheme pre-assessment occurs prior to the version change, RdSAP 2012 pre-assessment could be used to prove the property has an eligible starting SAP band rating.

Scores for retrofits that straddle the version change would be evidenced using RdSAP 10.2; for ECO4 and the GB Insulation Scheme, this would require any RdSAP 2012 pre-assessments to be converted, as per industry practice, to RdSAP 10.2 after the version change.

This approach would require TrustMark and Ofgem to support multiple versions of RdSAP to be uploaded to their systems.

Option 3: Fixed evidencing

In option three, all retrofit assessments would need to be completed in RdSAP 2012 before the version changeover date and in RdSAP 10.2 after this date.

Any retrofits with a starting RdSAP assessment conducted before the date, and a finishing RdSAP assessment after it, would risk becoming ineligible due to an improved starting energy efficiency rating.

This approach would not require industry, Ofgem or TrustMark to manage multiple versions of RdSAP software.

Elmhurst Response

Elmhurst Energy welcomes the opportunity to respond to this consultation and appreciate that the change of methodology needs careful consideration for any and all applications of RdSAP/SAP.

We strongly feel that running two methodologies concurrently is problematic. It has never been done before for RdSAP and the potential disruption to the industry is something that would be difficult to justify to a relatively short period of time where this would apply. From a first review of the three options, Elmhurst Energy prefers option two; it is something we can commit to as the solution exists now and is also less of a risk to the rest of the industry that relies on RdSAP.

However, we will spend some time examining the consultation and the options, in further detail, and will supply a full response to members in due course.

This consultation closes at 11:59pm on 11th September 2023.

Should you wish to submit a response, please do so by 8th September.