PAS 2038 for the retrofit of Non-Domestic Buildings – Have your say!

Many of you will know about PAS 2035, the domestic retrofit specification that was published by BSI including direct from input from Elmhurst. It outlines the functions of Retrofit Assessors, Retrofit Coordinators and the need for a retrofit plan for all dwellings that are being considered for energy efficiency improvement. The PAS has now been adopted for the Energy Companies Obligation (ECO) policy and Government intend making it a requirement for all future initiatives, including elements of the Green Homes Grant. As a result, hundreds of domestic Retrofit Assessors and Retrofit Coordinators have now been trained.

The obvious next step was for BSI to consider commercial buildings and we have now received the first draft of PAS 2038, “Retrofitting non-domestic buildings for improved energy efficiency – Specification”. For those that don’t know a PAS (Publicly Available Specification) is a sponsored, fast-track, consensus-building informal standard that is produced by the UK national standards body, BSI Standards Limited. PAS 2038 has been sponsored by the Department for Business, Energy & Industrial Strategy (BEIS).

The draft was issued on 28th September and comments close on 26th October 2020 so we all need to act fast.

BSI has asked Elmhurst to solicit comments and views from Elmhurst members and collate them into one single submission. Elmhurst has drafted its response to BSI and is now seeking input and comment from members. To assist in this process we have created a simply survey. Please click here to have your say on the PAS2038 specification.

A summary of our message to BSI:

1.    Not utilising the asset rating of a building. The 3 key factors of buildings are the asset, occupancy and metering to provide the whole building measurement. If you cannot measure these three items however can you make any real decisions on improving the building.

2.    No reference to the regulated, quality assured, Government approved national calculation methodology (NCM) for non-domestic buildings that current underpins government regulations and legislation such as Energy Performance Certificates, Minimum Energy Efficiency Standards, Part L2 building regulations and Display Energy Certificates to name a few.

3.    The lack of reference to the 1,500 or so non-domestic energy assessors that have the knowledge, expertise and competency to assess non-domestic buildings for context and energy performance in the energy assessment industry.

Elmhurst’s Managing Director Martyn Reed comments “PAS 2038 could be a very important standard for the non-domestic sector, especially if government adopt it as a prerequisite for grant support. The deep retrofit approach of assessing the needs of the building and the occupant are equally applicable to commercial buildings as they are domestic. With the move to zero carbon the demand should be high. The country will need competent assessors who have knowledge, skills, experience and tools to undertake such and, crucially, links with those building owners. Elmhurst will be fighting to ensure that the skills of Elmhurst members are recognised and that the industry builds upon what it has already delivered, rather than reinventing the wheel.”


Click here to see Elmhurst’s draft PAS 2038 Retrofitting Non-Domestic Buildings for Improved Energy Efficiency Response.

Click here to see BSI’s public announcement of the draft specification.


Article published 9th October

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