Elmhurst submits response to draft PAS 2038 for the Retrofit of Non-Domestic Buildings

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).

Response to BSI

BSI has asked Elmhurst to solicit comments and views from Elmhurst members and collate them into one single submission. Elmhurst has submitted its response to BSI after seeking input and comment from members. We would like to thank all members that took time out of their busy schedules to contribute towards our survey and encourage anyone who hasn’t done so already to submit their responses by the deadline.

It’s great to see an advancement and focus on non-domestic buildings within PAS 2038 and Elmhurst totally supports the aims of this new specification. However, an opportunity has been lost to implement the measurement of crucial energy efficiency of buildings through the national approved and regulated methodologies of Simplified Building Energy Models (SBEM) and Display Energy Certificates (DEC). Elmhurst feel that Non-Domestic Energy Assessors (NDEAs) should have the opportunity to be part of the retrofit project team and use their well-established accreditation, quality assurance, insurance, knowledge, expertise and competency in the energy assessment industry. There is a common goal to be achieved and we feel the strong capabilities and nationally approved methodologies already present in the industry have been omitted in the draft PAS 2038: Retrofitting non-domestic buildings for improved energy efficiency specification. The draft PAS 2038 seems to be “re-inventing the wheel” when there is already a major energy assessment industry ready to deliver the requirements of the PAS 2038 specification.

We have summarised three key points below:

  1. To acknowledge and include the role of existing accredited Non-Domestic Energy Assessors and DEC assessors, suitably upskilled to meet the extended requirements of PAS 2038
  2. To encourage the use of SBEM, the Government’s approved National Calculation Methodology (NCM), which is currently used for assessing the energy efficiency of non-domestic buildings.
  3. To encourage the use of DECs – the Government’s approved methodology for undertaking occupancy assessments and should be used instead of CIBSE TM54.

You can read Elmhurst’s and our members' response. 

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.”


Article published 26th October 2020

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