The IHBC has submitted responses to a suite of consultations important to the care of traditionally built homes, including on the Energy Company Obligation ECO4 and PAS 2035.
The IHBC writes:
The IHBC has submitted its responses on the Energy Company Obligation ECO4: 2022 -2026 and to PAS 2035:2019+A1:2021 PAS 2035:2019 + A1:2021 ‘Retrofitting dwellings for improved energy efficiency – Specification and guidance’.
… risks and unintended consequences of taking action should be analysed…
Responding to the ECO4 consultation the IHBC suggested that any proposals in ECO4 should give proper consideration to, and clear guidance for, the retrofit of traditionally built solid wall homes to ensure appropriate vapour permeable solutions are to prevent potentially disastrous results.
The IHBC writes: ‘The current SAP assessment method is to be replaced by a new revised SAP (Version 10) and will be more onerous and require higher levels of thermal improvement to achieve targets. Many homes will not be able to achieve this and the risks and unintended consequences of taking action should be analysed. An arbitrary requirement to increase SAP levels cannot be applied safely to many types of building. Applying internal insulation can lead in buildings of traditional construction to problems such as condensation and overheating. The private sector rental regulations already make provision for the exclusion of wall insulation and provision for an expert to assess whether buildings are suitable for wall insulation. This approach should be adopted in ECO4 to ensure that insulation is installed only when it is safe to do so and to bring consistency to regulation.’
Responding to the PAS 2035:2019+A1 consultation the IHBC suggested that although PAS may be aimed at being publicly accessible the cost makes them prohibitive for the public and it is unlikely to be effective unless it can be made more accessible and reasonably priced.
… An arbitrary requirement to increase SAP levels cannot be applied safely to many types of building…
The IHBC writes on the PAS: ‘The major difference between traditionally constructed buildings and modern buildings needs to be understood as they require different treatment. Modern solutions for traditional buildings can result in detrimental unintended consequences. The proposals only require additional training in older buildings as the performance of the building will be the same and the training needed the same’
The IHBC’s Consultations Panel
The IHBC constantly monitors Government Departments and other national and regional organisations for relevant proposed changes to legislation, policy and guidance. The Consultations Panel formulates responses to these documents on behalf of the IHBC.
The IHBC may not comment on all these consultations, but we are glad to hear opinions on them from both members and non-members