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ID sylw: 108324

Derbyniwyd: 07/03/2025

Ymatebydd: George Martin

As with other net zero policies for buildings in the consultation, it is not specific enough and has no teeth. 

I am pleased to see reference to LETI and Passivhaus, but the policy misses the AECB CarbonLite Retrofit Standard which is better for traditional buildings and also takes into account many more retrofit risks.  The STBA Guidance Wheel provides the opportunity to research the interactions between different options of retrofit. 

As an alternative to AECB CarbonLite Standard or Passivhaus (EnerPHit) then PAS 2035 (for domestic buildings) & Trustmark should be required as it has consumer protection and QA embedded in it.  

The various emerging documents and standards from the National Retrofit Hub should also be included.

For non domestic buildings, PAS 2038 should be used but need to check if this has consumer protection. For commercial Properties the BBP Low carbon Retrofit tool.

The policy needs to set out clearly when each standard should be required. If left to the applicant it will just not happen.

The policy appears to rely heavily on EPCs for domestic buildings.  By comparison with DECs (for non-domestic buildings) EPCs are generally considered as unfit for purpose.  The authors of this policy should look at the following two references:

• Letter from Lord Deben chair, Committee on Climate Change to Lee Rowley MP parliamentary Under Secretary of State dated 2nd February 2023 - Reform of domestic EPC rating metrics to support of Net Zero
• National Retrofit Hub response to the ‘Reforms to the Energy Performance of Buildings regime’ consultation 2024-2025 - February 2025.

It is agreed by the committee on Climate Change that the current EPC is unfit for purpose. Work is underway to change this. EPC C is not going to deliver net zero. The authors should check what other targets are proposed between 2030 and 2050.

As the South Warwickshire Joint Climate Action Programme (October 2021) Is 4 years old it should be reviewed.

The STBA approach is important for listed buildings and properties in Conservation Areas.