Summary of Ofgem ECO 1.2 consultation workshopMinimum insulation levels for primary measures and building regulations

28 August 2014

Amending Order (ECO1.2)• CERO target reduction• Changes to CSCO areas• New CERO primary measures• Early CERO delivery uplift• Optimum carry forward of excess actions• Interim provision

Changes up to March 31 2015 First obligation period (OP1) Laid 22 July 2014 Coming into force ~ Nov 2014 Applying from 1 April 2014

Proposed legislative changes in ECO 1.2 – based on the legislation laid by DECC

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Key areas of our consultation• ECO 1.2 changes:

• New CERO primary measures: minimum insulation level to support a secondary measure

• Connections to a district heating system: pre-conditions under CERO and CSCO

• In addition we are also consulting on the following issues unrelated to the ECO 1.2 changes:• Compliance with building regulations: installation of a measure• General comments on our guidance (version 1.2)

ECO 1.2 consultation timeline

Key dates Activity

22 July DECC laid amending Order

11 August Ofgem launch consultation

22 September Ofgem close consultation

Late October Ofgem publish response to consultation and final guidance

Early November Amending Order comes into force

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• The amending Order introduces new CERO primary measures:– Insulation of a cavity wall – Flat-roof insulation – Loft insulation – Rafter insulation – Room-in-roof insulation – Connection to a district heating system (DHS)

in addition to the existing primary measure of solid wall insulation (SWI)

• From 1 April 2014 HTTCs will be included within 'insulation of a cavity wall'

CERO primary measures

“Roof-space insulation”

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• Under CERO, a secondary measure can only be installed if a primary measure is installed at the same premises

• Existing CERO primary measures must be installed to at least 50% of the total exterior-facing wall area to support a secondary measure

• We are proposing to apply the same rule to the new CERO primary measures

Supporting secondary measures

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• Insulation of a cavity wall – at least 50% of the total exterior-facing wall area of the premises must be insulated

• Roof-space insulation – at least 50% of the total roof-space area of the premises must be insulated

• Loft insulation, as outlined in legislation, must also:– be installed to lofts with no more than 150mm insulation in place

before installation, and– be installed to a depth of at least 250mm after insulation.

Proposed minimum insulation levels

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• “Roof-space area” means:– for loft insulation, the area of the floor of the loft – for rafter insulation, the area of the rafters – for flat roof insulation, the area of the roof – for room-in-roof, the area of the room-in-roof including the common walls,

gable walls and ceiling – for properties with more than one roof type, and/or more than one type of

roof-space insulation installed, the sum of the areas as explained above.

Defining “roof-space area”

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Question for break-out sessions• Do you agree that insulation of a cavity wall and roof-space

insulation must be installed to at least 50% of the total exterior-facing wall area or total roof space area of the premises in order to support a secondary measure?

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• Current evidence requirements only cover demonstration of compliance of product or system used in the installation with building regulations

• Anecdotal evidence suggest poor quality installations, installers not informing appropriate bodies about the installation etc.

• The consultation proposes that suppliers provide evidence that installation also complies with building regulations

Compliance with building regulations

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• Proposed forms of evidence:– An approval certificate by a building control body– An approval certificate by Approved Inspectors – A building regulations compliance certificate issued by a competent

person scheme

• These would all demonstrate compliance of both the installation and product or system used

Evidencing compliance

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• We recognise that this is a late addition• However some parties may already be collecting this evidence • Further assurance of high standards may work in everyone’s

favour to introduce this change now• We would like to hear stakeholders’ views about when this

requirement should be introduced

Introducing this requirement

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Questions for break-out sessions• Do you agree with our proposal to require evidence that the

installation of a measure complies with Building Regulations? • If this requirement was introduced, how could compliance be

demonstrated? • Are you aware of any other means of evidencing compliance

with building regulations other than those mentioned?• Do you think we should introduce this requirement from the

date version 1.2 of the guidance takes effect or for the next ECO obligation period?

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Break-out sessions

• Groups of ~12– Conference room 3– Conference room 5– Conference room 6– Conference room 9 (this room)

• Reconvene at 14:45

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Common points from breakout groups• Broad acceptance of the proposed 50% minimum insulation level• Questions over whether changing building regulation requirements

would lead to improvements in quality, or whether improvements to certification schemes might address the problem better

• General consensus that Ofgem’s proposal is merely formalising what many suppliers do already, and is attempting to improve quality whilst causing minimal additional burden

• No-one could think of additional ways of evidencing compliance of both the installation and product or system used

• Agreement that ECO 2 is the best time to introduce the changes to requirements for building regulations to allow the supply chain time to adjust

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• Do we need to set a minimum insulation level at all • Discussion about how to measure 50% for walls and roof space e.g.

should openings be included• How to calculate rafter area (or any roof-space area) – method used

should be consistent across industry. Suggestion that RdSAP could be best for this

• Should the age or condition of pre-existing loft insulation be taken into account. An EPC being lodged could verify this

Additional points raised by participantsMinimum insulation level

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• Not all evidence options are available for all measures so Ofgem should make it clear which can be used for each measure

• Scotland may have different building regulations which we need to take into account

• Details of the Competent Persons Scheme were discussed, with views that this is the most cost effective way of evidencing

• Concerns that suppliers could end up policing certification bodies if they feel the controls aren’t stringent enough

• Will Ofgem accept an application for a certificate rather than waiting for it to come through?

• If quality does improve as a result, this could impact technical monitoring

Additional points raised by participantsBuilding regulations

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Next steps

• We will circulate the main points from this and our other workshop

• Written responses to our consultation should be submitted by 9am Monday 22 September

• We will publish a response and final guidance at the end of October