The Each Home Counts report and traditional buildings

John Preston argues that ‘Each Home Counts’, the report of the Bonfield Review, focused on the right questions but its total blindness to traditional buildings means that it is fundamentally flawed.

Government retrofit schemes started in 2000, with the Treasury-funded Warm Front scheme, focused on fuel poverty. Subsequent schemes, including the Green Deal and ECO (Energy Company Obligation), have been funded by bill payers of the Big Six energy companies, through the so-called ‘green taxes’. The current government has pledged to achieve a million ‘low-cost retrofits’ by 2020, funded through the next stages of ECO.

Many see this programme as far too unambitious in relation to 2050 Climate Change Act targets, with demands for retrofit to be made a national infrastructure priority [1]. But, as the Society for the Protection of Ancient Buildings (SPAB) has warned, a rush to retrofit could lead to severe defects in older buildings and health problems for their occupants [2]. ECO, unlike the Green Deal, has no safeguards for traditional buildings.

Following the withdrawal of Green Deal funding in July 2015, the DECC and DCLG ministers Amber Rudd and Greg Clark commissioned Peter Bonfield to lead an Independent Review of Consumer Advice, Protection, Standards and Enforcement for Energy Efficiency and Renewable Energy. The Each Home Counts report was published for consultation in December 2016. Its newsletters show how the review was racing to implementation without waiting for feedback.

This extreme haste, driven by political timescales, would have been worrying at the best of times. The government compounded the problem by devolving responsibility to industry, in effect to existing industry bodies plus independent bodies representing consumers. The ministerial foreword by Baroness Neville-Rolfe (now at the Treasury, for the Department for Business, Energy and Industrial Strategy) and Gavin Barwell MP (housing and planning minister, for the DCLG) welcomes the review ‘as offering a clear and tangible way forward, led by industry itself ’.

The ministerial foreword claims that the review ‘has been highly active in consulting a diverse range of stakeholders’. That statement was, and remains, dangerously wrong. The review was chaired by an industry insider (Bonfield is CEO of the Building Research Establishment), and its working and implementation groups were and are recruited from and led by industry insiders. While the review process forced the industry to confront consumer protection issues, there was no independent external review of the construction aspects.

The review was neither a formal government consultation nor an open call for evidence (unlike the Hansford Review [4] for the Green Construction Board). The process was so opaque that it was extremely difficult for even external bodies (including The Institute of Historic Building Conservation (IHBC)) aware of the review to engage with it. The National Trust was not invited, even though it had carried out highly relevant research on its 5,000 privately rented properties. Efforts to find out the membership of the working and implementation groups were stonewalled: this ‘independent’ review is outwith the government’s Code of Practice for Consultations.

The review’s work streams were made up of and chaired by invited industry representatives: consumer protection (chaired by Citizens Advice); advice and guidance (Energy Saving Trust); quality and standards (BSI), skills and training (Trustmark); compliance and enforcement (BBA), holistic property consideration (David Adams, ex-Willmott Dixon), insulation and fabric (Construction Products Association), smart meters (Telefonica), home energy technologies (BEAMA), and the social housing sector (Steve Cole, ex-National Housing Federation).

The high-level questions were good. ‘Who can the consumer trust? How can companies find the right certification? How can consumers be certain that those operating under the different schemes are credible and can be trusted to do their work where driven by incentives of regulation? How can we ensure that the many different measures being installed interact with the building and each other as they should?’

The review’s solution, now being implemented, is a Framework combining a new Quality Mark and three key elements: a Consumer Charter; a Code of Conduct for companies; and Codes of Practice relevant to the installation of each measure. Many detailed recommendations appear good at first sight: ‘a consistent and fair redress process’; ‘impartial information and guidance’ through a central information hub; an ‘overarching standards framework’; ‘embed core knowledge including basic building physics’; ‘an organisation to develop and oversee the quality mark’; a ‘robust and joined-up industry-wide compliance and enforcement regime’; and ‘an appropriate design stage which takes a holistic approach and adequately considers the home, its local environment, heritage, occupancy.’

So far, so good. But Each Home Counts is fundamentally flawed because it is totally blind to traditional buildings. The heritage sector argues that these form around 25 per cent of the building stock, but the BRE’s ‘Solid wall heat losses and the potential for energy saving: literature review’ [5], published on the DECC website in January 2015 (and inexplicably not referenced in Each Home Counts) suggests that ‘heritage buildings’ may form up to 35 per cent of dwellings. Yet for the last 50 years the construction industry has seen heritage buildings at best as a six per cent niche market, and its training has been on new construction. These industry failings, totally overlooked by Bonfield, are now compounded by a government seeking quick and simple deregulated solutions, and lacking the awareness and vision for a joined-up approach.

Government statistics suggest that 20 per cent of owner-occupied and 34 per cent of the privately rented stock is pre-1919, and among solid wall buildings in these tenures only 7.4 per cent and 5.1 per cent respectively have insulation. [6] At least 750,000 owner-occupied and a minimum of 650,000 privately rented, solid-wall buildings are uninsulated. Bafflingly, Each Home Counts fails to mention the Private Rented Sector Regulations (the only statutory requirement for retrofit), already in force for tenants’ requests, which come into full effect with compulsion on landlords from April 2018.

With at least 1.5 million (and arguably many more, allowing for post-1919 solid-wall buildings) traditional buildings needing a different approach, one-size-fits-all plainly will not work for the UK’s dwelling stock. The government itself said in November 2016, in its response to the House of Lords built environment select committee that ‘a variety of different but complementary measures is required’. So how come a report which was signed off in Number 10 a month later suggests a single Framework, Consumer Charter, Code of Conduct and Codes of Practice?

This is a very high-risk approach, compounded by Bonfield’s omission of the BRE’s 2015 solid wall literature review [3], and failure to give proper consideration to the risks it highlighted. While Bonfield has a section on compliance and enforcement, issues relating to failed energy-efficiency measures are glossed over. The report cites quality control through an OFGEM inspection regime, but fails to mention that this does not make the vital distinction between ‘vapour-open’ and ‘vapour-closed’ insulation.

A single reference to ‘redress in Preston’ is the only mention of failed solid-wall insulation). There is no mention of the BRE’s long-awaited, DECC-commissioned ‘in-depth study’, of which Colin King’s presentation to Ecobuild 20147 remains the only published evidence. The new CIGA (Cavity Insulation Guarantee Association (sic Agency)) customer-care regime is cited as an example of ‘redress’, but it is no more than a complaints procedure. There is no sign yet that risk, liability or carbon-cost issues are being taken on board adequately, either by the government as promoter of schemes, or by the industry.

Sustainable Traditional Building Alliance (STBA) members had the opportunity to hear and question Peter Bonfield in person at the STBA Advisory Group meeting in February 2017. In my role as STBA heritage chair I provided a response to the review, along with the other two chairs (industry and sustainability). We all urged the formation of a separate Traditional Buildings Working Group (for my part, I suggested the reinstatement of the Older Properties Working Group convened by the DECC in 2011, following a meeting between the then minister Greg Barker MP and Prince Charles, but subsequently allowed to lapse by the DECC).

Peter Bonfield told us that a separate working group would not be possible, but he invited the STBA to nominate representatives to the existing working groups, and to take part in a large-scale pilot project in Cornwall involving over 80,000 houses. While the details and basis of the involvement remain to be resolved, there was no sense that the knowledge and training challenges, or the overall risks, were adequately understood.

What is more, unless and until the BRE publishes its long-promised research on solid walls, it is hard to quantify the full extent of failed existing measures. Without a ‘thorough and extensive review’ of installed external wall insulation (as the 2015 BRE Solid Wall literature review [3] recommends) it is impossible to make a full assessment of the extent of the problem, or the financial and carbon costs of rectification.

By the time you read this, heritage sector interests will have discussed a collective approach to retrofit issues. Hopefully there will have been progress with the STBA on the working groups, and we should be able to judge whether there was substance in Peter Bonfield’s offer.

This article originally appeared in IHBC's Context 149, published in May 2017. It was written by John Preston, a historic environment consultant. He is vice-chair of the IHBC policy committee, convenor of the newly-formed IHBC green panel, and heritage chair of the Sustainable Traditional Building Alliance.