14 C O N T E X T 1 4 9 : M A Y 2 0 1 7 (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 inEach 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 such as my own 1938 house) 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, DECCcommissioned ‘in-depth study’, of which Colin King’s presentation to Ecobuild 20147 remains the only published evidence.The new CIGA (Cavity Insulation Guarantee Association) 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 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 separateTraditional BuildingsWorking Group (for my part, I suggested the reinstatement of the Older PropertiesWorking 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 review3 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. References 5 www.gov.uk/ government/uploads/ system/uploads/ attachment_data/ file/396363/ solid_wall_insulation_ literature_review.pdf 6 English Housing Survey Headline Report 2015–16, March 2017, www.gov.uk/government/ uploads/system/uploads/ attachment_data/ file/595785/2015-16_ EHS_Headline_Report. pdf 7 www.slideshare.net/ BREGroup/colin-kingecobuild-6-march-2014 John Preston is a historic environment consultant. He is vice-chair of the IHBC policy committee, convenor of the newlyformed IHBC green panel, and heritage chair of the Sustainable Traditional Building Alliance. Peter Bonfield, chair of the review that produced the Each Home Counts report
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