The National Insulation Association (NIA) published its response to the public comment draft of the revised PAS 2035 and PAS 2030 retrofit standards on 16 May 2023, saying it is generally supportive of the changes while calling for a reasonable transition period for adoption1.
The draft standards, out for public comment, would remove the risk pathways that currently split retrofit projects into different routes. Under the proposals, all projects would follow the assessment process previously used for the Path B route, requiring a basic building assessment plus enough detail to build an accurate RdSAP, SAP or PHPP energy model1. Design requirements would be standardised across projects, covering detailed design for the measures, an improvement options evaluation, a heritage significance assessment, a ventilation assessment and upgrade, a medium-term improvement plan, protected building design in line with BS 7913, and an airtightness strategy for some projects1.
The NIA set out its position on the main changes:
"The NIA is generally supportive of the revisions to PAS 2035/2030."
Other amendments in the draft include making the contents of a Medium Term Improvement Plan a requirement in all retrofits rather than guidance, and removing the Retrofit Advisor role pending improved qualifications, with retrofit advice continuing to be delivered by other retrofit professionals1. The draft adds clauses allowing Retrofit Design to start from assessments of archetypes to support retrofit at scale, brings moisture requirements in line with BS 5250, and explicitly includes airtightness in insulation retrofit under both standards, though airtightness testing is no longer normative as part of the assessment1. A new Annex E covers how to assess a building's significance, and Retrofit Coordinators would be required to carry out site inspections including a minimum of one visit1. Monitoring and evaluation would reference the new BS 40101 Building Performance Evaluation and run from inception through to completion1.
On the transition question, the NIA noted that many PAS-accredited businesses are already delivering long-term retrofit programmes such as ECO4, SHDF 2 and HUG 2, due to run until 2025 or 2026, and that installer certification is currently 2030:2019, which would need updating1. It also warned of limited capacity within accreditation bodies to handle industry-wide certification updates in a short window1. The NIA said a reasonable transition period is necessary to allow industry time to adapt to new delivery standards1. The length of that period has not been reported.
Why it matters for households
The PAS 2035 and PAS 2030 retrofit standards set the process that sits behind most publicly funded home energy efficiency work in the UK, including schemes such as ECO4 and the Social Housing Decarbonisation Fund. The draft revisions would change how a home is assessed and designed before measures are installed, and would require a medium-term improvement plan setting out a future strategy for the property in every retrofit rather than only in some1. The NIA cites the figure that 80% of the UK's housing stock in 2050 is already in existence, which it says makes those plans a source of building-specific data for later work1. For a household, the practical effect of the proposals is a more uniform assessment and design process, more points at which advice is given, and a minimum of one site inspection by the Retrofit Coordinator during the project1. The NIA also argues that retrofit designs should remain building-specific even where archetype assessments are used, to avoid unintended consequences from generic solutions1.
What happens next
The draft standards were out for public comment, and the consultation asked respondents what an appropriate transition period would be for adoption of PAS 2035:2023 and PAS 2030:20231. No date for publication of the final standards has been reported.