BSI Releases Consultation for PAS 2035 – 2023 Update
The British Standards Institution (BSI) has recently announced a public consultation for proposed amendments to the current versions of PAS 2035. The scope of the work is defined in the drafts published for consultation. Among the specific changes proposed are amendments and clarifications that aim to enhance the retrofit process. The deadline for public comments is 12th May 2023.
What is PAS 2035?
PAS 2035 is the over-arching document in the retrofit standards framework, outlining the requirements for a home to achieve its energy efficiency potential through a ‘whole house’ or ‘whole building’ approach. More information can be found on the page: What Is PAS 2035?
Summary of Major Changes:
- PAS 2035 guidance clauses have been updated to:
- Reflect national policy
- Emphasise the role of PAS 2035 in protecting the consumer
- Clauses have been included to facilitate scale retrofit by allowing Retrofit Design to commence based on Assessments of archetypes.
- The BEIS Retrofit technical guides have been included as references.
- The risk assessment process has been simplified to avoid unintended complexities.
- Reflecting the change of emphasis from measures-based retrofit to whole dwelling retrofit by including more reference to a Retrofit Contractor.
- Clarification of the role of the Retrofit Coordinator, including site visits and recording of non-compliance.
- Contents of a Medium Term Improvement Plan are now a requirement rather than guidance.
- Requirements to produce an airtightness strategy for some fabric projects, which may include the setting of an airtightness target and air leakage testing.
- Clarification of what happens in the PAS 2035 process if historic significance is identified. A new Annex E is included.
- Annex C has been simplified and aligned more closely with Approved Document F.
- Further Monitoring and Evaluation references the new BS 40101 Building Performance Evaluation and Monitoring and Evaluation is now considered from inception through to completion.
- A process has been included whereby distressed replacement of heating appliances can retrospectively comply with PAS 2035.
- The guidance and requirements for climate resilience and adaptation in retrofit have been strengthened.
- The requirements and qualifications for an independent inspection of the Pre-installation Building Inspection (PIBI) and some PAS 2030 Annexes have been strengthened.
- Requirements and guidance around moisture in buildings have been brought in line with the language in BS 5250.
Removal of Risk Pathways
A fundamental proposed change to PAS 2035 is the removal of risk pathways. It has been an all-encompassing change affecting many areas within PAS. The proposed changes mostly impact Retrofit Assessment, Retrofit Design and Advice. We have provided a summary of the changes for each area below:
Clarity on pathways changes for assessment:
| Current version of PAS 2035: | Proposed change: |
| PATH A: Basic building assessment
PATH B: As Path A + more details to create an accurate RdSAP/SAP/PHPP energy model PATH C: As Path B + Principles of RICS level 3 assessment + air leakage test + appropriate testing
|
As Path B
Airtightness testing: no longer normative as part of the assessment
|
Clarity on pathways changes for design:
| Current version of PAS 2035: | Proposed change |
| PATH A: Complete and detailed design for the measure(s)
PATH B: As Path A + improvement options evaluation + heritage significance assessment + ventilation assessment (Annex C) + medium-term improvement plan PATH C: As Path B + protected building design in accordance with BS 7913 + airtightness target & post testing
|
Complete and detailed design for the measure(s) + improvement options evaluation + heritage significance assessment + ventilation assessment & upgrade (Annex C) + medium-term improvement plan + protected building design in accordance with BS 7913 + airtightness strategy for some projects
|
Clarity on pathways changes for advice:
| Current version of PAS 2035: | Proposed change |
| PATH A: Advice at inception, on completion of the retrofit design and at handover.
PATH B: As Path A + on completion of the improvement options evaluation PATH C: As Path B
|
Advice at inception, on completion of the retrofit design, & on completion of the improvement options evaluation and at handover.
|
Qualification Changes
There are a number of proposals for changes to qualification requirements. These are shown in the tables below.
Key:
🟪 = Level 5 Diploma in Retrofit Coordination and Risk Management.
🟨 = Level 3 Award in Energy Efficiency and Retrofit for Traditional Buildings (or Scottish/Welsh equivalent).
MCIAT = Chartered Member of the Chartered Institute of Architectural Technologists.
MCIOB = Professional Member of the Chartered Institute of Building.
M/FRICS = Chartered Building Surveyor.
CIBSE = Professional Member of the Chartered Institute of Building Services Engineers.
Current Qualifications:
| Path A | Path B | Path C | Heritage/Traditional Building | |
| Retrofit Assessor | Domestic Energy Assessor
or 🟪 |
Domestic Energy Assessor | Domestic Energy Assessor + 🟨 | |
| Retrofit Coordinator | 🟪 | |||
| Retrofit Designer
|
🟪 or CIAT*
|
🟪
or MCIAT or Architect or MCIOB or M/FRICS |
MCIAT
or Architect + 🟪 or CIBSE + 🟪 or MCIOB + 🟪 or M/FRICS + 🟪 |
Path B + 🟨
or Member of building conservation scheme or Path C + member of a building conservation scheme |
| Retrofit Installer | Operatives are required to have measure specific competencies as defined in the Annex’s of PAS 2030 | |||
| Retrofit Evaluator | 🟪 | 🟪+🟨 | ||
*for single measure projects, the qualifications listed do not apply, instead the Retrofit Designer is a specialist designer or specifier of that measure and holds a measure-specific recognised qualifications.
Proposed Changes:
| Single Measure | Two Measures | System-built, Highrise, > Two Measures | Traditional Building | |
| Retrofit Assessor | Domestic Energy Assessor | Domestic Energy Assessor + 🟨 | ||
| Retrofit Coordinator | 🟪 | 🟪 + 🟨 | ||
| Retrofit Designer
|
Specialist designer or specifier of measure
or MCIAT or Architect or MCIOB or M/FRICS or 🟪 |
MCIAT
or Architect or MCIOB 0r M/FRICS or 🟪
|
MCIAT
or Architect or MCIOB or M/FRICS |
MCIAT
or Architect or MCIOB or M/FRICS + 🟨 |
| Retrofit Installer | Operatives are required to have measure specific competencies as defined in the Annex’s of PAS 2030 | |||
| Retrofit Evaluator | 🟪 | 🟪+🟨 | ||
Elmhurst Response
Josh Wakeling, Head of Operations, commented:
“Elmhurst Energy welcomes the commitment by BSI to revise the PAS regularly and appreciates the opportunity to be involved in the steering group for PAS 2035, representing retrofit assessors and coordinators. The simplification of the risk pathways seems to be a practical move to ensure the industry and stakeholders remain clear on what the requirements are for each retrofit project. The biggest challenge for PAS 2035 is maintaining quality whilst not increasing the cost of compliance through the process. We will now take some time to digest the consultation as well as the key points raised and respond accordingly”.
Elmhurst Energy will reply to the government consultation on behalf of our members. The deadline for all public comments is 12th May 2023.
To view the consultation, use the following link: https://standardsdevelopment.bsigroup.com/projects/2022-01802/#/section