Stroma Certification DEA Masterclass Update CPD Session May 2016

Transcription

1 Stroma Certification DEA Masterclass Update CPD Session May 2016 Presented by Andy Parkin Stroma Certification 2016 Version 1.0 Page 1

2 House Keeping Welcome to Stroma s CPD session Housekeeping Fire alarm Emergency exits Toilets Breaks Mobile phones Please keep questions to the end of each section Stroma Certification 2016 Version 1.0 Page 2

3 Welcome In this presentation we will cover: 1. Industry Developments Smart Audits and New SORs Minimum Energy Efficiency Ratings for Rental Properties Green Deal, FIT and RHI u-values for ECO OFGEM update 2. Audit Masterclass New Conventions (v.9) Current list of common audit failures New reasons for audit failures (RdSAP 9.92) 3. Training Opportunities HI Stroma Certification 2016 Version 1.0 Page 3

4 Industry Developments What is happening in ? Stroma Certification 2016 Version 1.0 Page 4

5 Changes to Scheme Operating Requirements The Scheme Operating Requirements (SORs) are put in place to instruct Schemes on how to operate with respect to their members. Therefore they have a direct effect on scheme members. They cover 13 key areas from Fit and Proper persons, to audits, to disciplinary action. The SORs were last rewritten and released in June DCLG were due to review the SORs this year or next year. Stroma Certification 2016 Version 1.0 Page 5

6 Proposal for the SOR A new SOR So what has happened? Schemes contacted DCLG to explore rewriting the SORs to help improve key areas and move the industry forward. DCLG have agreed to the review and have worked with Schemes to start the process. Key focus is the auditing process. Starting with DEA Strand first. Stroma Certification 2016 Version 1.0 Page 6

7 Changes to Audit Process Smart Auditing Current Auditing Process. It does work, but is slow to instigate learning and change All agree it is out of date - too random Not fit for current purpose Overly complex / bureaucratic Slow to react & change Focuses on the process for compiling evidence Stroma Certification 2016 Version 1.0 Page 7

8 Smart Audit Process Proposed Smart Auditing process Focus on non-random audits Audits called on the data entered into EPCs Highlights data that could be wrong Highlights suspicious patterns These are smart triggers and are created by the schemes and industry where issues are found Audit remains the same same evidence and timescales Stroma Certification 2016 Version 1.0 Page 8

9 Smart Audit Process What are the smart audit Rules? Stroma Certification 2016 Version 1.0 Page 9

10 Smart Audit Process What about Random Audits? There will still be audits called at random Every assessor will still be audited but this could be a lesser amount if the DEA doesn t trigger any smart rules These standard audits will still be audited in the same way All failed audits (random and smart) will have follow up audits to check that the DEA has learned from the audit process Stroma Certification 2016 Version 1.0 Page 10

11 Smart Audit Process Maintains Current Audit Volumes but auditing in a smarter way Schemes will spend the same amount of resource more effectively Moves to an output driven risk based approach Builds upon the good points of what we do today Allows flexibility to cater for new requirements of the EPCs Starts a journey together Stroma Certification 2016 Version 1.0 Page 11

12 Audit Blend Stroma Certification 2016 Version 1.0 Page 12

13 Smart Audit Trial At present DCLG are running a trial on the Smart Auditing process with all Accreditation Bodies Scheme communicated this to members at the end of March This will allow all stakeholders to evaluate the process and see if it could work going forward It will highlight where problems occur and where any improvements to process and audit system will be needed The trial will work alongside the currently running audit process set in the SOR Stroma Certification 2016 Version 1.0 Page 13

14 Structural Changes to the SOR? Currently one very large and confusing document Proposed to move to a 4 level document The structure allows flexibility at the right levels High Level DCLG requirements should not need to change very often (levels 1 and 2) Strand specific levels can be amended (Level 3) without need for changes to levels 1 and 2 Level 4 docs can be amended very quickly to address any industry issues Stroma Certification 2016 Version 1.0 Page 14

15 Structure of SORs Stroma Certification 2016 Version 1.0 Page 15

16 The Future? Schemes are undergoing a smart auditing trial with approval from DCLG The trial is going to be reviewed in early May, and then after 3 months. There will probably be a consultation on changes to the SOR and smart audits, which all stakeholders will be invited to contribute DEA strand is a focus, but other strands will see similar rewrites to the SOR at a later date. Stroma Certification 2016 Version 1.0 Page 16

17 Minimum Energy Efficiency Standards Domestic Stroma Certification 2016 Version 1.0 Page 17

18 What are the Regulations? The Regulations were published in February 2015 This was following a consultation between July and September 2014 The Regulations were put in place to meet Government obligations set out in the 2011 Energy Act They are set up to improve the energy efficiency of privately rented property Both domestic and non-domestic rented properties are included However, whilst the principles are the same, there are some differences. Stroma Certification 2016 Version 1.0 Page 18

19 What are the Regulations? Below are links to the consultation document and the regulations themselves Consultation Response le/401381/dom_prs_energy_efficiency_regulations_- _Gov_Response_FINAL 04_02_15_.pdf Regulations _en.pdf Stroma Certification 2016 Version 1.0 Page 19

20 Key Policy Decisions Regulations apply to the Domestic private rented sector in England and Wales Welsh Government may have their own angle on the regulations however. Properties let on tenancies of less than 6 months or of 99 years or more are excluded. All types of domestic property are included except those excluded from having an EPC (see properties excluded from a need to have an EPC) Stroma Certification 2016 Version 1.0 Page 20

21 Key Policy Decisions The minimum energy efficiency standard was set at an E rating Meaning, properties that only achieve an F or G rating must be improved to at least an E rating. However, there are safeguards in place that allow restrictions on making improvements. Stroma Certification 2016 Version 1.0 Page 21

22 Key Policy Decisions Only permissible, appropriate and cost effective improvements are required under the regulations Landlords will be eligible from exemptions from reaching an E rating where they can evidence; The measure are not cost-effective on a 7 year payback or under the Green Deal Golden Rule (pay for the improvement via savings generate over he lifetime of the improvement) What is happening with Green Deal?? The Landlord cannot obtain necessary consents to install the improvements (from tenants, lenders or superior landlords) A suitably qualified expert provides written advice that the measure would reduce the properties value by 5% or more, or that wall insulation will damage the properties structure. Stroma Certification 2016 Version 1.0 Page 22

23 Timescales From 1st April 2018 the regulations will apply upon the granting of; a lease to a new tenant, and, a least to an existing tenant. From 1 st April 2023, the regulations will apply to ALL privately rented property in the scope of the regulations, including where a least is already in place and property is occupied by a tenant. Stroma Certification 2016 Version 1.0 Page 23

24 Enforcement Local authorities will enforce the provision of the regulations It is likely that Trading Standards will undertake the enforcement activity. To avoid enforcement, Landlords will need to notify the exemption on the PRS Exemption Register. Local authorities can serve a compliance notice on the landlord if they do not agree or feel insufficient evidence is supplied. Ultimately the Local Authority may issue a penalty notice. These are potentially very costly to a landlord Stroma Certification 2016 Version 1.0 Page 24

25 Enforcement Stroma Certification 2016 Version 1.0 Page 25

26 Next steps The Government will work with the sector to develop guidance to help landlords, tenant, local authorities and sector bodies to understand and prepare for the regulations; Before the they apply in 2018 Before the register becomes available to lodge exemptions in 2016 The Government has committed to review the effectiveness of these regulations every 5 years, the first being in Stroma Certification 2016 Version 1.0 Page 26

27 Next steps If you are an active DEA, speak to your clients landlords, letting agents and inform them about these regulations and ask if they are aware of them They will need an EPC the next time they rent out their property It is important that they achieve an E rating OR can achieve an E by There are many implications of number of EPCs required but this most likely will increase the number of EPC lodgements. Either initial EPCs or follow up EPCs after improvement has occurred. Your advice may be sought by those in the industry and Landlords. Stroma Certification 2016 Version 1.0 Page 27

28 Next steps There has been little movement on this legislation in the last year; However, DECC have just announced that the Exemptions Register is going ahead and will need to be ready for It therefore seems to be prudent to be aware of the legislation and discuss with clients. Stroma will keep its members informed of any developments that occur. Stroma Certification 2016 Version 1.0 Page 28

29 RHI and FIT and Green Deal RHI Changes These can be found in the updated website and guidance material. on_form_guide_v2_0_mar_2016_web.pdf Stroma Certification 2016 Version 1.0 Page 29

30 RHI and FIT and Green Deal RHI Changes GDAR no longer required for RHI bad and good news? Applicants will still need to meet minimum insulation requirements of loft and cavity wall insulation and provide a valid Energy Performance Certificate (EPC) that is no more than 24 months old. Changes to the tariffs (degression) Using CPI and not RPI for tariff indexation Changes to occupancy days for first year (self build) Enabling Ofgem to amend RHI payments following the acquisition of a new EPC. Stroma Certification 2016 Version 1.0 Page 30

31 RHI and FIT and Green Deal FIT Changes Guidance taken from EST website states; For solar PV, the Energy Performance Certificate that shows your home has an energy efficiency rating band D or better in order to be eligible for the higher rate. (Note: if you submit your application before 10 May 2016, the EPC will need to be dated on or before the commissioning date of your PV system. If you submit your application on or after 10 May 2016, the EPC will need to be dated before the commissioning date of the system). If the EPC band D or better is dated after the commissioning date of your system you will be eligible for the lower rate. Stroma Certification 2016 Version 1.0 Page 31

32 RHI and FIT and Green Deal Green Deal DECC are committed to keeping a Pay as you Save / Able to Pay model running. Green Deal was that model. They are currently looking at improving the way the report looks and what it says. This is in preparation for any new launch. However, no guarantees have been made as to when (or if) this may happen. Stroma will keep you updated on any developments. Stroma Certification 2016 Version 1.0 Page 32

33 U-value consultation Earlier this year OFGEM consulted on how u-values should be used for ECO There was a concern of fraud and over claiming of carbon They have therefore gathered opinion and issued new rules for those involved in the ECO chain to follow; Stroma Certification 2016 Version 1.0 Page 33

34 U-value consultation Stroma Certification 2016 Version 1.0 Page 34

35 U-value consultation Stroma Certification 2016 Version 1.0 Page 35

36 U-value consultation What does this mean? You will need to be aware that it will be unlikely that you cannot change u-values for ECO reports. OFGEM will reject them if checked or questioned. However, you wont fail an EPBD audit at this stage as the Convention hasn t changed (yet) Stroma Certification 2016 Version 1.0 Page 36

37 Any Questions? Stroma Certification 2016 Version 1.0 Page 37

38 Break (15mins) Stroma Certification 2016 Version 1.0 Page 38

39 Conventions v9 What is changing? Stroma Certification 2016 Version 1.0 Page 39

40 Conventions What are the Conventions? They are a set of rules that, if followed correctly, will result in a standardised approach for completing assessments. This should result in a repeatable process and outcome. Why do they change? In order to improve the repeatability of the EPC When refinement is requested/required Where further clarification is required Where it is noted that a convention needs to be created Stroma Certification 2016 Version 1.0 Page 40

41 Conventions What is in the new conventions? The major changes are likely to include; Known u-value use Shared PV systems Dwelling separations (self-contained) Unknown thicknesses of insulation Rules around entering foam insulation Room in roof aging guidance Further clarification when entering two main systems Transaction type guidance Stroma Certification 2016 Version 1.0 Page 41

42 Conventions What is in the new conventions? We can only publish the conventions once DCLG have approved them and written to Schemes. This is to ensure that DEAs start using conventions at an agreed point in time. As soon as Stroma has been told to release the new document, we will communicate them to our members. Stroma Certification 2016 Version 1.0 Page 42

43 Conventions What is in the new conventions? As soon as Stroma has the approved convention document and the letter from DCLG, we will release: The document and letter A technical bulletin covering the changes CPD sessions and online CPD to help members use the conventions It is important that members read these and complete the CPD. You will be more likely to pass audit if you are ready for new conventions. Stroma CPD is free to all members. Stroma Certification 2016 Version 1.0 Page 43

44 Audit Masterclass - Common Audit Failure Reasons Stroma Certification 2016 Version 1.0 Page 44

45 Why do audits fail Two main groups There are two kinds of audit failure; 1) Technical Reasons Something is technically wrong with the EPC Details are covered in a later slide 2) Lack of Evidence received Non-submission Insufficient evidence Lets have a look at the Non-Submission reasons first Stroma Certification 2016 Version 1.0 Page 45

46 Why do audits fail Non-submission By far the most common reason for audit failure. There are several reasons for Non-Submission; Simply not submitting in time (most common) Lost all evidence Lost key evidence floor plan, certain photos etc. Stroma Certification 2016 Version 1.0 Page 46

47 Why do audits fail Non-submission Non-submission will result in the assessor being suspended until they submit the audit or they tell the audit team why they cant submit. Repeated failure for non-submission can result in the assessor being Struck Off. This is absolutely avoidable and is only down to bad practice. All audits give an assessor 15 working days to send in all audit evidence. Stroma Certification 2016 Version 1.0 Page 47

48 Why do audits fail Non-submission Stroma will call you at least once in this period to remind you to send the audit in. You can send in evidence via RSAP+ ipad or Desktop Software OSA 15 folder WeTransfer ( When you send in evidence, the audit admin team will check to ensure enough evidence to do the audit is present You will then get a confirmation to let you know that we have submitted the audit to an auditor. Stroma Certification 2016 Version 1.0 Page 48

49 Key Point Evidence Evidence should be collected and stored: Site notes Floor plans Photographs Documentary Evidence The minimum photos are listed in the SOR and in our Monitoring Document. Anything that can be questioned by an auditor should be sent through. Supports the findings of the EPC Supports the DEA at audit Supports the DEA if a complaint is received Useful for historical reference When returning to the property Or similar property on the same site Stroma Certification 2016 Version 1.0 Page 49

50 Key points Evidence Storage All evidence must be kept for 15 years All evidence must be retrievable during this time: Do you have a system to store and retrieve the information quickly Is all evidence relevant to each survey? Is it organised? Mixed up evidence will result in audit failure All evidence must be backed up: To allow retrieval in the event of fire, theft or flood Lost evidence is a common reason for audit failure: Not an acceptable reason Evidence wasn t suitably backed up Stroma Certification 2016 Version 1.0 Page 50

51 Why do audits fail? Technical Reasons An audit can fail for several technical reasons: The EPC EER is deemed to be more than +/- 5 SAP This is culminated score (i.e. the absolute sum of all errors) There is a variance in the recommendations, or inappropriate recommendations. There is a material difference in the EPC. This can be any statement on the EPC: Address Property description Star ratings etc. Stroma Certification 2016 Version 1.0 Page 51

52 List of Audit Failure Types 2016 to date Stroma Certification 2016 Version 1.0 Page 52

53 Key point Date Stamps All photographic evidence should be dated within the image, to prove that they relate to the property being assessed, on the date of assessment. If this is not possible, electronic files (e.g..jpg) are acceptable as long as we can securely ascertain the dates from the file. Photographs embedded in files (e.g. WORD, PDF) should be dated within the image, with the master images being retained by the DEA. Stroma Certification 2016 Version 1.0 Page 53

54 Key point Date Stamps Acceptable Evidence The following slides covers what is classed as acceptable and unacceptable evidence for EPC audit; Date stamped photographic evidence Metadata evidence Stroma Certification 2016 Version 1.0 Page 54

55 Key point Date Stamps Acceptable Date stamp is applied by the camera within the image This photo is a particularly good example as the weather conditions support the date on the photo. If all photos submitted are of this standard, then the audit will pass on this aspect. Stroma Certification 2016 Version 1.0 Page 55

56 Key point Date Stamps Acceptable - Electronically dated camera type is also listed This evidence would be sufficient to pass the photography aspect of the audit Stroma Certification 2016 Version 1.0 Page 56

57 Key point Date Stamps Unacceptable Evidence Unacceptable Date stamp is applied by word or an importing package it wasn t added by the camera within the image The audit fails 30/01/2013 Stroma Certification 2016 Version 1.0 Page 57

58 Key point Date Stamps Unacceptable Evidence Unacceptable The photos have had their metadata removed from the file. It would be impossible to ascertain the date taken. The audit fails. Stroma Certification 2016 Version 1.0 Page 58

59 Key point Date Stamps Unacceptable Evidence Unacceptable A word document with photos added (no date stamp) The photos no date stamp in the image. It would be impossible to ascertain the date taken. There is no metadata The audit fails. Stroma Certification 2016 Version 1.0 Page 59

60 Key point Date Stamps Round Up From the unacceptable examples, you can see that there is no metadata associated with the photos that have been submitted and/or there is no date stamp in the photo. Without this evidence, an auditor cannot ascertain that the photos; Belong to the property Have been taken on the day of survey Are authentic and are not stock photography The audit will fail for lack of photographic date stamp reasons The audit will carry on to check the technical aspects of the EPC. Stroma Certification 2016 Version 1.0 Page 60

61 Use of As-Built and Unknown This has become one of the most common and appealed failure points. Stroma wrote a technical bulletin that deal with this issue (August 2015), but we have seen a steady increase in audit failures. Because assessors are not aware of the changes to the dataset, unknown has been used instead of as built (and vice versa)and this supresses recommendations, therefore results in an audit fail. Assessors will often appeal but the audit result is upheld. Stroma Certification 2016 Version 1.0 Page 61

62 Use of As-Built and Unknown Stroma wrote a technical bulletin that deal with this issue (August 2015), but we have seen a steady increase in audit failures. in the following circumstances; Flat roof Room in roof Sloping Ceiling Lets have a quick look at the convention as it currently stands. Stroma Certification 2016 Version 1.0 Page 62

63 Use of As-Built and Unknown Stroma Certification 2016 Version 1.0 Page 63

64 Use of As-Built and Unknown When NOT to use As-Built As Built is NOT used in the following circumstances; When you have access to a loft area the theory here is that you can either a) measure the insulation and you can enter a thickness or (b) the loft is boarded and you enter unknown. When you have evidence of the presence of retrofitted insulation i.e. the as built statement no longer applies. Stroma has written validation into its software for theses circumstances. Stroma Certification 2016 Version 1.0 Page 64

65 Use of As-Built and Unknown Please remember when recording a flat roof/sloping ceiling, roof room, wall construction and floor type, you should select the option 'As Built' if there is no evidence to prove otherwise. Effectively, as the assessor, you are saying that the element in the dwelling has not changed since it was built. You will have to have NO access in the room in roof areas in order to select the as built if access is possible then you should use a known thickness for any insulation present. The next few slides are examples of how the data must be entered in RSAP+ for each scenario Stroma Certification 2016 Version 1.0 Page 65

66 Use of As-Built and Unknown Flat/Sloping Ceilings Flat Roof Sloping Ceiling Stroma Certification 2016 Version 1.0 Page 66

67 Use of As-Built and Unknown Room in Roof Areas Room in Roof No access and no evidence of additional insulation (as built) Stroma Certification 2016 Version 1.0 Page 67

68 Use of As-Built and Unknown Room in Roof Areas Room in Roof No access to all areas and no additional insulation installed (as built) no flat ceiling (i.e. vaulted/sloping ceiling) Stroma Certification 2016 Version 1.0 Page 68

69 Use of As-Built and Unknown Wall Construction Any wall and no evidence of any retrofit insulation (in this case, cavity construction) Stroma Certification 2016 Version 1.0 Page 69

70 Use of As-Built and Unknown Wall Construction Any wall and conflicting evidence of retrofit insulation (in this case cavity construction) use of unknown Stroma Certification 2016 Version 1.0 Page 70

71 Use of As-Built and Unknown Floor Insulation Any floor and no evidence of any retrofit insulation (in this case, suspended timber) Stroma Certification 2016 Version 1.0 Page 71

72 Use of As-Built and Unknown Floor Insulation Any floor and conflicting evidence of any retrofit insulation (in this case, suspended timber) use of unknown Stroma Certification 2016 Version 1.0 Page 72

73 Preventing audit failure Stroma Certification 2016 Version 1.0 Page 73

74 Help and Support Login to Read our technical bulletins These go towards your CPD total for the year There are also CPD documents for each common audit failure point These also contribute towards your annual CPD total Download our recently rewritten RdSAP manual If you have an ipad or other tablet, you can save these documents to your device and use them when needed in the field Stroma Certification 2016 Version 1.0 Page 74

75 Passing Audit General tips for passing audit 1. Submit all audit information on time ideally ahead of time so we can resolve any issues 2. Ensure all minimum evidence is supplied 3. Ensure evidence is of sufficient quality and relevance to allow an auditor to complete the audit and come to the same decision as you 4. Read the DEA technical bulletins when they are released 5. Use to your advantage 6. Download the documents to your PC and/or tablet for reference on site Stroma Certification 2016 Version 1.0 Page 75

76 Any Questions? Stroma Certification 2016 Version 1.0 Page 76

77 Thank you for your time Stroma Certification 2016 Version 1.0 Page 77