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Last edited 23 Nov 2021
PAS 2038:2021 Retrofitting non-domestic buildings for improved energy efficiency
Illustration by MVOPro, source: https://mvopro.nl/wp-content/uploads/2021/02/Energielabel-bedrijfsgebouw-1024x403.png
The British Standards Institution (BSI) is the UK National Standards Body (NSB). A PAS is a fast-track standard, specification, code of practice or guideline developed to meet an immediate market need following guidelines set out by BSI.
 PAS 2038:2021 background
On 25 August 2021, BSI presented an online discussion about PAS 2038:2021.
She discussed the Each Home Counts programme for domestic energy standards, which was set up in 2016 by MHCLG and DECC (now part of BEIS). Also known as the Bonfield Review (lead by Peter Bonfield of BRE), the Each Home Counts approach was a response to the poor quality of delivery of energy efficiency retrofits under previous schemes (including the Green Deal) and included several recommendations such as a new standard and a supporting certification system established by TrustMark.
This resulted in the establishment of the Retrofit Standards Task Group (RSTG), which defined a need for a cohesive standard with a holistic approach. In conjunction with this work, the RSTG announced the development of a new technical committee to examine additional related standards (including building performance evaluation, energy assessment, air tightness and ventilation and energy advice).
The standard was initially published as PAS 2030/2035 in 2019. Early versions of PAS 2030 included cursory coverage of non-domestic structures, but with the publication of PAS 2035, it was apparent that non-domestic existing buildings required their own standard. This resulted in the development of PAS 2038.
 Best practice for non-domestic energy retrofits
Peter Rickaby, chair of the BSI RSTG, clarified points about the task group, explaining that it attempts to address functionality, durability, sustainability, historic preservation and comfort issues in addition to energy efficiency. He then went on to explain how the domestic standard (PAS 2035) “set the scene” for the process used for the non-domestic standard (PAS 2038) - both requiring compliance with a set of existing and new BSI standards as well as non-BSI standards.
Rickaby said “offices, shops and industrial buildings occupy about 60% - or maybe 65% - of the entire stock or ‘bulk classes’” of existing non-domestic buildings in England and Wales. In total, there are approximately two million buildings in England (plus approximately 10% more in Scotland) covering every type of non-domestic building. While there are not many very big buildings that use large amounts of energy, smaller base buildings with multiple tenants create their own challenges for retrofit purposes, as do stock buildings (in retail) and large speciality sheds (in the industrial sector).
Within the non-domestic sector, retrofits tend to take place in conjunction with more comprehensive refurbishment or refitting projects. This work tends to involve professional consultants or contractors (as opposed to projects in the domestic sector). This is due to the general size and complexity of non-domestic projects.
One of the key points of PAS 2038 is that the role of retrofit coordinator (found in PAS 2035) has been replaced by a retrofit lead professional “who deals with managing the project from end to end and claiming compliance,” Rickaby said.
He explained that smaller, simpler non-domestic buildings less than 500 square metres could opt to comply with PAS 2035 instead of PAS 2038. For traditionally constructed or protected non-domestic buildings, there are additional requirements - including a heritage impact assessment - that must be considered.
Andy Jackson, Policy Lead, Energy Efficiency Market, BEIS explained why the standard was commissioned and what will ideally be achieved by it. He mentioned the importance of giving lenders and customers confidence in retrofit work, particularly in terms of post-retrofit performance. He also spoke about the skills gap (an ongoing issue in energy efficient retrofit projects) along with guidance for building owners looking to achieve net zero goals by 2050.
Jackson said, “By 2050, we expect that 70% of the existing commercial buildings will still be in use, with 40% of those built prior to 1985, which is when Part L of the building regs were introduced. Retrofit is a significant and vital challenge, and one we’ll need to get right the first time, by not creating further work down the line for the supply chain. By using PAS 2038, that quality should happen.”
- Approved document L.
- Bonfield Review.
- British Standards Institution BSI.
- IHBC COP26 podcasts.
- NABERS UK.
- PAS 2035.
- PAS 2038 and older buildings.
- Publicly available specification.
- Retrofit coordinator.
- Soft landings.
- The Each Home Counts report and traditional buildings.
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