Scoping ECO for Park Homes
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Scoping ECO for Park Homes
A study on the availability of ECO funded external insulation
systems for improving the building standards of Residential
Park Homes in England & its applicability on two existing
residential sites.
A report by NEA on behalf of npower
March 2014
Acknowledgements
NEA is extremely grateful to npower for funding this project to identify a means of
helping the residents on park home sites in England who have been neglected in
previous funding programmes aimed at improving the housing stock.
The project team would like to thank the residents of the two park home sites visited, for
allowing us access to their homes, and giving up their time to talk to us.
NEA would like to thank Ursula Seddon from Eden District Council, and Les Laws from
Salford City Council for their help and encouragement.
Finally, NEA would also like to extend their thanks to the park home site owners and
managers for giving up their time to assist with the initial resident engagement and for
discussing the project with us.
Prepared by National Energy Action
March 2014
Authors: Michael Hamer & Paul Cartwright
NEA
Level 6 (Elswick)
West One
Forth Banks
Newcastle upon Tyne
NE1 3PA
www.nea.org.uk
Page | 1
Table of Contents
Acknowledgements ................................................................................................................................................ 1
Glossary of Terms ................................................................................................................................................... 4
Executive Summary ................................................................................................................................................ 5
1 Project Background ........................................................................................................................................ 9
2 Project Aims ................................................................................................................................................. 10
3 Overview of ECO .......................................................................................................................................... 10
3.1 Applicability to park homes................................................................................................................. 11
4 Insulation products for use on park homes ................................................................................................. 11
4.1 Overview of Insulation Types .............................................................................................................. 13
4.1.1 Typical rigid board insulation types ................................................................................................ 13
4.1.2 Spray Insulation .............................................................................................................................. 13
4.2 General Comparison of Insulation Systems ........................................................................................ 13
5 Product Accreditations and standards ......................................................................................................... 14
5.1 Product Guarantees ............................................................................................................................ 14
5.2 ECO Guarantee requirements ............................................................................................................. 15
5.3 Overview of requirements .................................................................................................................. 16
5.4 General Contractor Requirements ...................................................................................................... 18
5.5 Surveyors Qualifications...................................................................................................................... 18
5.6 Insulation System Compliance Summary ............................................................................................ 19
6 Identification of Appropriate CSCO eligible park home residential sites ..................................................... 20
6.1 Sites Identified through desk based Activity ....................................................................................... 20
6.2 Tenure ................................................................................................................................................. 24
6.2.1 What the issues are with private site owners? ............................................................................... 24
6.3 Recommendations for best practice ................................................................................................... 25
6.4 Best practice recommendations for delivery ...................................................................................... 28
7 Case Study 1 – Greenacres Park, Cumbria ................................................................................................... 30
7.1 Insulation Study Findings .................................................................................................................... 30
7.2 Wider Benefits .................................................................................................................................... 33
7.3 District heating .................................................................................................................................... 33
7.3.1 Focus on District Heating ................................................................................................................ 34
7.4 Conclusion ........................................................................................................................................... 36
8 Case Study 2 – Fairways Park, Manchester .................................................................................................. 37
8.1 Introduction ........................................................................................................................................ 37
8.2 Insulation Study Findings .................................................................................................................... 37
8.3 Wider Benefits .................................................................................................................................... 39
8.4 District heating .................................................................................................................................... 40
9 Other Potential Funding............................................................................................................................... 41
9.1 Green Deal Communities – Local Authority Fund ............................................................................... 41
9.2 Urban Community Energy Fund (UCEF) .............................................................................................. 41
9.3 Rural Community Energy Fund ........................................................................................................... 42
10 Conclusion .................................................................................................................................................... 42
11 Recommendations ....................................................................................................................................... 42
Appendix 1 – Census Data (2011), dwellings defined as “temporary structures” ................................................ 43
Appendix 2 - Park Homes – Typical RdSAP Performance and costs ..................................................................... 44
Appendix 3 – The Green Deal – Cashback scheme ............................................................................................... 45
Appendix 4 – ECO Brokerage Auction clearance price ......................................................................................... 47
Page | 2
Appendix 5 –Questionnaire .................................................................................................................................. 48
Appendix 6 – Fairways – Property detail from questionnaire .............................................................................. 52
Appendix 7 – Fairways – Behaviour detail from questionnaire ............................................................................ 53
Appendix 8 – Greenacres – Property detail from questionnaire .......................................................................... 54
Appendix 9 – Greenacres – Behaviour detail from questionnaire ....................................................................... 55
Page | 3
Glossary of Terms
BBA British Board of Agrément
CERT Carbon Emissions Reduction Target
CERO carbon Emissions Reduction Obligation
CIGA Cavity Insulation Guarantee Agency
CSCO Carbon Saving Communities Obligation
ECO Energy company Obligation
EPC Energy Performance Certificate
ESCO Energy Services Company
EWI External Wall insulation
HHCRO Home Heating and Cost Reduction Obligation Part of ECO
IWI Internal Wall insulation
LPG Liquefied Petroleum Gas (Bottled Gas)
MPAN Meter Point Administration Number
NIA National Insulation Association
PAS Publically Available Specification
RdSAP Reduced Data SAP
RHPP Renewable Heat Premium Payment
SAP Standard Assessment Procedure
SWIGA Solid Wall Insurance Guarantee Agency
TRV Thermostatic Radiator Valve
VIP Vacuum insulation Panel
Page | 4
Executive Summary
Project Background
There are an estimated 96,000 mobile homes or park homes, used as permanent
residential dwellings for 200,000 residents in the UK, spread across over 1,200 parks 1.
Park homes are often known as residential caravans. Residents are often particularly
susceptible to fuel poverty because:
The structures are thermally inefficient – they lose heat quickly
Parks are often off the mains gas network so more expensive fuels are used such
as bottled LPG (liquid petroleum gas)
Owners are of mostly over the age of 60 so are more vulnerable to the health
impacts of cold
Owners are often on fixed incomes i.e. pension
These factors combined create undesirable conditions for residential accommodation, in
terms of an energy inefficient building, high fuel costs and limited income. The definition
of these properties as “moveable” presents problems with eligibility for government
retrofit schemes.
The Energy Company Obligation (ECO) is a potential source of help for residents of park
homes, providing carbon as well as social benefits to the communities. There is a lot of
uncertainly in this area regarding guarantees for products, appropriate methodology for
measuring the impact of retrofit measures, and the appetite of residents and park home
site owners to take up these measures.
Project Aims
This report, for npower, aims to clarify the ECO eligibility in relation to park home
insulation, and then applies this knowledge to two unrelated residential park home sites
in England. This will provide npower with a valuable insight into both the issues
concerning this longstanding problem and enable them to be one of the first
organisations to provide much needed assistance to the vulnerable residents
occupying park homes.
This project considers the applicability of ECO funding to park home retrofit situations,
investigate the availability of approved products and approved installation contractors.
The report will allow the funder to model retrofit works within ECO processes to
determine cost effectiveness (carbon benefit and capital funding) of a retrofit project.
The Energy Companies Obligation2 (ECO) is a statutory scheme for Great Britain
established by the Gas and Electricity (Energy Companies Obligation) Order 2012 (the
Order). It imposes a legal obligation on larger energy suppliers to deliver energy
efficiency measures to domestic energy users.
Insulation products
There are many different insulation materials available on the market today, all with
differing thermal and mechanical characteristics. Park homes, comprised of wood,
plastics, aluminium or MDF in varying proportions and configurations require a different
approach to that used on more traditional houses. System manufactures’ specifications
1
Consumer focus Briefing: Park homes available at http://www.consumerfocus.org.uk/files/2010/12/Green-Deal-and-park-homes-v1.pdf
2
See Energy Company obligation – Guidance for Suppliers available at https://www.ofgem.gov.uk/ofgem-publications/59015/energy-
companies-obligation-eco-guidance-suppliers-15-march.pdf
Page | 5
should always be consulted when selecting an appropriate system and suitably qualified
installation contractor is used. Manufacturers usually publish a list of contractors who
are approved to install their systems. This process is essential to comply with ECO
requirements where insulation measures installed must be accompanied by an
appropriate guarantee.
Case study sites
As part of this study, NEA was required initially to identify and cross reference residential
park home sites in England with the tables of CSCO areas. After the governments
Autumn Statement in November 2013, which changed the funding and timescales
relating to ECO delivery (and carbon reduction targets), the preference for a site being in
the CSCO eligible area was relaxed.
Investigations revealed that there is no comprehensive list of UK based park home sites.
In addition, the Department of Communities and Local Government (CLG) commented
that they have no intention of compiling one. Two sites were selected to be included in
the case studies for this report. The Fairways Caravan Park, a showman park in Salford,
Manchester and Greenacres Park, a rural park near Penrith in Cumbria, occupied by
residents over 50 years in age, giving a good representation of sites across England.
Results
It is apparent through the research carried out on this project that there is a large
number of residential park home sites dispersed over the UK. The detail and location of
these sites is not available from any single source, detail is hard to locate.
During the timeline of this project, there have been significant developments in the
funding and technology landscape bringing the benefits of solid wall insulation systems
(funded by ECO) closer to being deployed in the Park Home community. 2014 saw the
acceptance of the installation standards by the approvals body CERAM, followed by the
acceptance by the insurance backed guarantee scheme operated by KINNELL, and finally
that some insulation products met the ECO funding requirements set by OFGEM. The
result is that there are now products available to funders of ECO schemes to deploy on
park home sites and meet ECO and OFGEM eligibility criteria.
The project saw significant changes to the ECO requirements placed upon energy
companies – in the Governments Autumn Statement. As such, available funding was
effectively reduced, and the result was that carbon requirements [on ECO providers]
were made more challenging – meaning less money is available to achieve higher
funding : carbon rations.
This project highlights the challenges funders face in meeting the market driven carbon
prices in projects, and the effect that these commercial [market driven] processes have
on the overall feasibility of them. The effect is to exclude some vulnerable residents
from being considered for help under ECO funded insulation projects.
In addition to the ECO changes, it was initially anticipated that the Green Deal (and
Cashback) could potentially contribute to any Eco funding shortfall, however, again due
to changes in the cashback scheme, the involvement of ECO funding precludes a
resident from receiving cashback. Both ECO and Non ECO funding scenarios produce
shortfalls in funding of an average £178,000. It is hoped that the assumed carbon
“value” of £45 per tonne lifetime savings could be relaxed, and re-modelled in
conjunction with an accurately priced district heating scheme.
Page | 6
Penrith
This Park Home site, located in rural Cumbria, consists of 26 homes with varying heating
systems including Oil (16), Electric (4), LPG (3) and 4 unknown systems. The site
would benefit from an ECO funded Insulation scheme in several ways.
Residents would benefit from an average reduction in heating costs of £500 per
year
Residents would enjoy better living conditions
Carbon Dioxide emissions would be reduced by over 920 tonnes over the product
lifetime (including the “in use factor” correction)
Incorporating a district heating scheme, the site would save an additional 1,965
tonnes of CO2 over the product lifetime (including the “in use factor” correction)
The projected funding shortfall (beyond the ECO contribution) is £170,000
Salford
This 62 pitch site which is reserved for members of the Showmen’s Guild, provides
pitches for current and retired show people. At present, 40 pitches are occupied, 37
with permanent structures. 3 are mobile units and so are excluded from this study. The
site faces particular challenges with funding as the homes are fed with electric sub
metering owned by the site managers. Green Deal (and the current cashback
mechanism) requires a dedicated electricity meter (with MPAN). There are various cold
related health issues among residents, and an appetite for a scheme to improve the
housing conditions through an insulation and district heating scheme. Such a scheme
has clear advantages in the form of:
Improved living conditions and the health of residents.
Residents would benefit from an average reduction in heating costs of £368
per year
Carbon Dioxide emissions would be reduced by over 1235 tonnes over the
product lifetime (including the “in use factor” correction)
Incorporating a district heating scheme, the site would save an additional 2543
tonnes of CO2 over the product lifetime (including the “in use factor”
correction)
An improvement in the look and feel of this community
The projected shortfall in funding is £212,000
Several potential funding sources may be available, but bids would be subject to detailed
discussions and development with interested parties including Salford City Council.
Possibilities include ECO (covered earlier), Council run Equity Loans, Local credit Union
Loans, Lottery Funded Grants, Government initiatives such as the Traveller Pitch
Funding3 for improving conditions on traveller sites, Council or Community Energy
Services Companies (ESCO) set up to own and administer a heating scheme, selling heat
to residents.
3
Further information available at http://www.homesandcommunities.co.uk/ourwork/traveller-pitch-funding
Page | 7
Recommendations
It is recommended that the funders perform detailed modelling according to their
procedures on these sites, and determine whether the scheme(s) can be funded
through innovative and multifaceted projects.
If financial and environmental objectives can be met – embark on a resident
engagement process and progress the physical works ASAP.
In the event where funder objectives cannot be met on park home sites, it is
recommended that the precise conditions which would have to be met to make
deployment of their ECO money viable on another site is made available, and
resources are provided to find such a site where criteria for meeting project
requirements are more favourable.
It is further recommended that once the “in house” modelling has been
completed, this information [in a suitable redacted form] be published to
disseminate the current knowledge and best practice gained through this project.
Page | 8
1 Project Background
There are an estimated 96,000 mobile homes or park homes, used as permanent
residential dwellings for 200,000 residents in the UK, spread across over 1,200 parks 4.
Park homes are often known as residential caravans. Residents are often particularly
susceptible to fuel poverty because:
The structures are thermally inefficient – they lose heat quickly
Parks are often off the mains gas network so more expensive fuels are used such
as bottled LPG (liquid petroleum gas)
Owners are of mostly over the age of 60 so are more vulnerable to the health
impacts of cold
Owners are often on fixed incomes i.e. pension
These factors combined create undesirable conditions for
residential accommodation, in terms of an energy inefficient
building, high fuel costs and limited income.
In the past, park homes have missed out on Government fuel
poverty and energy efficiency programmes, because they
cannot meet the eligibility criteria for this support, such as no
cavity walls and requiring non-standard heating technologies.
very few park homes received help from Warm Front and
none so far have received help through the Energy Company
Obligation (ECO) funding. Due to park home classification as Figure 1
‘chattels’ rather than ‘dwellings,’ they missed out on help from
the Carbon Emissions Reduction Target (CERT) funding.
Current funding through ECO and elsewhere has similarly
failed to support insulation and heating projects relating to
park home residents. Many residents purchase their
electricity through their site owner (via privately owned sub
metering) and therefore the most vulnerable are not able to
claim the Warm Home Discount because it would be too
‘administratively complex.’5 In addition, there is concern
about the commercial nature of the programme impeding
delivery to rural areas.6
The Energy Company Obligation (ECO) is a potential source of
help for residents of park homes, providing carbon as well as
social benefits to the communities. There is a lot of Figure 2
uncertainly in this area regarding guarantees for products,
appropriate methodology for measuring the impact of retrofit measures, and the appetite
of residents and park home site owners to take up these measures.
This report for npower, aims to clarify the ECO eligibility in relation to park homes, and
then applies this knowledge to two unrelated residential park home sites in England.
This project will provide npower with a valuable insight into both the issues
concerning this longstanding problem and enable them to be one of the first
organisations to provide much needed assistance to the vulnerable residents
occupying park homes.
4
Consumer focus Briefing: Park homes available at http://www.consumerfocus.org.uk/files/2010/12/Green-Deal-and-park-homes-v1.pdf
[Accessed 14/02/2014]
5
‘In terms of the eligibility being extended to include those who do not pay their electricity bill directly e.g. who pay it through their rent
on a caravan park or park home……. , due to the administrative complexity….there are no plans to include these individuals in the
proposed scheme.’ Extract from the Government response to the Warm Home Discount programme.
6
Feedback from NEA conference, Harrogate [2013]
Page | 92 Project Aims
The project will consider the applicability of ECO funding to park home insulation retrofit
situations, investigate the availability of approved products and approved installation
contractors.
In order to fully consider the available scenarios relating to ECO funding and meeting the
cost effectiveness in terms of Carbon reduction, the project questioned residents on their
appetite to be connected to a community heating scheme fuelled [most likely] by wood
chip. An indicative carbon saving is presented in each of the two surveyed communities.
Finally, the report will be presented to the funder (npower) to allow them to model the
project within ECO processes to determine cost effectiveness of a retrofit project.
It is worth highlighting at this point that after the start of this project in September
2013, the governments “autumn Statement” (on 5th December 2013) made significant
changes to the ECO scheme. The changes related to funding availability and CO2 targets
placed on energy companies for retrofit projects, which will impact on a follow on
practical installation project.
This report will follow the structure outlined below:
1. Research of insulation products & their applicability to Park homes.
2. Accreditations of products identified in (1) above and whether they can meet the
OFGEM requirements for deployment in a park home setting (BBA certificates,
Appropriate Guarantees and other applicable standards relating to ECO installations).
3. Identification of residential park home sites in eligible areas – in particular the
Carbon Saving Communities Obligation (CSCO) strand of the ECO funding.
4. Detailed study of a residential park home site in Cumbria
5. Detailed study of a residential park home site in Manchester
6. Conclusions and recommendations
3 Overview of ECO
The Energy Companies Obligation7 (ECO) is a statutory scheme for Great Britain
established by the Gas and Electricity (Energy Companies Obligation) Order 2012 (the
Order). It imposes a legal obligation on larger energy suppliers to deliver energy
efficiency measures to domestic energy users. This is realised through the establishment
of three distinct obligations:
a. Carbon Emissions Reduction Obligation (CERO):
The Carbon Emissions Reduction Obligation (CERO) focuses on the insulation of solid and
hard-to-treat cavity walls, which are termed ‘primary measures‘ under this obligation.
Other insulation measures and connections to district heating systems are also eligible
as ‘secondary measures‘ if they are promoted as part of a package that includes solid
wall insulation or hard-to-treat cavity wall insulation.
b. Carbon Savings Community Obligation (CSCO):
CSCO focuses on the provision of carbon saving measures to domestic energy users that
live within an area of low income or a rural area. The obligation promotes the
installation of insulating measures and connections to district heating systems in areas of
low income and rural areas. Under this obligation suppliers must achieve at least 15%
of their total CSCO by promoting qualifying actions to domestic energy users who are
members of the Affordable Warmth Group living in a rural area.
7
See Energy Company obligation – Guidance for Suppliers available at https://www.ofgem.gov.uk/ofgem-publications/59015/energy-
companies-obligation-eco-guidance-suppliers-15-march.pdf [accessed 15/02/2014]
Page | 10c. Home Heating Cost Reduction Obligation (HHCRO):
Under HHCRO, suppliers must deliver measures which result in cost savings and which
improve the ability of a householder to affordably heat their home. HHCRO focuses on
low income and vulnerable householders, living in private housing (generally), where
residents are in receipt of specific benefits and meet other related conditions (the
‘affordable warmth group‘ or ‘AWG. promotes the installation of measures, including the
repair and replacement of boilers, to homes in receipt of certain benefits, to reduce the
overall cost of space heating.
3.1 Applicability to park homes
Under ECO, suppliers are required to retain evidence to demonstrate that measures are
installed in accordance with the relevant standards. Full details of this requirement are
provided in section 4.32 to 4.42 of the ECO Guidance for Suppliers (the Guidance)8. The
points below summarise how the ECO requirements relating to standards apply to Park
Homes.
a) Measures referred to in PAS20309 which are installed in Park Homes must be
carried out in accordance with the provisions of PAS 2030 (as defined in PAS
2030 Annex B4 Measure BFM.4 External wall insulation)
b) In cases where Building Regulations do not apply to Park Homes, it is not a
requirement to demonstrate that measures installed comply with Building
Regulations.
4 Insulation products for use on park homes
There are many different insulation materials available on the market today, utilising a
variety of synthetic and natural products, all with differing thermal and mechanical
characteristics.
Insulation systems used for retrofitting insulation measures to standard housing is
usually achieved through injection of a foam insulation within an existing wall cavity. In
a park home situation, the cavity (if present) will be relatively narrow, and comprised of
wood, plastics, aluminium or MDF in varying proportions and configurations. In
traditional houses, cavities are generally much wider (≈50 – 100mm) allowing the
injection of a foam in sufficient quantities to improve the thermal efficiency of the
building to appropriate standards.
Alternative specialist systems are available to install insulation on harder to treat (non-
standard) housing stock. These systems are more sophisticated and more expensive,
and include internal wall insulation (IWI) or external wall insulation (EWI) systems. In
the case of park homes, the internal insulation option is not generally appropriate due to
the reduced internal space which would result from the installation of such a system,
along with technical matters relating to the mechanical fixing of the material to the
various internal finishes seen within this housing type.
The preferred system used in the majority of insulation retrofit projects undertaken with
park homes is the External Insulation option.
8
https://www.ofgem.gov.uk/ofgem-publications/75775/energycompaniesobligationecoguidanceforsuppliers-version11.pdf
9
http://www.besca.org.uk/Content/downloads/GDS/PAS%202030%202012%20Second%20Edition.pdf
Page | 11There are several different external insulation systems available. In general Figure 3
illustrates the principle of EWI, involving the mechanical fixing of the chosen insulation
(see below) to the external existing face followed by a rendered coating, usually
incorporating a reinforced mesh and a final weather proof layer with decorative finish.
Some systems involve the insulation being supplied with the initial base coat applied in
the factory which provides additional advantages including reduced installation
timescales.
Figure 3 Figure 4
Rigid board insulation systems used for external wall insulation may be of different types
providing a combination of thermal performance, thickness, strength, weight, ease of
installation, and cost. In general terms the lower cost options will require thicker profiles
to provide the same thermal performance as some more expensive products.
External wall insulation systems will incorporate these differing insulation types to
produce the necessary properties for any particular application. The use of external wall
insulation on park home properties will need to consider the unique nature of the
construction compared to more traditional construction type. Mobile homes are
generally built on a metal frame, or chassis, similar to that for static caravans and
therefore do not have the same rigidity and stability as houses built onto rigid
foundations constructed below ground level. A typical park home will be constructed on
either one or two chassis units, which are moved on wheels to the location and
sometimes bolted together to form one dwelling. The flexibility of the property must be
taken into account when designing and installing external insulation on park homes.
System manufactures’ specifications should always be consulted when selecting an
appropriate system. System manufacturers will insist that the installation contractor is
suitably qualified in the installation process and many provide appropriate training and
approval for contractors. Manufacturers usually publish a list of contractors who are
approved to install their systems. This process is essential to take advantage of any
manufacturers guarantee, and comply with ECO requirements.
Page | 124.1 Overview of Insulation Types
4.1.1 Typical rigid board insulation types
Expanded polystyrene (EPS)
Relatively inexpensive and lightweight but will require greater thickness than most other
rigid board insulation types.
EPS platinum
Similar to EPS but with graphite additives to provide increased thermal performance
Extruded polystyrene (XPS), Polyurethane (PU), Polyisocyanurate (PIR) &
Phenolic Insulation systems
These four insulation types generally have more strength than EPS or EPS platinum and
will require thinner profiles to achieve the thermal performance but at higher cost. In
addition these products will have varying other performance characteristics such as
weight, water and vapour permeability and resistance to fire.
4.1.2 Spray Insulation
Spray foams can be used to insulated the external wall in appropriate systems but is a
commonly used to improve the thermal performance of the floor of mobile homes.
These products provide good insulation properties but also due to the method of
application provide excellent draught reduction benefits too.
It should be noted that ECO funding for thermal improvement to park homes must
include floor and roof insulation in addition to wall insulation. (See section 5.1)
4.2 General Comparison of Insulation Systems
Different insulating systems using varying chemical constituents have different
characteristics. In general, a thin material with an equivalent thermal characteristic will
be more expensive to purchase than a thicker equivalent product. In most situations,
the thinner the insulation can be, the better in terms of space and appearance.
However, usually a compromise has to be reached balancing appearance, space and
cost. Figure 5 and Figure 6 illustrates the different thicknesses of insulating material of
varying constituents to achieve the same U value.
Figure 5
Page | 13Figure 6
The thickness of insulation is important for several reasons – the look and appearance of
the insulation on park homes, making windows and doors appear inset. In addition, on
high density sites, distances between residential units will be reduced which may
contravene fire and local licencing regulations. Vacuum Insulation Panels (VIPs) in the
diagram are the thinnest option, but relatively expensive at present, and don’t carry the
necessary approvals and guarantees required by ECO for installation onto park homes
(See below).
5 Product Accreditations and standards
Under the ECO rules, paragraph 8.20 states:
Quality Assurance Framework: there must be an assurance framework for the quality
of the installation and the product used in the installation. We will assess the suitability
of this framework and we may require verification through independent assessment by
an independent UKAS-accredited (or other appropriate) body.
5.1 Product Guarantees
Many manufacturers of insulation products offer their own warranties. Icynene claims to
have a warranty which surpasses all others in that it guarantees the product for the life
of the building, and is transferrable to new owners. The Insta Group offer a complete
package of insulating the walls, floor, and roof and also provide a 10 year manufacturers
guarantee; this approach is required under Ofgem rules where ECO funding is to be
provided but will require a 25 year insurance backed guarantee. To achieve this level of
guarantee the product/system will require verification through independent assessment
by an independent UKAS-accredited (or other appropriate) body.
Several products/systems are known to be utilised for park home installation, however
only during February 2014 was approval awarded to a product. The narrative below
compares the guarantees of a range of products in relation to park homes .
The Insta Group supply offer a complete park home insulation system for walls, floor
and roof under their Instaclad brand which they have developed over a number of years.
They are currently working with the Solid Wall Insurance Guarantee Agency (SWIGA) to
develop a 25 year guaranteed system for EWI. This project does not have any
independent assessment by a UKAS accredited (or other appropriate) body.
Page | 14Therm-ECO E.W.I Ltd offer a 10 year guarantee on their system but have no evidence
of independent assessment on their marketing literature.
Icynene spray foam is used to insulate the floor of park homes and will provide good
results but, in terms of ECO funding, will be an addition to EWI and roof insulation
works. Insulating the floor of a park home is particularly important as the underside of
park homes is more vulnerable to outside weather conditions due to the nature of the
construction. The only protection is usually a simple brick ‘skirt’ below the chassis but
this is often used for storage and reduces the protective effect of the ‘skirt’. Sometimes
this skirt is not present at all.
Parex Limited offer EWI systems complying with Green Deal and ECO standards,
however the BBA certificate covers timber and steel construction does not specifically
state ‘Park Homes’. This company has been involved in projects involving Park Homes
supported by funding from unspecified sources.
The Parasol Group were involved in a project in 2009-2011 where NEA oversaw the
insulation and monitoring of 87 park homes across the country with a view to the
measure being included in Warm Front. Government policy changed before the findings
of this study could be integrated into the Warm Front funding offer. This company is
endeavouring to use their system on park homes using ECO funding.
The National Insulation Association (NIA) promote the use of the Solid Wall Insulation
Agency (SWIGA) Guarantee. The Guarantee is only available for work completed by
registered SWIGA Installers who install System Certificate Holders Solid Wall Insulation
systems (i.e. who are approved and trained by manufacturers to install their specific
products or systems).
The Solid Wall Insulation Guarantee Agency (SWIGA) Quality Assurance Framework and
Guarantee for solid wall insulation provides additional peace of mind and access to
technical expertise in the event of any defect arising in the design, workmanship or
materials and is aligned to the Green Deal & Energy Company Obligation (ECO)
requirements for a 25 Year guarantee.
5.2 ECO Guarantee requirements
To be eligible for ECO funding, all wall insulation measures installed must be
accompanied by an appropriate guarantee. The criteria for an appropriate
guarantee are outlined in paragraph 8.20 of the Guidance:
8.20. An appropriate guarantee is one which meets the following criteria:
1. Financial assurance: there must be a mechanism that gives assurance that
funds will be available to honour the guarantee.
2. Duration: lasts for 25 years or longer.
3. Coverage: results in the failed measure being replaced and covers costs of
remedial and replacement works plus materials.
4. Quality Assurance Framework: there must be an assurance framework for the
quality of the installation and the product used in the installation. We will assess
the suitability of this framework and we may require verification through
independent assessment by an independent UKAS-accredited or other
appropriate body.
Page | 15A list on the Ofgem website has details of guarantees which have been assessed and
considered to meet these four criteria. There is currently (March 2014) one guarantee
on the list which includes the category of Park Home External Wall Insulation Systems. 10
The applicable guarantee is - Kinnell ECO Guarantee through the QANW brand issued by
Warranty Services Ltd on behalf of Guarantee Protection Insurance Limited 37 Carrick
Street Ayr KA7 1NS
The following illustrates the current process currently underway to identify suitable and
appropriate EWI systems for use on park homes
1. Manufacturers/ system designers agree specification for use on park homes
NEA are aware of at least four manufacturers/system designers currently working
together with Kinnell and Ceram to developer specification for external wall
insulation on park homes. These are:
Wetherby Building Systems Limited
SPS Envirowall Limited
Alsecco (UK) Limited
Alumasc Exterior Building Products Limited
2. Independent assessment by UKAS-accredited or other appropriate body
As mentioned above, CERAM are currently working with the manufactures/system
designers to produce an agreed specification for EWI suitable for park homes.
Existing products/systems of EWI used on more traditional construction types are
known to have been accredited by independent UKAS accredited organisations. A
search of the British Board of Agrément website indicates that 47
products/systems have been accredited for use as ‘External Wall Insulation’ the
majority of which are for masonry wall construction. A refined search suggests
just five where the system is approved for timber frame construction but again
this is on more traditional construction which does not include park homes.
3. Appropriate guarantee
Again as mentioned above, a Kinnell ECO Guarantee through the QANW brand
issued by Warranty Services Ltd was approved in February, and manufacturers
are finalising the training and approval of contractors to install the systems on
park homes
4. Ofgem Approval
Ofgem currently list the Kinnell scheme (in point 3 above) as an appropriate
guarantee.
5.3 Overview of requirements
ECO measures can be recommended for Park Homes in a report compiled by a chartered
surveyor or, where one is available, in a Green Deal Advice Report. (Note that it is
insufficient for measures to be recommended solely through an in an Energy
performance Certificate). The requirements of the chartered surveyor reports are
outlined in paragraphs 4.26 – 4.29 of the Guidance – in summary this states that
1. Representative samples of homes can be used to represent the range of homes –
but it will be necessary to visit each property to establish some key facts.
2. Appropriately qualified surveyors are necessary to comply with OFGM
requirements.
10
https://www.ofgem.gov.uk/ofgem-publications/59018/ecoappropriateguaranteesv115.pdf
Page | 16The ECO Order stipulates that, where it is possible, cost or carbon savings should be
calculated in accordance with SAP or RdSAP.
Where questions arise regarding the best approach to completing SAP/ RdSAP
assessments for ECO, these should be addressed to the software providers in the normal
way, for the following reasons:
a) There is already a process in place whereby software providers can develop and
seek BRE approval for new conventions for completing SAP/ RdSAP assessments;
and
b) If Ofgem were to intervene in this process, it may lead to inconsistencies in how
energy assessments are performed.
If it is deemed that the cost or carbon saving of a measure cannot be calculated using
SAP or RdSAP, obligated suppliers may submit an appropriate methodology for Ofgem
approval.
In the case of Park Homes, it is expected that savings achieved by insulation measures
can be calculated using SAP.
RdSAP is in the process of being revised to include park homes as a build type. RdSAP is
capable of being used for park home surveys, following guidelines published by BRE, and
has been used in the compiling of the subsequent sections of this report.
Under CERO - solid wall insulation measures must bring the U-value of the wall to
0.30W/m2K does not apply to Park Homes, as per paragraph 5.16 of the Guidance:
5.16. Under the Order, Solid Wall Insulation (SWI) is defined as:
1. Internal or external insulation which lowers the U-value of the treated walls to
0.30W/m2K or less; or
2. In the case of a mobile home, internal or external insulation applied to the
ceiling, floor or walls which lower the U-value of those parts of the mobile home
to which the insulation is applied.
In order to enter actual U-values into RdSAP, there must be evidence that they have
been calculated in accordance with Appendix S of RdSAP 2009 version 9.91 (Applicable
from April 2012). The following is an extract from this document (S5):
U-value entry (walls, roofs, floors)
The U-value is that of the whole element, including any added insulation. Documentary
evidence applicable to the property being assessed (see convention 9.02) must be
provided and recorded if overwriting any default U-value. This evidence shall be either:
- relevant building control approval, which both correctly defines the construction in
question and states the calculated U-value; or
- a U-value calculation produced or verified by a suitably qualified person.
Evidence of suitable qualification is through membership of a recognised U-value
calculation competency scheme (BBA/TIMSA (UK)), OCDEA membership (England &
Wales, Northern Ireland) or any other scheme formally agreed between Accreditation
Schemes/Approved Organisations and Government.
Page | 175.4 General Contractor Requirements
Under ECO, it is necessary to install 100% of a measure, as per paragraph 4.45 of the
Guidance:
Suppliers must install 100 percent of a measure at premises unless there are
reasonable grounds for not doing so.
For the installation of EWI on a Park Home, as per 5.16 of the Guidance, 100% of the
measure includes the insulation of the ceiling, floor and walls.
Examples of reasonable grounds for not installing 100% of a measure are provided in
paragraph 4.47 of the Guidance:
Planning restrictions, inability to gain access to necessary work areas, or lack of
consent from the domestic energy user, are some examples of what we would
consider to be reasonable grounds for not installing 100 percent of a measure.
We also consider reasonable grounds to include where a measure has already
been partially installed. Reasons relating to the cost of installing the measure
alone will not be accepted as reasonable grounds for suppliers not installing 100
percent of a measure.
Paragraph 5.16 (b) states that in the case of a mobile home, IWI or EWI applied to the
ceiling floor or walls must reduce the U-value of those parts of the mobile home to which
the insulation is applied. Paragraph (a) provides a target U-value of 0.3W/m²K
EWI installers are accredited to install the various systems by the product or system
manufacturers. This usually involves the contractors undergoing appropriate training on
the particular system to be installed. As the details of the system to be used on park
homes have not yet been decided it follows that no contractor can, as yet, be approved
to install a product on a park home, and comply with ECO requirements.
The EWI systems currently available for general housing (excluding park homes),
currently have national networks of ‘approved contractors’. It is expected that certain of
these contractors will be able to install EWI on park homes when the design standards of
the system has been agreed and the contractor has satisfied the requirements for
training from the system manufacturer.
5.5 Surveyors Qualifications
In the ECO guidance for suppliers, Paragraph 5.15 states that where a report is required
on a park home, an appropriately qualified chartered surveyor working within those
qualifications is used.
The Park home must be surveyed by an appropriately qualified and experienced surveyor
who is a member of the Royal Institute of Chartered Surveyors (RICS)
It is thought that in the recent upgrades to RdSAP software, a domestic energy assessor
should be able to produce a RdSAP survey certificate which meets OFGEM requirements
for carbon savings without the need to engage a RICS member, as long as the date of
manufacture can be accurately determined for the park home being surveyed.
Page | 185.6 Insulation System Compliance Summary
In order for an insulation product to be eligible for use under an ECO funded scheme, the
following conditions should be met
1. There must be an appropriate guarantee from the manufacturer, backed up by an
insurance scheme, which covers the product for 25 years.
2. The product must be covered for use on park homes by an appropriate standard
such as BBA
In order for a project to be eligible, the following criteria must be met:
1. The Park home must be surveyed by an appropriately qualified and
experienced surveyor who is a member of the Royal Institute of Chartered
Surveyors (RICS)
2. The product must be specified by the above
3. The product(s) local availability
4. The modelled carbon saving must be met (varied between funders obligations,
priorities and OFEGM guidelines
In order to be funded:
1. The funder must agree that the project meets their cost effectiveness (& CO2)
criteria,
2. The area is in an ECO eligible area for the funding strand being considered
(HHCRO, CSCO rural etc.)
Overarching Considerations
1. The residents must be in agreement for a scheme to be implemented on their
property
2. The site owner must be in complete agreement for a scheme to be implemented
on their land.
3. Existing heating systems need to be established to inform CO2 savings
4. OFGEM need to authorise the project
5. Look at alternative supplementary ways of increasing cost effectiveness such as
installing renewable generation, or renewable heating.
Page | 196 Identification of Appropriate CSCO eligible park home
residential sites
A 2002 report by the Office of the Deputy Prime Minister estimated that there are some
69,000 households currently residing in park homes in England and Wales, representing
a population of approximately 114,000 adults and 2,400 children.
2011 census data tells us that there are 100,228 temporary living structures. These
include park homes and house boats. Their geographical distribution is offered in
Appendix 1
As part of this study, NEA was required initially to identify and cress reference residential
park home sites in England with the tables of CSCO areas. After the government
Autumn Statement in November 2013, the preference for a site being in the CSCO
eligible area was relaxed.
Investigations with a number of commercial and public sector organisations have
revealed that there is no comprehensive list of UK based park home sites. In
addition, the Department of Communities and Local Government (CLG) commented that
they have no intention of compiling such a list.
To fill this gap and support npower in identifying sites NEA employed two methodologies
I. Compiling a list of park home sites, from information from British Homes & Home
Parks Association (BH&HPA), the Independent Park Homes Advisory Service (IPHAS),
UK Parks.com, local authorities and contractors. 1,300 park homes sites were
identified and NEA is compiled data to match the park home sites to LSOA areas and
links those to the CSCO eligible areas. We are also following up with the local
authorities as described below.
Note: some of the 1,300 sites initially identified were later found NOT to be
residential sites
II. The project team used known contacts as a starting point to identify sites that may be
eligible and, importantly, where we will have a personal and trusted link e.g. with
local authorities.
6.1 Sites Identified through desk based Activity
Working with the individuals and organisations mentioned above NEA has obtained post
codes of more than 1,300 park home sites throughout England. These post codes have
been used to plot locations on the map in Figure 7 show as a red diamond. Please note
that in many areas two or more sites are located in close proximity. Due to the scale of
map one diamond may represent several park home sites. These 1,300+ postcodes
have then been converted to the appropriate LSOA area references and these then
compared with those in the DECC database of CSO eligible areas. This has resulted in 18
sites, indicated by green squares on the map. Again identified sites may be located in
the same area and be represented by a single point.
Page | 20Figure 7
Identified sites
Sites in CSCO area
Page | 21Residential park homes sites include those occupied by the showman and traveller
community. The map in Figure 8 indicates locations of these sites which provide a total
of nearly 5,000 pitches of which over 90% are residential. Some of these sites have
been included in the 1,300+ sites mentioned above. Some have been also identified as
located within CSCO areas as shown in the Table 1. The showman industry traditionally
used temporary sites during the year and only returned to ‘winter quarters’ during the
‘off season’. Temporary sites are now not generally available: this combined with the
need for the children to received regular education has resulted in permanent residential
sites. Some of these sites will still however involve residents in fully mobile caravans
(capable of being towed around the country) whilst other contain homes classified as
mobile but generally static. Other sites contain a mixture of both.
Figure 8
Page | 22Table 1 shows 17 sites (out of the initial list of 1,300+) sites (shown in appendix 1)
which are within a CSCO area. Four are believed to have mains gas; four are gypsy and
traveller sites where there are few (if any) static homes, four are predominately holiday
home sites. This left five potential sites for further consideration to be part of a retrofit
project (Shown with white background in the table). All of these are privately owned.
The Showman’s Guild was first established in Salford, Manchester, and still represents
the interests of the Travelling Show-people Community all over the UK. The Fairways
Caravan Park has therefore been selected as one of the case study sites.
The second site for detailed study is a residential site in the district of Eden, Cumbria.
Eden has major fuel poverty, and the Local Authority is known to be actively pursuing
the feasibility of insulating park homes in their area.
Mains
SITE NAME ADDRESS 1 Address 2 County POSTCODE STOCK
Gas
West
Broadstone Caravan park Sherriff Lane Bingley BD16 3LT 37 Yes
Yorkshire
West
Paley Road Caravan Park Paley Road Bradford BD4 7EN
Yorkshire
Mary Street Caravan West
Mary Street Bradford BD4 8TF 28
Park Yorkshire
Kandy Park Rope Walk Littlehampton West Sussex BN17 5DE
Harbour View Park Rope Walk Littlehampton West Sussex BN175DQ 22 No
Sunnyhurst
Sunny Hurst Park Blackpool Lancashire FY4 2HR 44 Yes
Avenue
Ravenscraig
Brookdale Park Little Hulton Manchester M38 9BB
Road
Duchy Road Caravan
Duchy Road Salford Manchester M6 6WR
Park
Clarence
Fairways Caravan Park Salford Manchester M7 1GY 25
Street
119 Church
Hall Hills Park Boston Lincolnshire PE21 0LG 22 Yes
Road
Eastview Chapek St
Four Seasons park Lincolnshire PE24 5YW 79 No
Close Leonards
Seabreeze Sea Lane Ingoldmells Lincolnshire PE25 1PL 33 No
King Fisher / Small Grove Ingoldmells Lincolnshire PE25 1PG
Bridge Park Doniford Watchet Somerset TA23 0TH 24 No
Sunnybank Doniford Watchet Somerset TA23 0UD 23 No
Eastern Green Caravan
Eastern Green Penzance Cornwall TR18 3AY 86 Yes
park
Crimdon Dean Holiday Blachall County
Hartlepool TS27 4BW No
Park Colliery Durham
Table 1
Page | 236.2 Tenure
Background information to a Commons Select Committee enquiry in June 2012 stated, ‘The vast
majority of park home sites are privately owned, with a small number owned by local authorities.’
Other stakeholders have highlighted that there are very few local authority owned sites. We are
aware of some in Staffordshire and Oxfordshire and continue to work with the LGA and individual
local authorities to seek out these sites.
6.2.1 What the issues are with private site owners?
The following issues with private site owners have been noted in the literature and through NEA’s
experience. Where the barriers have been inferred by NEA rather than directly expressed, this is
made clear. Where solutions or steps to solutions have taken place, these are also noted.
Barriers Solutions
Refusal to allow access to site, Repeated meetings with different stakeholders including
largely reasoned through residents, contractors, local authority and MP
concerns noted below
Concern about quality of work Meetings with contractors, case studies of past work, direct
contact numbers and guarantee for product and labour
Loss of space therefore loss of Demonstrated that new product had better fire rating therefore
earning potential enabled more homes on the site and therefore potentially
higher income
Concern that insulation would Reassurance from local authority that they support the work and
jeopardise the ‘mobile’ nature of the license will not be jeopardised
park homes and therefore risk
the site license
Insufficient stability in the hard
standing
Site owner supplies LPG Demonstrate alternative revenue from FiT and RHI
therefore loss of potential
revenue (inferred)
Elements of the site don’t An honest discussion can be proposed to provide help to rectify
conform to regulations therefore elements of the site that do not conform to regulations.
access is refused (inferred) New legislation can also be invoked.
The Mobile Home Act 2013 provides for more stringent powers
for Local Authorities to take action. In particular, section 5
outlines additional and clearer powers for local authorities to
take emergency action if a site owner has not taken previously
required compliance action, which would result in harm to the
health of the resident. Local authority officers are also able to
instruct other parties to carry out work to ensure compliance.
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