Through regular contact with ministers, MPs and civil servants, and responding to key consultations the BESA makes its voice heard in the 'corridors of power'.
The Association also brings its influence to bear on opinion-formers across the wider construction industry and among key construction clients.
Representatives from across the BESA Group companies work closely with government, actively imputing on key issues within the industry. We are particularly proud of our legal and commercial director Rob Driscoll who is working alongside the government as part of an advisory panel to ensure that by 2020, £1 of every £3 invested by Whitehall in goods and services goes to small and medium-sized enterprises. If achieved, the target would mean almost £3bn of new business up for grabs each year, either directly or through the supply chain.
There are always ways in which you can support and get involved with the key issues and topics facing our sector - contact us to get involved.
VAT fraud in labour provision in construction sector
The Government have launched a consultation on options for combatting fraud on labour provision in the construction sector. The consultation is likely to affect many BESA Members. We are encouraging Members to take part and have their say.
The consultation will consider a range of policy options to prevent supply chain fraud in the sector, including a VAT reverse charge and changes to the qualifying criteria for gross payment status within the Construction Industry Scheme. The introduction of a VAT reverse charge in construction would mean that you must account for VAT on services you buy from businesses who are based outside the UK.
The consultation relates directly with BESA Members who supply predominantly labour services to those in the construction sector. Click here to view the consultation documents.
We are looking to collate views and respond on behalf of BESA members and are looking to directly feedback on the proposals commenting on which proposals will or won’t work, and which will be difficult and costly to operate in practice. If you have any comments, questions or concerns please contact Rob Driscoll or Gari Sibanda - please send your feedback before 21 April 2017.
NICE (National Institute for Health and Care Excellence) recently issued draft guidelines covering road-traffic-related air pollution and its links to ill health.
It aims to improve air quality and so prevent a range of health conditions and deaths. The draft recommends taking a number of actions in combination, as multiple interventions, each producing a small benefit, are likely to act cumulatively to produce significant change. This includes changes to driving style, selection of vehicles by the public sector, and the introduction of cycle lanes, clean air zones and congestion charging.
What was THE BESA's response
The BESA believes that buildings have the potential to provide “safe havens” to mitigate many of the harmful impacts of air pollution. People spend over 80% of their time within buildings (87% National Human Activity Pattern Survey Klepeis et al 1995). 20 hours per day (Royal Institute of British Architects RIBA 2016). It therefore makes sense to protect them during these periods. This can be achieved by the design and installation of ventilation systems that filter incoming air. In order to design ventilation systems to mitigate air pollution, a base line of pollutants should be taken in much the same way as a noise impact assessment does to establish ambient noise levels. Typically planning approval sets a requirement to design at 10dB below ambient so that a new building does not contribute to additional noise pollution.
In order to design ventilation systems to mitigate air pollution, a base line of pollutants should be taken in much the same way as a noise impact assessment does to establish ambient noise levels. Typically planning approval sets a requirement to design at 10dB below ambient so that a new building does not contribute to additional noise pollution.
Once installed it is vital that systems are correctly commissioned and maintained. Air pollution is not visible so unless there is a monitoring system installed, poor air quality is not detected systems can therefore fail to deliver clean air to the building without the occupants becoming aware of this.
At our own offices on the Hammersmith Road in London where the BESA are tenants, it was only by installing air quality monitoring equipment that we detected spikes in poor air quality throughout the day. Investigation revealed the air intake for the ventilation system is sited at the entrance to the garage; cars sit at the gate idling waiting for it to open. The problem was compounded by the removal of the air filters from the ventilation system, as they were clogging frequently and impacting on the performance of the fan.
In future a planning approval should include a requirement to install air quality monitoring equipment and to make the results public. This would alert occupants to the issue and provide an opportunity to raise general awareness of the wider air quality problem.
Employers in England may be eligible for a grant towards to fund taking on apprentices. Apprenticeship reforms have caused confusion and uncertainty as to how the new system will work and who will be eligible to receive the funding.
WHAT THE BESA WANTS
A start date for the new system
Funding bands – a larger number of narrower bands to help employers understand how much they are expected to pay as a maximum for the delivery of an apprenticeship and help set parameters for negotiating terms with training providers
A simpler funding system for apprenticeship frameworks
Support for small employers training 16-18 year olds and extra support for apprentices aged 16-18, 19-24 care leavers and those who have an education health and care plan
Support for English and maths training – to support technically demanding apprenticeship.
Cross border training and re-training
Transferring of digital funds
We have already seen significant results following our lobbying work in regards to apprenticeship funding. The government has confirmed a huge boost for the funding and in October 2016 announced a raft of new measures to help employers take on more apprenticeships.
The BESA is committed to raising awareness of the links between outside air pollutants and indoor air quality (IAQ) and to persuading government to re-focus on this crucial issue. In practical terms, it seeks an appropriate amendment to the Building Regulations, and for guidance on planning applications in respect of schools and hospitals to include a requirement for a broad-based pollution check to be undertaken.
A consultation for an updated version of BB101 'Guidelines on ventilation, thermal comfort and indoor air quality in schools' has been completed with BESA representatives responding to ensure that our members, who are responsible for the majority of the work within the education sector, will be fairly considered.
Our main concern is whether our members would be able to comply with proposed design parameters without ensuring the building is sealed, mechanically ventilated and air conditioned. Whether it is possible to get an iterative loop in place, if all the standards are complied with simultaneously, making it extremely expensive to achieve and prove compliance, a task that falls to the contractor without giving the certainty of a single standard to prove against.
As part of Brexit, the UK’s departure from the European Union, the Government released a green paper proposing their industrial strategy to address the long-term challenges faced by the UK economy. The draft outlines their aim is to improve living standards and economic growth by increasing productivity and driving growth across the whole country.
The green paper was drafted to propose the UK’s future industrial strategy and opinions were sought to encourage a collaborative conversation about the skills, research, infrastructure and the other things needed to drive long term growth in productivity.
The BESA teamed up with the ECA (Electrical Contractors’ Association) to respond to the consultation and ensure that the both of our sectors are fairly represented in the industrial strategy plans and outline how the engineering services sector can contribute to a successful future for UK industry, commerce and society.
Our response includes the key observation that engineering services delivers not just the construction of assets (generally some 10% of the overall cost of built assets), but is then predominant in the operational performance of that asset, which can account for a further 80% of the whole-life cost of that asset. To achieve best value during the operational life of the UK’s built assets, the commercial models of construction and asset operation must be integrated. This requires the active and early involvement of engineering services expertise to reduce whole-life costs and increase the functional and sustainability performance of built assets.
We are looking to work in partnership to achieve significant and highly constructive change. We therefore call on government, working in a sector partnership with the engineering services sector to:
"The Scottish Government has designated energy efficiency as a National Infrastructure Priority, the cornerstone of which will be Scotland’s Energy Efficiency Programme (SEEP) – a 15 to 20 year programme. The Programme for Government commits to investing more than half a billion pounds to SEEP over the next four years setting out a clear commitment to develop this programme with substantial annual funding. By 2035, through SEEP we will have transformed the energy efficiency and heating of our buildings so that, wherever technically feasible, and practical, buildings are near zero carbon."
What the BESA wants
Many of the solutions and in particular the initial energy survey are far too high level and simplistic. This leads to unrealistic expectations on behalf of the consumer and often does not result in the correct solution.
Any process needs to be long term, consistent, simple and low cost to operate, offer sufficient customer protection (it is almost impossible to protect some customers where fraud is perpetrated) and encourage skilled and competent contractors to participate.
The single most effective energy efficiency measure any government could take would be to implement mandatory assessments post-occupancy of a completed building that demonstrate that any building works requiring Part L compliance actually achieve the calculated efficiency gains. This is already a requirement of Part L but has never been enforced.
Read our full response by clicking here.
Successful implementation of district heating needs to start on a local level with community networks where achievable. For example, Local Authority support has been proven to be vital for the success of district heating. Authorities should work together where the need arises to ensure district heating networks are well matched to the demand zones. This should be judged on a case by case basis.
The schemes need to be focused on delivery and not promised delivery and as such should focus on the actual carbon/energy performance of the building delivered and not a theoretical value deduced from poorly constructed calculation within the building regulations (no consideration for dynamic weather conditions, unregulated energy usage etc.)
The measure of success of the principals needs to be based on the true output and not theoretical inputs. Use simple metrics like KG CO2/KWh with cheap sub metering and data logging - this is cost effective.
Demand/market risk can be minimised by successfully identifying anchor loads (schools, hospitals, leisure centres etc) with known and predictable heat load demands for district heat networks to be based around. This will de-risk the network and the operator by providing confidence on a return on investment rate.
Performance risk can be reduced by focussing on energy efficiency in buildings and ensuring technical standards ensure that district heating networks are designed, installed, commissioned, maintained and operated appropriately to maximise efficiency.
Construction risk reduction through use of qualified and certified contractors e.g. BESA members.
Click here to read our full response.
The Standard Assessment Procedure (SAP) is a methodology used to assess the energy performance of homes and thereby helps deliver many of Government’s energy and environmental policy objectives.
Click here to see the Government's consultation document.
what the BESA wants
The BESA responded to the consultation in January 2017 - highlighting that although the SAP calculation process may be a best practice process for estimating the performance of a building, however, it only represents a theoretical model and a “promise” that this will be delivered.
Click here to read our full response.
Prompt payment helps SMEs to meet community benefit requirements by being able to employ more people or increase their intake of apprentices. As an industry we train more apprentices than any other in the construction industry (Over 3,500 electrical apprentices are currently in training) and to help government meet their targets of employing more Modern Apprentices our Members require the certainty of prompt payment.
The BESA position is that we fully support fair payment policy across the UK within the construction industry. However, PBAs are only one of many policy initiatives within the fair payment landscape.
WHAT BESA WANTS
Clear guidance that the Scottish Government will set targets for using PBAs and monitor their use.
Encouragement for bodies to use PBAs.
A clear and detailed timetable for increasing PBA coverage to below the proposed thresholds.
Tier 3 contractors should have an automatic right to be a beneficiary if the value of their sub-sub-contracts is at least 1% of the main contract value.
In October 2016 Derek Mackay, Scotland’s Cabinet Secretary for Finance, announced that Project Bank Accounts will be used as the preferred method for improving payment conditions and speeding up cash flow on all public sector projects over £4m in Scotland.
Almost 10 years after the introduction of the Gas Safe Register, HSE (Health and Safety Executive) are seeking feedback from stakeholder groups about what the industry would like to see from GSR going forward.
A survey was conducted to allow those in our sector to voice their opinions on the register and how it will working moving forwards.
HSE have created a presentation on the Gas Safe Register click here to download your copy.
HSE is consulting on changes to the Gas Safety (Installation and Use) Regulations 1998 (GSIUR).
The proposed changes are:
Amendments to regulation 36(3) to
Disapplication for compressed natural gas (CNG) filling stations fed by a dedicated metered gas supply from the majority of the requirements of GSIUR, bringing them in line with other industrial premises.
Amend GSIUR to incorporate the existing exemption certificate no.1 to regulation 26(9)(c), which sets out the circumstances where engineers can carry out alternative safety checks when the prescribed tests are not possible.
Designation of Service Layer Engineers (SLEs) as a “member of a class of persons” under regulation 3(3) (this is an administrative change, not a change to legislation).
Below are some of the key issues the building engineering industry are currently facing and what we are doing about them.
There is a clear need for an increase in the use of electronic procurement, tendering and payment across the public sector. BESA members routinely report that, when responding to public sector tenders, they are required to pay registration fees before inputting into numerous procurement portals information they have provided many times before. This is not only time-consuming, but also involves additional cost that is inevitably passed back to the client.
The BESA is convinced that its members’ financial stability can be jeopardised by the lack of transparency in and prolonged nature of the prevailing cash flow cycle in the construction supply chain. To date, the impact and measurement of initiatives such as project bank accounts, prompt payment codes and revised late payment legislation have been hampered by government under-investment in digital systems and processes.
While it welcomes the progress that has been made in the integration of digital passport control, DVLA transactions and other citizen-focused services, the BESA wishes the same priority to be attached to, and the same investment to be made in, the management of the public sector’s property portfolio.
The merger of the government’s Contracts Finder and Construction Pipeline services into a centralised online procurement portal system would allow public sector clients to manage the supply chain at project and strategic level through analysis of “big data”. This would enable public sector payment requirements to be verified throughout the supply chain, and allow suppliers to improve their procurement performance by allowing them to study their procurement failures at both a micro and a macro level.
At the same time, an online payment management system would resolve the problem of how to implement and manage payment processes, making payment monitoring clearer and simpler. Such a system could – once public bodies were awarding contracts automatically – issue a payment schedule to the registered supplier, stating when payments become due and the period for their discharge.
The online payment schedule would also set out the anticipated throughput of cash, based on the terms of the contract award and pricing mechanisms, providing digital transparency of cash flow. The BESA has proposed that, in circumstances where payments are late (ie, beyond the 30-day public sector deadline), the system would automatically include the interest due.
The BESA has welcomed the government’s lead in driving forward digitisation through its BIM strategy, which is designed to deliver real savings through greater efficiencies in the construction process brought about by the increased use of building information modelling. However, the specialist contractors that design and install the systems which make buildings work often waste a great deal of time on the completion of pre-qualification questionnaires and, once tenders have been won, in chasing payment.
The BESA is taking every opportunity – including meetings and communications with ministers, civil servants and officials and responding to appropriate consultations – to put across our core message: that inefficiency in business processes equate to waste; and that digitisation will deliver savings for the public sector, reduce cost and increase productivity for the construction industry.
Further information from Rob Driscoll at firstname.lastname@example.org
In November 2014, the House of Commons Environment Audit Committee published the Action on Air Quality report, a key recommendation of which was for the installation of air filtration in all school buildings close to pollution “hotspots”, along with changes to the National Planning Policy Framework and guidance designed to encourage local authorities to prioritise indoor air quality (IAQ) when granting planning permission, especially for schools and hospitals.
The report warned of the negative impact on building occupants of diesel vehicle emissions, nitrogen dioxide (NOx) and particulate pollution. It went on to describe the current state of affairs as a “public health crisis” that caused almost as many deaths as smoking – ie around 29,000 every year – and pointing out that the UK’s incidence of asthma is the highest in the developed world.
Since long before the committee’s report, the BESA had been highlighting the fact out that polluted air does not mysteriously disappear when it reaches a building. On the contrary, it has a catastrophic impact on IAQ.
The government’s response to the committee’s response was disappointing. It dismissed the call for air filtration with the comment that “the Building Regulations include requirements to provide adequate means of ventilation and apply when ‘building work’ is carried out”. However, the regulations are not retrospective and do not require work to be undertaken in existing buildings.
On the call for local authorities to prioritise IAQ, the government stated that it “does not consider that there is a need for additional planning guidance or Building Regulations, given the current level of protection”, but that it will keep the matter under review.
The BESA is committed to raising awareness of the links between outside air pollutants and IAQ and to persuading government to re-focus on this crucial issue. In practical terms, it seeks an appropriate amendment to the Building Regulations, and for guidance on planning applications in respect of schools and hospitals to include a requirement for a broad-based pollution check to be undertaken.
In the wider context, the BESA is particularly concerned that the problem of poor IAQ is often “hidden”, due to the low levels of monitoring currently being carried out, and is urging government to provide funding assistance to building owners/managers to allow effective monitoring equipment to be installed.
The BESA also believes that there should be a duty on developers to measure the quality of the prevailing outdoor air at the outset of a construction project, so that an informed assessment can be made of the likely magnitude of the problem once the buildings have been completed, the methods required to address such issues, and an allowance made for the attendant costs.
The BESA has formed a specialist Indoor Air Quality strategy group – membership of which comprises manufacturers and consulting engineers as well as contractors – to build relevant contacts within local and central government,
and to develop alliances with pressure groups such as the Close the Door initiative and research organisations including Kings College London.
The strategy group is also lobbying officials at the relevant government departments to extend their focus from outdoor to indoor air quality – and has submitted a response to the Environment, Food and Rural Affairs select committee’s recent enquiry into air quality in the UK.
Further information from David Frise at email@example.com
The BESA has been encouraged by the positive stance being taken on the future of apprenticeships, and is pleased that the government has pledged to create three million apprenticeships by 2020.
Of particular importance is the Trailblazer programme, in relation to which the BESA has brought together representative groupings of its members to developing up-to-date apprenticeship standards and assessment plans for the building engineering services sector which reflect current business requirements.
The BESA also recognises the recent announcement of the introduction of an apprenticeships levy as a real “game changer” in the manner in which apprenticeship training will be funded and promoted.
Through its sector-specific training organisation, the BESA has managed the training of over 10,000 apprentices and introduced them as skilled personnel into building engineering services. In addition, it has raised the competence levels of many of the industry’s existing workers, allowing them to gain recognised qualifications that reflect their prior experience.
All employers in England, Scotland and Wales with a pay bill of more than £3m will pay the levy, based on 0.5% of the pay bill, thereby generating by 2019/20 a statutory fund of £3bn in England alone to support apprentice training.
While access to what amounts to a national apprenticeship training fund will provide many employers with the financial means to address skill shortages head-on – which is critical to business growth, ensuring higher technical standards and tackling climate change – the BESA has two areas of concern.
Firstly, there remain aspects of the proposed arrangements which remain unclear – for example, how small and medium-sized enterprises (SMEs) will access the funding which the levy makes available, what government support they will otherwise be able to access directly for apprentice training, how a larger employer’s unused funding will be used, and whether the funding generated by a given sector of industry will remain within that sector.
The BESA believes that:
Secondly, the BESA believes it would be foolhardy to overlook the many unskilled workers in the industry, who came into the sector during the recession, have missed out on formal training and could be offered apprenticeships or the opportunity to upskill through a process of experienced worker assessment.
The BESA is confident that, working in conjunction with its industry-specific training organisation, it can address the difficulties SMEs may encounter in engaging with the apprenticeship levy.
The BESA welcomes the appointment of Nadhim Zahawi MP as apprenticeship adviser to the Prime Minister and the establishment of the Institute for Apprenticeships – and looks forward to working closely with both to ensure that the building engineering services sector benefits from the introduction of the apprenticeship levy and that its members receive effective support in addressing skills shortages.
Further information from Tony Howard at firstname.lastname@example.org
The energy efficiency requirements of the Building Regulations are set out in Part L of Schedule 1, and in a number of specific regulations. However, these have never been actively enforced (despite being regularly upgraded), owing principally to a reduction in the number of the local authority building control officers with whom the duty of enforcement lies.
In consequence, the current system for ensuring that buildings meet energy performance requirements is demonstrably failing – with the result that the UK is required to build more power stations and increase gas capacity to cope with the higher-than-anticipated demand.
The BESA favours the wholesale of scrapping of Part L, and its replacement by a regime which focuses on actual building performance – and is less prescriptive as to how that performance is achieved.
The BESA is convinced that the current Part L – along with local planning requirements for onsite generation – drives perverse design decisions, such as biomass installations in cities far from the fuel source and combinations of technologies that are impossible for end users to operate efficiently.
A more imaginative approach to reshaping the built environment and mitigating its environmental impact would be to set maximum energy and carbon levels per m2. This would provide designers with the flexibility to select the most suitable solution for each application, rather than simply meet the requirements of a SAP or SBEM calculation – and, in turn, ensure that buildings deliver specific lifetime energy, carbon-saving and other benefits.
The BESA is working to raise awareness of the limitations and unintended consequences resulting from the Part L regulations.
Most recently, it has expressed its views to Lord Bourne of Aberystwyth – the minister responsible for the regulations at Department of Energy and Climate Change – and will be continuing to raise the issue with relevant ministers, MPs, civil servants and other opinion-formers.
Further information from David Frise at email@example.com
With an increasing amount of energy going into managing physical risk in the building engineering services industry – are we getting the health and safety balance right?
The stigma around mental health can be considered one of its biggest boundaries.
Mental health is a growing issue for the building engineering industry as operatives and business owners regularly face highly pressurised work environments, tight deadlines and slim profit margins – all of which have the potential to build up stress levels. Many may feel that there is no room to fail, or even pause for breath, and just soldier on keeping stress or even a gradually deteriorating mental state to themselves – this is where action is needed. In order to combat this problem we must help others, break down the stigma surrounding the issue and let everyone know mental health is not a taboo subject and that it is ok to talk about it and seek help.
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