Written evidence submitted by Oil Heating Consultancy Services Ltd (DHH0018)

1. What has been the impact of past and current policies for low carbon heat, and what lessons can be learnt, including examples from devolved administrations and international comparators?

When measured against published targets, there is little evidence to date that government policies to deploy low carbon heat have been successful especially off the gas grid with less than 1% of oil heated homes converting to low carbon heating solutions via RHI. This is I believe because policy is targeting a market sector where the preferred solution of heat pumps is not an appropriate solution for existing oil properties which in the main are classed as “hard to treat” due to their age and design having very poor levels off insulation for which there is no easy or cost effective solution.

2. What key policies, priorities and timelines should be included in the Government’s forthcoming ‘Buildings and Heat Strategy’ to ensure that the UK is on track to deliver Net Zero? What are the most urgent decisions and actions that need to be taken over the course of this Parliament (by 2024)?

Consumers are most likely to adopt energy efficiency and low carbon measures that are affordable and cause least disruption. Industries will invest in and roll out new affordable solutions but a clear message is needed to be given by government. To this end Government needs to:

• amend and republish Approved Document L (Requirement L1) worded so as to prohibit the installation of any new or replacement boilers combusting fuels with a CO2e level above that of electricity (currently 0.233 kg CO2e kWh). This is a simple, clear and manageable way of encouraging traditional industries to invest and change in new fuels and technologies for end users whilst providing a benchmarked transition towards 2050 net carbon zero.
• Realign L1 CO2e max with the electricity grid decarbonisation achieved every 5 years.
• Define a CO2e max level below which solid, liquid and gaseous fuels can be legitimately described as being net carbon zero i.e. 0.50 kg/CO2e kWh.
• Provide Clean Heat Grant funding for all and any decarbonisation technology and/or fuel solution which achieves “net carbon zero” status.

3. Which technologies are the most viable to deliver the decarbonisation of heating, and what would be the most appropriate mix of technologies across the UK?

Consumers and industry will only adopt decarbonisation measures which are affordable and applicable to the varied types and ages of housing. Simply specifying a solution by technology is anticompetitive and as has been demonstrated fails to achieve the intended outcomes. A range of net carbon zero energy solutions will be required to be recognised and supported such as bio-mass, bio-gas, bio-liquid as well as decarbonised electricity. This would then enable domestic heat installers to specify the most appropriate net carbon zero solution for a given specific property.

4. What are the barriers to scaling up low carbon heating technologies? What is needed to overcome these barriers?

Please see previous answers.

5. How can the costs of decarbonising heat be distributed fairly across consumers, taxpayers, business and government, taking account of the fuel poor and communities affected by the transition? What is the impact of the existing distribution of environmental levies across electricity, gas and fuel bills on drivers for switching to low carbon heating, and should this distribution be reviewed?

No comment submitted

6. What incentives and regulatory measures should be employed to encourage and ensure households take up low carbon heat, and how will these need to vary for different household types?

Council tax should be replaced with a Dwelling CO2e emission tax. The consequences and incentives of such an initiative require no further explanation.   

7. What action is required to ensure that households are engaged, informed, supported and protected during the transition to low carbon heat, including measures to minimise disruption in homes and to maintain consumer choice?

Please see previous answers.

8. Where should responsibility lie for the governance, coordination and delivery of low carbon heating? What will these organisations need in order to deliver such responsibilities?

Local Authority Building Control and Competent Persons Schemes for compliance with the Building Regulations as presently.

Ends.

November 2020