Written evidence submitted by Mr Chit Chong (DHH0085)


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?

- All Boilers to be Condensing – Success. Reduced cost to residents and reduced emissions

- Installation of Communal Heating Systems – Failure. Near doubling of gas use and emissions from dwellings. Reason, poor policy design, lack of policy learning, feedback, conspiracy of professionals resulting in oversized plant and cost, lack of responsibility for policy failure and inability to admit failure.

- Installation of CHP in communal heating systems – Failure. Adherence to theory triumphs over reality of failure in practice. Probably only one in ten CHP plants operate, some (60%) in Peabody are operating now when the emissions factors mean that carbon savings are minimal.  Reason – fantasy economics of sale or use of electricity, reality of difficulty to sell electricity at viable rate to big six to pay for much more than administration costs. Conspiracy of Professionals creates unworkable plant designs eg oversized plant designed to operate with 80C flow rate results in 78C return meaning that CHPs cannot work as they require return below 70C.

Learning – Professional liability to be joint and several for five years beyond installation. All design changes to be signed off from original designer to installer to maintain chain of liability. Design Criteria to be based on real data rather than the obsolete of SAP 9.92 with notional efficiency of communal heating of 85% real efficiency 50%  and carbon emissions factors of 500 g CO2e/kwh electricity when the reality was 350 g CO2e/kwh and falling.  Designers should report on reconciling obsolete standards with reality and with foreseeable factors.

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)?

- Review Landlord and Tenant Act to mandate landlords to implement “heat as a service” agreements and “spend to save” investments where savings can be shown over 10 years.

- Develop legislation to allow external insulation to over sail curtilage.

- Set national limits for emissions from heritage stock including  Listed Buildings and Conservation Areas

- Clarify rights to heat in ground and water courses with such usages encouraged.

- Develop contracts for peer to peer energy sales.

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?

- GSHP and WSHP with peak demand automaton ASHP where not possible. Refrigerants to be zero GWP.
(this will need to be coupled with restriction on electric vehicle car size to preserve electricity capacity for heating)

- External wall insulation and triple glazing wherever possible in retrofit

- External shading where possible to minimise need for cooling.


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

- Skills Gap. Training is urgently needed and job guarantee unlike training for “Green Deal”

- cost gap in investment

- cost gap in whole life.

-increased grid capacity

- increased zero carbon electricity.

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?

- Possible use of combined social and market tariffs. Consumers provided sufficient heat at low cost to achieve minimal heat and hot water, but pay for higher for full comfort heating.

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?

- zero stamp duty for net zero carbon homes.

- discounted stamp duty for EPC A homes.

- MEES to be EPC B by 2040

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?

- Coordinated publicity, especially in climate change vulnerable areas.

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 government and strengthened planning, licencing and trading standards teams.


November 2020