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STA response to RHI Consultation - 26/04/10

Renewable Heat Incentive Consultation response

26th April 2010

Table of Contents

1. Introduction
2. Solar Water Heating and the UK Market
3. General Comments
4. Answers to Consultation Questions
Chapter 1: Accessing the RHI
Chapter 2: Eligibility and Standards
Chapter 3: Tariffs
Chapter 4: the RHI beyond 2011
Chapter 5: Interaction with other policies
Chapter 6: Administration
Call for Evidence on district heating networks
5. Respondent Details - Trade Association - England & Wales

1. Introduction:

This document sets out the responses of the Solar Trade Association ("the STA") to the solar related sections of the Renewable Heat Incentive (RHI) consultation.

Established almost 32 years ago, the STA is the UK's longest established renewable energy trade association. Already representing in excess of 200 member companies we are still growing fast. Our association includes manufacturers of solar water heating equipment, importers, distributors, installation businesses and consultants. The STA plays a leading role in promoting high standards and ethical practice. For more information about the STA, including the Association's ‘Code of Ethical Practice', please visit www.solar-trade.org.uk.

 

2. Solar Water Heating and the UK Market:

Almost half (49%) of the final energy consumed in the UK is in the form of heat. Of this heat 70% is used by households and in commercial and public buildings. Heating water accounts for 27% of aggregate UK household use of heat. Therefore the usage of Renewable technology, such as Solar thermal is essential to tackle the issue of global warming and climate change.

Domestic Solar Hot Water (DSHW) is generally the most practicable, convenient and effective renewable energy technology for providing a contribution to the heat use of households. It is also the only virtually zero carbon heating technology.

This explains why solar water heating is the most widely used domestic renewable energy system in the UK with over 100,000 (400,000m2) systems installed already. Over 90% of all building integrated renewable energy systems fitted in the UK to date are solar water heating systems.

Please note that there are also strong arguments, both economic and technical, for using DSHW in homes rather than utilising electricity from additional wind farm capacity to heat domestic water via immersion heaters.

Uptake of solar water heating in other European countries and key lessons
Much information can be obtained on the European Solar Thermal market from the European Solar Thermal Industry Federation (ESTIF www.estif.org ) website and market data can be found by clicking here. Markets across continental Europe are very advanced in comparison to the UK, with installation figures or 2.1 million m2 of solar thermal collectors in Germany in 2008 alone.

Whilst well over 99% of solar thermal technology in the UK is DSHW, in the German and Austrian solar thermal markets, Solar Combined hot water and space heating (Solar Combined systems) account for around 50% of the solar thermal market. There is also a rise in the number of ST systems that feed into district heating networks in quite a number of northern based European countries, many being installed are producing heat at a comparable cost to fossil fuel generated heat. The UK solar market tends to follow the German market and so we expect this Solar Combined technology to significantly penetrate the UK market over the next few years.

Following on from this, solar thermal technologies for industrial, commercial, cooling and many other applications should become more widespread. Solar Thermal electricity generation technology which is now being utilised in Southern Europe is another huge growth area. Germany and other European countries are exporting their own expertise designing and installing these simple and extremely effective technologies abroad. The UK, with suitable support, has the potential to export its own solar thermal technologies in a very similar fashion to other European countries.

 

3. General Comments:

The STA welcomes the Governments commitment to the Renewable Heat Incentive. The STA views this as the most important development to date for the renewable heating industry and so we welcome the opportunity to give our feedback and influence in the development of the Renewable Heat Incentive. This Incentive will create many new jobs in the heating and other related industries.

The following section sets out the STA's responses to the Consultation questions. We note that the RHI scheme as set out within the consultation is still in a gestation phase of development and we as an Industry and as an Association commit to working closely with Government to develop the scheme in the coming year before its launch on 1st April 2011. We are keen to see an RHI that provides stability for our industry, so that we can assist Government in meeting its' 2020 renewable energy targets.

 

4. Answers to Consultation Questions:

 

Q1: Are there any issues relevant to the design or operation of the RHI that are not addressed in this consultation document? If so, how should we deal with them?

From the solar thermal perspective, the proposed Renewable Heat Incentive (RHI) only deals with Domestic Solar Water Heating systems (DSHW). It does not cover other common and possible solar applications:

• Space heating
• Pool heating
• Air heating
• Cooling
• Industrial heating
• District heating
• Medium and large scale solar thermal systems
• Many other solar applications of heat
• Systems above 100kW output

This lack of support for the full range of solar thermal applications severely limits the impact of the RHI. It is essential that it is able to effectively support the full range of applications for this simple technology.

 

Chapter 1: Accessing the RHI

 

Q2: Do you see any barriers to such financing schemes coming forward? In particular, are there any limitations in leasing and finance legislation that you feel inappropriately restrict the development of RHI financing models?

We agree that financing schemes will be essential to ensure widespread take-up of these technologies. We also feel that the rates of return proposed for solar thermal will provide a barrier to the introduction of financing schemes for the technology. When all other renewable heat technologies have been given an ROI of 12% it is unlikely that any investors will want to back a technology with only 6% ROI. This uneven incentive will adversely affect the uptake of solar thermal technologies, the only virtually zero carbon renewable heat technology

Solar thermal is a key technology which can be used to reduce fuel poverty and unless finance is readily available, it will only be accessible for the richer segments of society.

We note 2 further important points

• Whilst the energy utilities are a vital route to market to support the growth of onsite renewable technologies, they should be seen as one of many routes to market. RHI must be designed in such a way as to enable many routes to market and not come under undue influence from the energy utilities.

• Legislation around loans and mortgages needs to be fully clarified. What is the security behind the loan or is the loan unsecured? Is it on the property in question or is it on the technology in question and so acts somewhat like a car loan. At the moment, there appears to be grey areas around this issue which if clarified would assist in the structuring of loan facilities.

Q3: Do you agree with our proposed RHI registration and payment approach? If not, can you suggest how this approach can be improved?

In broad terms we agree with the approach being taken. We have concerns over the running of the scheme specifically relating to:

• The complexity for householders in registering and accessing the RHI particularly where their system is financed by others.

• The ability of Ofgem to administer a scheme in a user friendly way which may have many millions of household users as well as some large commercial users.

• The frequency of payments suggested may be too long to enable regular loan repayments in funded installations (particularily those in fuel poverty situations). We note that sub 45 kW systems obtain yearly payments and over 45 kW systems quarterly payments

• Similar to the Feed-in-Tariff, RHI must be tax free and index-linked

• On-going concerns about the cost and complexity of MCS accreditation and very significant concerns about what above 45 kW accreditation will look like. All renewable heat equipment will be installed by the heating industry and not by "renewable energy" installers. Therefore, accreditation should come through heating industry routes and not establishing schemes that have no links to the heating industry.

All structures and accreditation need to be simplified and rationalised.

 

Chapter 2: Eligibility and Standards

Q4: Do you agree with our approach of requiring products and installers for installations up to 45kW within RHI to be accredited under MCS or equivalent?

We do agree that it is important that solar installations and products are of a high standard and that the consumer is protected from bad quality installations and unethical sales practices.

Therefore we support a scheme to ensure this occurs, however we have serious concerns over the MCS scheme and its potential to block entrants to the market. It is felt by many in the industry as an overly onerous barrier to trade which is substantially more complex and costly to become part of than the Gas Safe register for example. Urgent attention needs to be given to this to ensure that the scheme meets it objectives with out creating an unnecessary barrier.

It may be that different levels of certification or accreditation may be more appropriate for the solar industry; perhaps schemes aligned with the existing Competent Persons Schemes for the smaller scale installations / installers and a scheme like MCS for the larger companies and more technical installations.

Avoiding duplication in fees and certifications at this point would be very helpful in smoothing the path for new entrants as well as existing companies, who currently must register with a number of schemes to comply with the standards.

A rival scheme for the REAL Code is needed in the marketplace and the STA is well placed to deliver this. However, the Association needs financial assistance to get its code of conduct OFT registered.

Q5: Where MCS product and installer certification is extended beyond this limit, do you agree that we should introduce the requirement of using certified installers and equipment for eligibility for the RHI?

The level of 45kW seems totally arbitrary and we would like to see different certifications for different types of system rather just a notional size cut off.

Each renewable heating technology needs to use the existing MCS working group structure to advise on what accreditation is required for each application of the technology and each size range.

Different skills are required for different applications on different technologies at different size ranges. The 45 kW model is simplistic and inadequate.

Q6: Can you provide details of any UK or European standards that should count as equivalent to MCS? How should we recognise these standards for the RHI?

We note that MCS is an EN 45011 scheme which requires the following 3 items:

• Evidence of an implemented product standard
• A Quality Management System (QMS)
• A regular audit of the above (normally annual)

Currently the only equivalent scheme is Solar Keymark and this is fully recognised. Before we can recognise other certification schemes, it is worth reviewing the British MCS scheme. On the product side, this seems logical to expect a product to be tested and then manufactured so as to qualify for a standard such as EN 12975, the solar collector standard. However, we note that the solar collector, like all other heating systems is just one component in a wider collection of components, none of which are required to have certification. This again demonstrates an isolated product rather than a "systems" approach that is the only way to ensure that a quality heating circuit is installed.

To recognise other product schemes, we should review if these schemes demonstrate that the component in question is made to a recognised standard (preferably international) and also that the component is manufactured, through a factory production control system or similar to the recognised standard. There doesn't appear to be any other method to ensure product quality.

Reviewing the installation methodology, we note that the emphasis of the MCS scheme is on the Quality Management System (QMS) of the installation company. Whilst this is a laudable aim, we question the need for such a QMS when the issue at hand is the installation quality. Yes, an installation company should have good office systems. However, the purchaser of heating equipment rather wants a good system installed than efficient paperwork. The emphasis of installer MCS needs to be restructured onto installation quality.

We note that much of this installer MCS review process is on-going and is being led by Summitskills. Much more emphasis and resources need to be diverted to this review process to make Installer MCS fit-for-purpose.

Q7: Do you agree with our proposed approach to eligibility of energy sources, technologies and sites?

No, we very strongly reject the criteria! Solar thermal is the only virtually zero carbon technology and we find it incredible that technologies that are only percentage points better than gas condensing boiler technology could qualify for a 12% ROI when a solar thermal system only qualifies for a 6% ROI. All renewable heat technologies must be treated equally when setting the rates of return.

The UK solar thermal industry is still small with only 100,000 completed installations. When compared to a potential market size of about 20 million installations it becomes obvious that the market is still at the "early adopter" phase and therefore must have complete parity with other Renewable Heat technologies in terms of levels of support if it is to reach a suitable level of market penetration.

As currently designed, the Incentive scheme is based on cost rather than a balanced approach including carbon. In this configuration it seems highly likely we will miss both 2020 and 2050 targets, and underperform on the deployment of these technologies. The emphasis must be changed to favour technologies that save carbon, are user friendly and present a reasonable cost/unit of carbon saved rather than technologies that are similar in carbon performance to gas condensing boiler technologies without some of the user friendly advantages of other renewable heat technologies.

We are therefore asking for a rethink of both the deeming process and returns for different technologies. The scheme will fail to meet its objectives as it is currently structured. We would encourage DECC to complete more technical analysis of the proposal in relation to different technologies as we believe that this is required to refine the design of the RHI and significantly the schemes impact.

We suggest that the whole RHI process needs further consideration so that it includes carbon savings and is not based just on a cost/kWh basis. A properly funded task group which consists of known industry experts needs to be established to advise on this process. Much more advice should be sort from our European neighbours who have a more advanced renewable heating industry to inform our UK based options. We are happy and willing to facilitate such a contact (as we have already started to do) and are very happy to have an input into the design of the scheme going forwards.

Therefore we ask for a task group to be established with industry experts that could refine the space and hot water heating look-up tables discussed elsewhere in this consultation response so as to balance the carbon benefits and the cost/kWh benefits of different technology and system solutions.

We find it unacceptable that RHI does not specifically include cooling. Solar thermal technologies are proven in cooling applications and are becoming widely used for such in some countries. Peak output from a solar thermal collector often coincides with peak cooling requirements. If cooling or heating is required, then they both need to be supplied in an efficient manner and excluding cooling from the scheme is misguided (unless there is another route to support cooling). Supplying cooling with low and zero carbon technologies will significantly reduce our national energy consumption and carbon output. The RHI must be implemented under the reduce then supply premise and not under arbitrary its heating or its cooling premises.

Finally, we do not agree that equipment should only receive the RHI if installed after 15th July 2009. Early adopters who have helped to establish a market for solar thermal and other technologies in the UK will be a key part of the promotional force to accelerate its uptake. Excluding these early adopters sets a precedent whereby those who do the right thing even though there is limited personal benefit are then disadvantaged when good benefits are brought to market. There needs to be more balance in the scheme with some additional benefits for these early adopters.

Q8: Do you agree with our proposed approach on bioliquids? Are you aware of bioliquids other than FAME that could be used in converted domestic heating oil boilers? If so, should we make them eligible for RHI support, and how could we assess the renewable proportion of such fuels to ensure RHI is only paid for the renewable content of fuels?

No Comment

Q9: Do you agree with the proposed emissions standards for biomass boilers below 20MW? If not, why, and do you have any evidence supporting different ones, in particular on how they safeguard air quality?

Solar thermal technologies have no effect on air quality.

Q10: Do you think the RHI should be structured to encourage energy efficiency through the tariff structure (in particular the use of deeming), or, additionally, require householders to install minimum energy efficiency standards as a condition for benefiting from RHI support?

We note that as part of any hot water system intervention, the building regs require that the installation company has to bring the Hot Water system up to the latest Part L standards and so all Domestic Solar Water Heating RHI installations will have to install minimum energy efficiency HW standards to pass building regs.

STA policy clearly states that we believe that demand should be reduced (energy efficiency) before supply side (renewable heat) measures are implemented.

However we do not feel that the RHI should be linked to specific energy efficiency measures, as this could act as an unnecessary barrier to uptake.

Q11: Can you provide suggestions for how to ensure that developers do not build to lower energy efficiency standards as a result of the RHI in advance of 2013 and 2016 building regulations taking effect?

We believe that this issue would be properly addressed through planning policy statements. We are concerned that planning will often be sought in one year say 2012 for a planned construction at a later date so that the building can be constructed to older building regs. This loophole could be legislatively addressed via several different routes.

 

Chapter 3: Tariffs

Q12: Do you agree with our proposals on where we should meter and where we should deem to determine an installation's entitlement to RHI compensation?

In principle, we agree with the proposal of deeming for smaller systems and metering larger systems.

However, we have observed that both in the consultation and in wider discussions, both with the British Government and our European colleagues that deeming is a complex process and that 2 separate deeming calculations are required, one for space heating and one for hot water heating. Deeming should also take into account bivalent and multivalent heat sources, weather compensation and the manner in which different heat distribution systems including cylinder volume, radiators, underfloor or fan coils influence the final outcome.

A fully funded and resourced deeming task force needs to be immediately established to address these issues. Relying on unqualified consultants will not deal with this issue. It requires heating industry expertise to develop a consensus view that can be implemented by Government.

We do not want to enter into a wider discussion of advantages and disadvantages of deeming within this consultation response. We have carried out some of our own analysis and are willing to share this information in the appropriate fora.

We are also working with our European colleagues to collect and collate data on medium and large scale solar thermal systems and will feed this onto the RHI team at DECC as we obtain useful and easy-to-process information

Q13: Do you agree that a process based on SAP or SBEM for existing buildings or the Energy Performance Certificate for new buildings is the best way of implementing deeming? Do you have any suggestions on the details of how this assessment process should work?

The deeming process is creating much confusion and concern. As is clearly understood, "gaming" (i.e. any form of over-claiming) is the major risk associated with adopting an incentive process. To avoid this gaming, space heating incentives probably have to be based on a look-up table as featured in appendix 2 of the consultation document. The task group discussed elsewhere in this submission could review this table and implement a more advanced version which covers the requirements of being:

• Quick & easy
• Certain
• Consistent
• & reasonably accurate.

We believe that using existing fuel bills in the deeming process should be avoided because this brings in behavioural elements. We also note that the insulation should be upgraded before renewable heat is installed and this will alter the buildings performance as compared to the fuel bills. An appropriately designed look-up table overcomes the potential complexities for both space heating and hot water heating technologies.

To achieve a more acurate result for solar thermal technologies, a slightly more complex methodology can be employed that uses elements of a look-up table to avoid "gaming" allied to the solar algorithm in appendix H of SAP. This calculation takes into account the zero-loss efficiency and efficiency curve of the collector and also the dedicated and effective solar volume of the hot water cylinder in its computation. Much of this information is readily available from Solar Keymark and MCS standards. We will gladly work on the further development of this process as part of a properly funded and resourced task group.

Q14: Do you agree that at the large scale/in process heating, where we propose metering, the risk of metering resulting in a perverse incentive to overgenerate is low? How could we reduce it further within the constraints of using metering, to ensure only useful heat is compensated? Do you see any practical difficulties concerning use of heat meters (such as on availability, reliability or cost of heat meters) and, if so, how should we address them?

The consultation document does not propose medium and large scale tariff levels for solar thermal technologies therefore the perverse incentive to overgenerate would definitely be low. As we have previously said we feel that this is a huge oversight. If a suitable tariff is introduced for systems of this scale then metering of the heat produced would be an appropriate way to measure the levels.

It is unlikely that large scale solar thermal applications would over produce heat as these systems are carefully designed to meet a heat loading. Installation of systems that were much larger than required would cause major stress on the system and potentially cause the system to fail. Excess heat in a solar thermal system is hard to dissipate, and therefore is normally designed to be a kept at a minimum.

A properly funded and resourced committee of industry experts needs to be established to support the RHI review process. This committee should include measurement and monitoring expertise so that metering processes can be evaluated by this committee.

Heat meters are a tried, tested and established technology. The key elements of a heat meter are accurate and reliable flow meters as well as robust temperature, data acquisition and storage systems.

Q15: What is the right incentive level required to bring forward renewable heat from large-scale biomass including in the form of CHP while minimising costs to consumers?

No comment

Q16: What is the right incentive level required to bring forward renewable heat from biogas combustion above 200 kW including in the form of CHP while minimising costs to consumers? Do you have any data or evidence supporting your view?

No comment

Q17: Do you have any data or evidence on the costs of air source heat pumps above 350 kW or solar thermal above 100 kW?

We will submit the European data we have on solar thermal systems above 100 kW and also information we have on other applications of solar thermal systems.

Some initial analysis from some of our European neighbours is as follows.

Systems costs vary a lot depending on the application, placing and size.

For your reference, system costs in Austria (including storage and installation):
100 - 500 m²: +/- 600 €/m² corresponding to 850 €/kW
500 - 1000 m²: +/- 500 €/m² corresponding to 700 €/kW

If it is a system for district heating (no need of a storage and secondary loop) the cost are significant lower (minus € 200/m²)
As for Sweden, we can estimate 1.100 €/kW (solar collector costs are of the order of 5 000 - 3 000 SEK/m² corresponding to +/- 570 €/kW and system costs incl. storage tank etc. adds up about the same)

Therefore, taking the highest cost (Sweden) and considering:
- yield of 400 kWh/a.sqm
- Annuity between 0.05 - 0.10
We can estimate solar heat costs about 0.14-0.28 €/kWh (or 0.07-0.14 €/kWh if it doesn't include storage, etc.).

We have previously submitted data from seven different solar district heating schemes located in Denmark, on a similar latitude to Scotland. These schemes are producing heat at a cost of £0.017 - £0.029 per kWhr.

Q18: Do you agree with the proposed approach to setting the RHI tariffs, including tariff structure and rates of return? Do you agree with the resulting tariff levels and lifetimes? If not, what alternatives would you prefer, and on the basis of what evidence?

The ROI on solar thermal technology needs to be the same as that on the other other low carbon heating technologies. A tariff level which provides a ROI of 6% when all the others receive 12% will provide a disincentive to invest in the technology.

Please see our answer to question 7. We want to see a balanced cost/kWh & carbon based deeming methodology which favours systems that save carbon as well as just cost benefit measures. The current system is in danger, without careful evaluation of the deeming process, of favouring technologies that make only minor improvements on gas condensing boiler technology.

To realise this, we are calling for the setting up of a short term task group of properly funded and resourced industry experts and representatives to design and establish a fair and reasonable deeming process based on space heating and hot water heating look-up tables.

This short term task group could be used as the basis for establishing a group of leading industry heating experts to advise government on the operation of the RHI scheme.

Q19: Do you agree with our proposed approach on mixed fuels? Do you agree with our proposal that, at larger sites, with the exception of EfW, RHI will require the use of a dedicated boiler for the renewable fuel? Where our approach is to follow the Renewables Obligation, do any aspects need to be adapted to account for the different situation of renewable heat?

No comment

Q20: Do you believe that we should provide an uplift for renewable district heating?

Yes, all renewable forms of heating should be supported.

Q21: Do you believe that an uplift should be available to all eligible district heating networks, or that eligibility should be determined on a case-by-case basis depending on whether a network contributes to the objective of connecting hard-to-treat properties (and, if the latter, how should we determine this for each case)? Do you agree that situations of one or a small number of large external heat users should not be eligible for an uplift, and, if so, what should be the minimum eligibility requirement for an uplift (expressed for instance as a minimum number of external customers)?

District heating is not within our core levels of expertise.

 

Chapter 4: the RHI beyond 2011

Q22: Do you agree that RHI tariffs should be fully fixed (other than to correct for inflation) for the duration of any project's entitlement to RHI support? Do you agree that we should include bio-energy tariffs, including the fuel part of those tariffs, in such a grandfathering commitment?

Yes a fully fixed tariff will provide stability to the market.

Q23: Do you agree with our proposal not to introduce degression from the outset of the scheme but consider the case at the first review?

Yes. We support the principle of degression.

Q24: Do you agree with our proposed approach on innovative and emerging technologies?

Q25: Do you have any views on how we should encourage technology cost reductions through the RHI, particularly on solar thermal heat?

We note that this discussion is based on cost/kWh rather than cost/unit of carbon saved. We have to be implementing technologies that are much and not just partially better than gas condensing boiler systems if we are to fully meet our long term targets.

We also note that this innovation discussion is based on a technology approach to the renewable heat issue. Heating is not just based on technologies; it is based on integrated systems consisting of many control, provision, collection, storage and distribution elements. These individual elements or technologies make up the heating system and innovation occurs within the elements and sometimes within the whole integration principle of the system.

For example, most heating systems, if effectively controlled and installed with underfloor heating often save more carbon as compared to their radiator based alternatives. However, the type of underfloor heating employed also has an effect on the heating system performance. RHI should encourage the uptake of low temperature heat distribution systems which can be provided by low temperature radiators, fan coils and radiant distribution systems.

Whilst we must have a relatively simple to use deeming process, this deeming process must encourage carbon saving and be supported initially by the task group of heating industry experts and this task group has to be developed into an independent set of government advisers so that all aspects of the RHI can be supported and the incentive scheme is developed to bring through a "systems" or portfolio approach to innovation and carbon saving.

Finally, we note that in the specific case of solar heating technology, costs are very different for different situations.

In our experience, the most expensive property to install can be a one-off new build situation where the installer is called back in by the contractor for several fixes at the various stages of the construction process. Several site visits adds to the total installation cost.

Then, in a typical retrofit scenario, to achieve the highest available solar fraction, the solar installer will opt to change the existing cylinder and as well as passing this cost on, they will also have to absorb the cost of access equipment within the total installation cost.

Finally, in a large number of new build properties, the installation cost can come down somewhat due to the ability to leave installers on the construction site for sometime as they move from property to property to install the system and both access cost and cylinder cost is covered by the wider construction process.

Room for innovation is fairly limited. If bigger solar fractions are to be obtained, current evidence indicates that the hot water cylinder should be changed and this has fairly fixed associated costs. Innovative access systems for reducing collector installation cost could be realised. However, there are many costs that only offer limited room for improvement.

Statements such as economies of scale don't always apply when analysing heating systems. Sometimes the individual local and integrated unit can be much cheaper than the large scale solution with all its inherent complexity. It brings us back to the case-by-case basis and the need for independent expert and knowledgeable advisers to support innovation and review processes.

Q26: Do you agree with our proposed approach to reviews, and the timing and scope of the initial review?

Yes

Q27: Can you provide examples of situations that could be taken into consideration in determining criteria for an emergency review?

With an independent group of heating experts meeting every 3 or 6 months or so, they would be capable of advising Government on innovative cases and Government could be provided with advice on whether an emergency intervention was required or not.

 

Chapter 5: Interaction with other policies

Q28: Do you agree with our proposed approach to allow access to RHI support to new projects where installation completed after 15 July 2009, but not before? Do you have any evidence showing that in particular situations RHI support for installations existing before this date would be needed and justifiable?

This decision to deny support to early adopters is misguided as it discriminates against those who have acted in good faith and looked to support the early adoption of on-site renewable technologies. These early adopters, if supported in some way through the RHI can act as ambassadors for the new Incentive scheme.

 

Chapter 6: Administration

Q29: Are there any parts of the proposals set out in this consultation that in your view would allow for unacceptable abuse of RHI support, or other unintended consequences? If so, how could we tighten the rules while keeping the scheme workable, and avoiding an overly high administrative burden?

A complex and bureaucratic deeming process requiring 2 MCS companies is described in the consultation; we consider this unnecessary. The deeming of all systems installed after 15th July 09 should go through the same deeming process which is likely to be based on look-up table for space heating and a SAP Hot Water and appendix H calculation allied to a look-up table for solar thermal hot water. This methodology should be applied to all RHI applications for incentives including those installed between 15th July 09 and 31st March 2011.
We also note that all heating systems, including all the major elements should be regularly serviced and maintained. In the case of solar thermal, many suppliers recommend that the householder regular checks that the solar system is functioning properly and that the system is given a major service every 5 years. Householders are shown how to check correct operation at handover. Therefore, we would recommend that the householder self certifies their solar performance to qualify for annual RHI payment and that an MCS installation company services the solar system every 5 years. MCS and any other relevant accreditation scheme should write the appropriate maintenance procedures into the relevant standards.

Data Collection: For many years, the STA has worked in association with other industry bodies to provide accurate information on the UK heating market. We note that it is more difficult to accurately obtain data on new industrial sectors as compared to mature industries. This solar market data will now be more accurately collected by Ofgem as part of the RHI process. The STA wants to continue to publish this broad (not individual company) market data.

We have been publishing our own data in association with our European sister association ESTIF on their website www.estif.org . We want to work closely with Ofgem to continue to publish this broadly based market data and want to be able to publish this data on a quarterly rather than yearly basis. We trust that Ofgem and Government will want to work with reputable industry bodies to achieve such a process.

 

Call for Evidence on district heating networks

 

Q30: Do you agree with our proposed overall approach to setting the level of the uplift? Can you provide evidence that would help us to determine the level of uplift? In particular:

• Can you describe typical district heating networks that would be appropriate as reference networks, and what are their network costs, heat loads, and customer numbers and characteristics?

• What proportion of the heat load of such networks is typically supplied to hard-to-treat properties? What proportion of the total network of the reference installation(s) supply heat to hard to treat properties?

Should we choose one reference network and determine one uplift (in p/kWh) applicable to all sizes of networks, or should there be several based on a number of differently sized reference networks?

No comment

 

5. Respondent Details - Trade Association - England & Wales

David Matthews
Chief Executive

Solar Trade Association
National Energy Centre
Davy Avenue
Knowlhill
Milton Keynes
MK5 8NG

Tel: 01908 442290
Fax: 01908 665577
E-mail: david.matthews@solar-trade.org.uk
The Solar Trade Association is proud to be celebrating its 30th Anniversary this year. Visit our website www.solar-trade.org.uk

The Solar Trade Association is managed on behalf of its Council by the National Energy Foundation - Registered Charity No. 298951 Registered in England with liability limited by guarantee No 2218531
Solar Trade Association Ltd is registered in England at the above address No 1372316

 

 

 

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