RHI CONSULTATION CIBSE RESPONSE
More expensive sources of renewable heat,
such as solar thermal, should attract no higher grant than other systems, advises CIBSE, suggesting target installed costs could be set that meet value-for-money criteria. CIBSE is cautious about the provision of
RHI for social housing landlords until capital costs have reduced and operating costs are better understood. However, it says that social housing landlords maybe able to offer better value for money from centralized installations. Monitoring should be favoured above deeming – a method of calculation that relies on a tick box approach, rather than analysis of real data – to calculate RHI payments, says CIBSE, as there is currently a lack of data to determine what is good performance. If a calculation method had to be used, the institution recommends SAP, once a version is developed for RHI. And it says the government has to offer incentives to customers to install metering and monitoring, and ensure any data is made available to the supply chain to enable development and improvement of systems. The government should undertake pilots to
identify benefi ts and problems, the fi ndings of which could be fed into product development,
system design and improvements in service provision, says CIBSE. Meanwhile, any pilot should closely monitor the performance of renewables, and help evaluate the experience for the customer.
Non-domestic RHI DECC asked for a response to proposals for an extension to the non-domestic scheme, particularly air to air pumps. CIBSE says that there should be no RHI
for reversible air-to-air heat pumps, as the market is already strong. It also believes that monitoring rather than deeming should be used to determine payment. It fears deeming will create a precedent for other forms of renewable heat, which will mean less data available for formulating future policy and less certainty over whether payments are appropriate. Ideally payments should be based on actual performance of the system. The use of waste heat should also be considered, while recent developments in below-ground thermal storage are achieving signifi cant carbon savings, says CIBSE, and can be used in conjunction with refrigeration systems generating waste heat. CJ
Opening tariffs need to be very attractive to kickstart the scheme, but then entrenchment to a more balanced tariff once the market has taken off causes confusion and market collapse
References
1 CIBSE Application Manual for biomass heating systems
www.cibse.org
2 Energy Saving Trust Heat pump fi eld trial initial fi ndings found that performance is highly dependent upon appropriate installation and integration with the building’s existing heating system, and appropriate control by customers.
The full response to the RHI consultation is available on the CIBSE website along with responses to other recent consultations
www.cibse.org/consultationresponses
www.cibsejournal.com
January 2013 CIBSE Journal 31
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