UKERC response to the DECC consultation on the proposed RHI financial support scheme

The UK Energy Research Centre welcomes this opportunity to provide input to the to the DECC Consultation on the proposed RHI financial support scheme. The UKERC response addresses a number of the questions posed in the consultation document.

• The level of integration between the RHI and the Household Energy Management Strategy is weak, despite strong parallels between the policies. In particular the RHI proposal does not take into account wider energy policy goals.
• UKERC is concerned that the approach taken in the proposed RHI scheme assumes that the appropriate policy instrument is a kWh based subsidy rather than exploring a wider range options such as loans and grants.
• There is no clearly defined mechanism for funding the RHI in the proposal. UKERC suggests that some type of levy system is preferable to individual suppliers bearing the cost of theRHI.
• It should be clearer how the fuel poor will benefit from the RHI; will lowincome families be able to obtain renewable heat equipment for free? If not it is difficult to see how they will benefit, given the high capital equipment costs.
• UKERC proposes that there should be a process for assessing and including emerging technologies that fall outside the list of technologies identified in the RHI proposal.
• Trigeneration and other innovative renewable cooling systems should be covered by the RHI as this would help to implement energy saving technologies and reduce CO2 emissions.
• Heat metering should be applied for medium-scale and large-scale systems; the use of heat meters is well-established in other EU countries.
• The benefit of using heat pumps above 350 kW is questionable, especially if cooling will not be supported by the RHI, as normally high capacity heat pumps operate in both cooling and heating regimes.
• There are issues with the RHI tariff structure in relation to energy efficiency measures, these include: confusion over minimum insulation; discrepancies in household occupancy; and problems with RdSAP in EDCs.