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Rethinking the mindset for mass retrofit - a provocative idea

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(@jamespa)
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Posted by: @derek-m

@jamespa

I think that many on the forum would agree that there is not a simple solution, but that all reasonable options should be considered and investigated. I am not convinced that many of our politicians and their advisors fully understand the scale of the problems. Voting into law net zero requirements is not going to make it happen.

I would suggest that we consider the problems and possible solutions, and then try to convince others of the need for action....

..

Posted by: @sunandair

The issue of uptake has loomed large lately and I’m sure there’s many and varied reasons. I guess inflation and the economy wouldn’t have helped. 

Reputation of the HP industry and conversations over the garden wall would certainly have fuelled a lot of resistance to what is often perceived as over-complicated, unreliable and very temperamental. 

You put the word “Mindset” in the title. 
But who’s mindset?

Customer’s still crave NEST or HIVE type thermostats. So the industry gives them pseudo smart thermostats which don’t work...

Both very valid comments (and a sensible suggestion for an approach) in my humble opinion, however can we make absolutely sure we agree on the objective - there are posts upthread suggesting we may not (or may be using different terminology!).  Your observations become some of the challenges with a solution, I wouldn't say that they are absolute constraints, but definitely challenges..  I've added some text below to reflect this, there are quite a few others of the same nature and we should make a list.

Posted by: @chickenbig

I would certainly add that the heat source needs to be simple to fit, probably opportunistically when the existing heat source breaks. This implies it should be quick (and low risk) to install, with a broad-base of installers trained and willing to do so....

Thanks.  I might argue that this isn't an external constraint (show shouldn't be listed under constraints) although I grant its a necessary feature of the solution if the objective is to be met.  Can I park it for now and then reintroduce it once we have agreed the basics

 

Amended text for comment

 

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Constraints (external to the system)

the primary constraint is that it has to be affordable, not just to the few, but to the many.  I would also suggest that making the assumption that it will be made affordable by ongoing taxpayer subsidies (at any material level) is dangerous, possibly foolhardy

the timescale objective means that any solution needs to be based largely on technology we have, or can be confident we will have shortly

It is recognised that there are also some hurdles, falling short of absolute constraints but nevertheless significant, which will need to be taken into account/overcome.  These include (but are not limited to) education, familiarity, usability, ease of installation, manpower for installation etc.   A comprehensive tlist to be compiled at a later date.

Assumptions

I think we have to assume that an ASHP run on electricity is cleaner, and will continue to be cleaner, than gas ever can be.  We further have to assume that the cleanliness of electricity will, at worst, keep pace with the demand (in fact the more likely scenario is that the current trend whereby electricity has got cleaner year on year will continue, the Government publishes greenhouse gas conversion factors, these are  currently 0.18 (Kg(e) per kWH) for Gas, 0.19 for electricity)

For the purposes of the discussion about ASHPs we also should assume that insulation is a parallel activity, not alternative but parallel.  However there will always remain a requirement to heat homes

 

Proposed next steps (one the above are agreed)

consider the problems and possible solutions, and then try to convince others of the need for action....

This post was modified 2 years ago 5 times by JamesPa

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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SUNandAIR
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Posted by: @jamespa

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Curious- what exactly will this discussion actually produce. Who are “we” who are you. With what authority do we speak? 

is there a material product/system at the end of this discussion? Do a band of innovative installers romp ahead with a fast low budget installation package? Is there a standards review? or is it an informative but passive temperature check of the mood of a  disparate  partially informed self help group?

What, for you, would be the perfect outcome and end product from this discussion?

I guess I’d like to know what do you represent?

thanks for any enlightenment 👍🏻


   
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Posted by: @sunandair

Posted by: @jamespa

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Curious- what exactly will this discussion actually produce. Who are “we” who are you. With what authority do we speak? 

is there a material product/system at the end of this discussion? Do a band of innovative installers romp ahead with a fast low budget installation package? Is there a standards review? or is it an informative but passive temperature check of the mood of a  disparate  partially informed self help group?

What, for you, would be the perfect outcome and end product from this discussion?

I guess I’d like to know what do you represent?

thanks for any enlightenment 👍🏻

 

All fair questions, lets start with the 'declarations of interest' one.

I personally represent nobody and have no connection with the industry.  However I do have a degree in physics, a background in engineering and experience of local government, so have some cross-disciplinary knowledge/skills which hopefully help with the analysis  I've been trying to install a HP in my house for the best part of 2 years and am totally frustrated by the state of the market.  I am also a member of buildhub (a forum that seems to be mostly self builders, those doing major DiY and members of the building trade)  and where I have posed a similar question and have had some interesting, albeit largely demoralising, responses. 

Im personally interested in doing this because, even though I am now over 60, climate change scares me but at the same time its clear that we do in fact have much of the technology to deal with it, yet lack practical solutions and political will.  So I would find it personally satisfying to at least understand, even if I cannot influence, the way forward in this key area which we collectively, as consumers, control.  

As to what it will produce?  There is at least one member active on this forum that is regularly interacting with their MP and others on the matter.  I have corresponded very productively with Baroness Parminter who led the recent lords review on the BUS scheme, and I would suspect that at least some others have ways into people who are involved in the decision making.  I am sceptical this will have much influence but we can but try.  Also if we do come up with a set of thought through proposals, those of us who are interested can actively promote them whenever they get the chance.

Do we speak with any authority?  I would say yes, morally, if we come up with practical solutions.  Will anyone listen, quite possibly not, but that wont stop me trying.

What would be the ideal outcome?

1. An set of practical steps which we could promote that stand a good chance of changing the current, failing situation (in the sense that there is no published industry roadmap to the objective and its clear that the current state of the industry/regulation is not achieving even the modest initial objectives set), into one which could meet the objective and which have been subjected to sufficient peer review by a wide spectrum of people to be tolerably robust

2. A seat at a table somewhere for informed, intelligent, non partisan, largely (but not exclusively) consumer-led thinking which could help influence the politics and the installation industry.

 

I would say that (2) is highly unlikely to happen, but you never know.  I would also that, if we cant achieve (1) then what hope do the politicians have of doing so.

 

 

Amended text for comment

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Constraints (external to the system)

the primary constraint is that it has to be affordable, not just to the few, but to the many.  I would also suggest that making the assumption that it will be made affordable by ongoing taxpayer subsidies (at any material level) is dangerous, possibly foolhardy

the timescale objective means that any solution needs to be based largely on technology we have, or can be confident we will have shortly

It is recognised that there are also some hurdles, falling short of absolute constraints but nevertheless significant, which will need to be taken into account/overcome.  These include (but are not limited to) education, familiarity, usability, ease of installation, manpower for installation etc.   A comprehensive tlist to be compiled at a later date.

Assumptions

I think we have to assume that an ASHP run on electricity is cleaner, and will continue to be cleaner, than gas ever can be.  We further have to assume that the cleanliness of electricity will, at worst, keep pace with the demand (in fact the more likely scenario is that the current trend whereby electricity has got cleaner year on year will continue, the Government publishes greenhouse gas conversion factors, these are  currently 0.18 (Kg(e) per kWH) for Gas, 0.19 for electricity)

For the purposes of the discussion about ASHPs we also should assume that insulation is a parallel activity, not alternative but parallel.  However there will always remain a requirement to heat homes

 

Proposed next steps (one the above are agreed)

consider the problems and possible solutions, and then try to convince others of the need for action....

 

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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SUNandAIR
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@jamespa 

Thanks James that helps to understand the context and your aspirations… I’m also enthused to make things better. 


   
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Posted by: @jamespa

Amended text for comment

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Constraints (external to the system)

the primary constraint is that it has to be affordable, not just to the few, but to the many.  I would also suggest that making the assumption that it will be made affordable by ongoing taxpayer subsidies (at any material level) is dangerous, possibly foolhardy

the timescale objective means that any solution needs to be based largely on technology we have, or can be confident we will have shortly

It is recognised that there are also some hurdles, falling short of absolute constraints but nevertheless significant, which will need to be taken into account/overcome.  These include (but are not limited to) education, familiarity, usability, ease of installation, manpower for installation etc.   A comprehensive tlist to be compiled at a later date.

Assumptions

I think we have to assume that an ASHP run on electricity is cleaner, and will continue to be cleaner, than gas ever can be.  We further have to assume that the cleanliness of electricity will, at worst, keep pace with the demand (in fact the more likely scenario is that the current trend whereby electricity has got cleaner year on year will continue, the Government publishes greenhouse gas conversion factors, these are  currently 0.18 (Kg(e) per kWH) for Gas, 0.19 for electricity)

For the purposes of the discussion about ASHPs we also should assume that insulation is a parallel activity, not alternative but parallel.  However there will always remain a requirement to heat homes

 

Proposed next steps (one the above are agreed)

consider the problems and possible solutions, and then try to convince others of the need for action....

Are there any other comments on the above, if not (by say Saturday morning) lets return to the 'how' having perhaps agreed the 'what'

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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cathodeRay
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I got an unsolicited email from my energy supplier (EDF) today: "Looking to transform your home heating? It's time to say hello to heat pumps...". Another major supplier jumping on the bandwagon. Ker-CHING! No doubt there are EDF execs sitting round a table somewhere saying "It time to say hello to profits...". 

In the real world, the key driver for just about everything to do with heat pumps is money. Those who want to make a fast buck, and those who don't want to part with their hard gained income, or, if they are lucky enough to have it, capital. I can say for certain that if I hadn't got a grant to install my heat pump, I would still be burning oil. The reason why there are almost 2 million gas boiler installations against a pitance of heat pump installations isn't, I suggest, lack of education or familiarity, but cash. For most home owners, heat pumps fall at the first hurdle. They are simply too expensive, and from that point on, they do not even get a look in.

It's not unprecedented for major national changes to involve some form of bribery. Doctors had to be bribed to get the NHS into being (Bevan: "I stuffed their mouths with gold", though this refers to consultants, who were allowed to have private patients alongside their NHS work, while GPs got their  'independent contractor status'). I say all this because I want to suggest that rethinking the finances for a mass refit may be as it not more important than rethinking the mindset for mass retrofit.       

Midea 14kW (for now...) ASHP heating both building and DHW


   
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Posted by: @cathoderay

In the real world, the key driver for just about everything to do with heat pumps is money.

Of course, not just heat pumps, everything.  That's why I started this thread, to see if I could get agreement on how to make the money objective and the climate objective align.  Until they do mass roll out won't happen.

I started a similar thread on buildhub.  It was initially very negative but now some are beginning to come round to admitting that the current MO with heat pumps won't work, and that maybe, just maybe, a rethink is necessary.

This post was modified 2 years ago by JamesPa

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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Posted by: @jamespa

It was initially very negative but now some are beginning to come round to admitting that the current MO with heat pumps won't work, and that maybe, just maybe, a rethink is necessary.

That's encouraging (the beginning to come round bit). I will put some thought into how we might convincingly show that the current MO won't work. It may just need one simple chart, gas installations vs heat pump installation per year (or quarter if available) and then add some whatiffery (aka modelling).  

Midea 14kW (for now...) ASHP heating both building and DHW


   
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Posted by: @jamespa
osted by: @jamespa

Objective

the objective is to reduce, eventually eliminate carbon emissions while heating our houses, with a degree of urgency commensurate with the ambition to be carbon neutral by 2050.  (Note: roughly 1.6M gas boilers are installed every year of which 1.4M are retrofits)

Constraints (external to the system)

the primary constraint is that it has to be affordable, not just to the few, but to the many.  I would also suggest that making the assumption that it will be made affordable by ongoing taxpayer subsidies (at any material level) is dangerous, possibly foolhardy

the timescale objective means that any solution needs to be based largely on technology we have, or can be confident we will have shortly

It is recognised that there are also some hurdles, falling short of absolute constraints but nevertheless significant, which will need to be taken into account/overcome.  These include (but are not limited to) education, familiarity, usability, ease of installation, manpower for installation etc.   A comprehensive tlist to be compiled at a later date.

Assumptions

I think we have to assume that an ASHP run on electricity is cleaner, and will continue to be cleaner, than gas ever can be.  We further have to assume that the cleanliness of electricity will, at worst, keep pace with the demand (in fact the more likely scenario is that the current trend whereby electricity has got cleaner year on year will continue, the Government publishes greenhouse gas conversion factors, these are  currently 0.18 (Kg(e) per kWH) for Gas, 0.19 for electricity)

For the purposes of the discussion about ASHPs we also should assume that insulation is a parallel activity, not alternative but parallel.  However there will always remain a requirement to heat homes

 

Proposed next steps (one the above are agreed)

consider the problems and possible solutions, and then try to convince others of the need for action....

 

I think its fair to say that a consensus has emerged on this thread (with a few exceptions of course) that, if we are to achieve the mass roll out of heat pumps that is necessary to achieve our climate change goals, changes must be made in the regulatory regime, in the installation industry and in the ‘toolbox’ with which the installation industry works.

The essential background is that today we install about 1.6M gas boilers each year of which 1.4M are retrofits.  Each gas boiler installed is an opportunity lost.  In 2022 we installed about 60,000 heat pumps.  The UK is 20th on the eurpoean league table of heat pumps per person. ( https://www.theecoexperts.co.uk/heat-pumps/top-countries).  

To achieve mass roll out it seems also to be generally agreed that the market needs to be opened up beyond the special purpose fly-by-night companies that have grown up to harvest the grant, don’t do a particularly good job, don’t have a roadmap to mass adoption and, through MCS, are stifling innovation and cost-effective system engineering.  Furthermore they are structured for, and probably quite happy with, low volume-high price.  Arguably this means opening it up to local plumbers and electricians, who today are excluded from the market, but certainly it means opening it up.  Some other work force changes may be needed as well, discussed above.

So in this post Im going to try to summarise the regulatory changes that it has been suggested are needed, and invite constructive comments.  Engineering/workforce changes will be summarised separately

 

The following was suggested on another forum (buildhub) and seemed to gain some traction (although its a bit volatile so sometimes difficult to tell what is gaining traction and what isnt.

·       Kill the MCS stranglehold. That eliminates the fly-by-night grant chasers AND a good chunk of non value add tasks. You keep the requirements (e.g. the technical requirements with regards noise for permitted development) but make it the job of planners to enforce planning conditions (e.g. please prove it's adequately quiet, where here are the requirements lifted from the old MCS standards, and if you meet them them it's deemed fine, but you don't need to partake in the rest of the MCS charade)

 ·       Relax a few planning conditions too. They're asking for units to be too small. It should be permissible to have both a heat pump and an air conditioner. There shouldn't be stupid restrictions on siting R290 propane units near to doorways whilst it's still ok to keep two 15 kg propane cylinders inside your house.

 ·       Take a chill pill. AC in cars is ubiquitous. Let people do AC in houses more easily. Don't mandate that in order to receive grant funding the heat pump must deliver heat AND hot water. Chop the available grant to £1k and apply the condition that it's a packaged/tested solution with a  sCOP of 5 or above. It's pish easy to install A2A units in this ball park. They work. People will rave about them.

 In this related forum, the following package of liberalisation measures was proposed, aimed also largely at killing the MCS stranglehold

 ·                No Vat on HP at purchase - regardless who/where/how. It really got on my wick that they announced that and then there's the "oh yeah you only get zero vat  as part of an MCS install...grr..."

·                BUS if Boiler swapped for HP - for all . regardless of by who or how. Boiler removal part to be by a GasSafe engineer who signs off that its was previously in service and this audited against premises recent gas bills and boiler servicing bills to prevent fraud on the BUS.

·                Additional grant support above and beyond BUS for low-income people (means tested) to genuinely get the install price down to same as gas for them.

·                Grant support for electricity price for HP use to be same as gas to get the run cost equal or better. Requiring separate input metering prior to any structural changes in the market like moving the green levy (if ever...)

·                any qualified plumbing and heating contractor to do the work

·                an umbrella organisation providing support and advice to those heating contractors , with their decision making as to what system design  and HP type to use. and providing a warranty (And access to swat team of Seasoned Veterans to troubleshoot) if there are performance issues.

 

Pulling these together I offer up the following combined strawman:

 

1.        Permitted Development rules in relation to air source heat pumps amended to remove all reference to MCS.  The noise condition only in MCS-020 to be incorporated into the PD rules (without reference to the spreadsheet being completed by an MCS engineer)

This will address the problem that, as things stand today, only systems designed and installed by an MCS contractor are Permitted Development and, as such, import into planning rules engineering considerations which are well outside the scope of planning.

 

2.              Permitted Development rules in relation to air source heat pumps amended to allow 2(?) ASHPs provided that the combined noise meets the noise condition (and the other PD rules are met in relation to both)

This will allow a combination of A2A and A2W heat pumps, or other two pump installation, without material negative effect on the built environment

 

3.              Grant support under the BUS or similar to be available wherever a HP is installed to replace a gas boiler (used for domestic heating and the primary source of same) by a contractor accredited under NICIEC, NAPIT, GasSafe (list of organisations to be expanded), without regard to MCS or other complex design rules.  Boiler removal part to be by a GasSafe engineer who signs off that its was previously in service and that he has audited against premises gas bills (to prevent fraud on the BUS).  Support reduced to £1K if A2A installed as a part-replacement (conditions, and whether a later full replacement attracts a grant, to be defined)

This will open up the market further and allow, for example, a separately contracted consultant to design the system to the person who physically installs it, currently forbidden under the MCS rules (much like the architect-builder relationship)

 

4.              No Vat on HP at purchase - regardless who/where/how

This will remove the discrimination against plumbers who fall below the VAT threshold (who currently cannot reclaim the VAT on the purchase) and  against self-installers

 

As I say above this alone wont be enough, we also need technical and workforce changes.  I will try to summarise the suggestions for these (where they have gained some traction) in a separate post.

 

Comments/suggestions for improvements please, preferably constructive if at all possible.

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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(@derek-m)
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Hi James,

To give credence to some of your suggestions, below is what we have achieved over the past 10 years or so, and what could be achieved by others.

Over 10 years ago we had a 4kWp solar PV system installed, which immediately reduced our electricity consumption be approximately 50%.

I think that it is 7 years ago when I installed a Power Diverter, which provides much of our hot water needs and also supplements our heating needs, which I estimate has reduced our gas consumption by approximately 20%.

About 2 years ago I installed and Air to Air heat pump, which I operate most of the time from solar power, which I estimate has reduced our gas consumption by a further 30%.

So with time and effort, and minimal expense, being a Yorkshireman, we have reduced our energy consumption by 50%. Think how much better the UK energy system and market would be if everyone could do the same.

My next project will be installing sufficient battery storage, to run the heat pump for longer periods, and store solar power for overnight use.


   
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Posted by: @jamespa

Pulling these together I offer up the following combined strawman:

 

1.        Permitted Development rules in relation to air source heat pumps amended to remove all reference to MCS.  The noise condition only in MCS-020 to be incorporated into the PD rules (without reference to the spreadsheet being completed by an MCS engineer)

This will address the problem that, as things stand today, only systems designed and installed by an MCS contractor are Permitted Development and, as such, import into planning rules engineering considerations which are well outside the scope of planning.

 

2.              Permitted Development rules in relation to air source heat pumps amended to allow 2(?) ASHPs provided that the combined noise meets the noise condition (and the other PD rules are met in relation to both)

This will allow a combination of A2A and A2W heat pumps, or other two pump installation, without material negative effect on the built environment

 

3.              Grant support under the BUS or similar to be available wherever a HP is installed to replace a gas boiler (used for domestic heating and the primary source of same) by a contractor accredited under NICIEC, NAPIT, GasSafe (list of organisations to be expanded), without regard to MCS or other complex design rules.  Boiler removal part to be by a GasSafe engineer who signs off that its was previously in service and that he has audited against premises gas bills (to prevent fraud on the BUS).  Support reduced to £1K if A2A installed as a part-replacement (conditions, and whether a later full replacement attracts a grant, to be defined)

This will open up the market further and allow, for example, a separately contracted consultant to design the system to the person who physically installs it, currently forbidden under the MCS rules (much like the architect-builder relationship)

 

4.              No Vat on HP at purchase - regardless who/where/how

This will remove the discrimination against plumbers who fall below the VAT threshold (who currently cannot reclaim the VAT on the purchase) and  against self-installers

 

As I say above this alone wont be enough, we also need technical and workforce changes.  I will try to summarise the suggestions for these (where they have gained some traction) in a separate post.

 

 

There seems to be little dissent that the above package of measures would be a good set to open up the market in the way that is necessary to achieve the volume needed.  Interestingly I posted the same set of measures also on Buildhub (where responses tend to be more critical) and likewise there was no material dissent.

Before we 'bank' these however and move on, Id just like to ask a couple of questions:

 

Is there anything else in the Permitted development constraints that needs to change.  Currently they read (summarised)

 

No more than 1 ASHP - which we are proposing should be changed to 2 - see above

The development must comply with MCS planning standards or applicable standards - which we are proposing should be changed - see above

 

and then:

 

a. the volume of the air source heat pump’s outdoor compressor unit (including any housing) must not exceed 0.6 cubic metres;

b. the air source heat pump must not be be installed within 1 metre of the boundary

c. the air source heat pump must not be installed on a pitched roof;

d. the air source heat pump must not be installed on a flat roof where it would be within 1 metre of the external edge of that roof;

e. the air source heat pump would be installed on a site designated as a scheduled monument;

f. the air source heat pump would be installed on a building or on land within the curtilage of the dwellinghouse or the block of flats if the dwellinghouse or the block of flats is a listed building;

g. in the case of land within a conservation area or which is a World Heritage Site the air source heat pump must not be installed on a wall or a roof which fronts a highway or  be installed so that it is nearer to any highway which bounds the curtilage than the part of the dwellinghouse or block of flats which is nearest to that highway

h. in the case of land, other than land within a conservation area or which is a World Heritage Site, the air source heat pump must not be installed on a wall of a dwellinghouse or block of flats if that wall fronts a highway the air source heat pump would be installed on any part of that wall which is above the level of the ground floor storey.

i. the air source heat pump must be used solely for heating purposes;

j.the air source heat pump must, so far as practicable, be sited so as to minimise its effect on the external appearance of the building and the amenity of the area;

 

To me the ones which may need modifying are

(a) should this be per unit if there are 2 units, or just bigger in total

(b) is this constraint necessary at all given the sound constraint?

(d) I presume this is a H&S requirement, but it rather depends on which way it is facing.  Is this constraint really needed?

 

I think (i) can stay as it, it says 'used'.  So an ASHP which is capable of being used for heating and cooling but which in fact is used only for heating is PD.  Obviously this is nigh on unenforceable, but it seems to me that the existing wording is not materially detrimental to the cause of mass roll out for heating.  

 

Also, part of 3 'Support reduced to £1K if A2A installed as a part-replacement (conditions, and whether a later full replacement attracts a grant, to be defined' and 4. - No Vat on HP at purchase - would appear to apply to aircon used for cooling alone.  Is there a way to prevent this potential abuse? 

 

Comments please.

 

 

4kW peak of solar PV since 2011; EV and a 1930s house which has been partially renovated to improve its efficiency. 7kW Vaillant heat pump.


   
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Posted by: @jamespa

To me the ones which may need modifying are

(a) should this be per unit if there are 2 units, or just bigger in total

(b) is this constraint necessary at all given the sound constraint?

Agreed that the volume limitation needs to be looked at again. Graham Hendra made a point in this blog post; bigger units can have more sound insulation around the compressor making them quieter. Are there volume rules on the continent that manufacturers are likely to align to? The UK market is currently a fairly small market (especially given the number of installations currently taking place) and places like Germany and France are more likely to have sway with manufacturer design decisions.

I think that rule b) (1 metre from boundary) should also be changed (or eliminated). In terraced houses with relatively small gardens it is fairly difficult to site a unit; my garden is about 4.9m wide. According to this blog post

Around a quarter of the population live with a neighbour on each side of them in a set of three or more uniformly designed houses, sharing common materials and plan forms.

It would be good to know the rationale behind rule c). I would guess that a pitched roof is likely to reflect much of the sound into the air away from other buildings.

I'd be tempted to just drop rule i) as it seems unenforceable and puts additional red-tape on A2A heat pumps. Alternatively perhaps it could be inverted to "the air source heat pump must be used for heating purposes" to rule out cooling-only applications?

I'm not sure it is worth trying to eliminate air-con from the zero-rated VAT scheme. These can not be installed by DIY-ers (unless they are F-gas registered, which is unlikely) ... did I read somewhere that only F-gas registered entities can buy such things?

 

   
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