The changes permit applicants to ignore previous requirements to install minimum standards of loft and cavity wall insulation building fabric recommendations that are included within their home’s Energy Performance Certificate (EPC).
The Government has not revealed details of any research its undertaken on the impact of this policy change, and in taking this step has ignored the findings of its own consultation – over 75% of respondents actually supported retaining existing requirements on minimum insulation building fabric requirements.
The policy change is about driving heat pumps sales but breaks with the long-established fabric-first retrofit principle. This increases the risk of poorer outcomes for consumers due to more expensive heating bills and less efficient installations. OFTEC argues the requirements were there to protect consumers by ensuring their home was optimised for a heat pump.
Risk of mis-selling
It also increases the risk of mis-selling. While reputable installers will specify the heat pump system correctly, even if that results in a more costly design, less scrupulous installers could use this policy change to dangle the carrot of lower prices, with little interest in the negative consequences of an underspecified system.
Even if the heat pump is sized correctly to cope with the heat demand, the owner will be left with an oversized heat pump should they later decide to improve insulation, potentially with poorer performance as a consequence.
There is also a risk that any negative publicity resulting from the change could damage consumer confidence in heat pumps and hinder further uptake. Consumers will blame the technology when the reality is it’s the poor installation.
Broader concerns
It also raises broader concerns about how far policy should go to incentivise heat pump installations and whether the benefits are being distributed fairly? For example, households benefitting from BUS grants are already better off than average, so is it right the taxpayers fund heat pumps in holiday homes – which is something BUS allows.
The BUS grants are already generous (BUS offers grants of £7,500 to help households switch to the low carbon technology) but some argue the Government should go even further in incentivising the switch.
One trade body has proposed that heat pump owners should also benefit by paying a lower rate for their electricity, suggesting that taxpayers – who have already subsidised the install – should also subsidise the running costs too.
Malcolm Farrow, Head of Public Affairs at OFTEC said: “It’s important that the wealthy are not rewarded disproportionally in the clean heat transition, or that less affluent households are left behind.
We need to focus not on simply growing the heat pump market at any cost, but instead on achieving the most cost- effective solution in every location, by using all the options at our disposal.
“For buildings where heat pumps are less suitable, such as older off- gas grid homes, owners should be supported to switch to Hydrotreated Vegetable Oil (HVO), which offers an easy transition pathway to low carbon heating for little capital outlay”.
Image credit: OFTEC
