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My Response to DECC’s Consultation on the Renewable Heat Incentive
I set out below the questions in the RHI Consultation together with my answers. I have underlined the questions.
- What are your views about the proposed approach of a universally available tariff scheme? Is a tariff scheme the most efficient way to drive down technology costs, increase innovation and value for money, together with developing a homegrown supply chain? Please include reasoning for your response.
I cannot be sure that a universally available tariff scheme is the best option for all technologies.
a. DECC wish that its approach to renewable heat be “technology neutral” or technology agnostic. However, different technologies have different features. The most important feature that renewable heat has is that unlike any electricity renewable heat can be stored and used later with the minimum of cost and environmental disruption. A tariff seems to reward the production of heat, possibly the production of useful heat, but have no allowance for storage of heat. Therefore it should be worth address heat storage.
b. Driving down technology costs will occur when technologies can be installed on an industrial scale (many repetitive installations as happened with the PV tariffs) and in volume (as also happened with PV tariffs. In fact the volume of PV installations was such that not only did prices of the product fall (which DECC picked up) but also the costs of installation fell just as sharply. Many technologies of renewable heat do not easily lend themselves of large scale installation. Some, if installed on a large scale, would have adverse environmental effects – air quality and biomass burning for example. Others like heat pumps seem to be sold on price rather than quality and efficiency, as the questions in this consultation acknowledges. I doubt whether a tariff will be as effective as a single lump sum incentive, but it should drive costs down.
c. A tariff will not increase innovation. At Genersys we have developed a solar source heat pump, which is innovative but does not fit into any existing category. If a tariff is to encourage innovation the categories must be sufficiently flexible to do this, and I doubt if they are at present.
d. Value for money is important, but not at the expense of high quality. This is especially so when the subsidy will be 20 years’ worth of subsidy paid over 7 years. We can see that with boiler replacement people usually buy the cheapest, not the most efficient or the boiler which consumes the least or which has the lowest servicing costs or the lowest polluting. As a principle renewable heat devices should be of high quality and the present rules do not really address the need to incentivise high quality.
e. Domestic renewable heat incentives should be targeted at (i) owner occupiers (ii) social landlords and (iii) residential tenants. With the PV incentive we saw the creation of an investment market in PV electricity production, where many PV installations were combined and sold as investment products. This has created legacy problems for the Government and will create legacy issues for the investors as the ROI lessens as the PV wears out and loses efficiency. It has also created the probability of government subsidising the production of renewable electricity at times when it is not needed by the grid, which is not a proper use of public funds. Renewable heat should not be devised to attract this kind of investment and behaviour and by targeting the subsidy at the occupier, rather than the investor, we will produce a useful heat based outcome, rather than a pure investment based outcome.
f. The consultation document states “The Government’s vision and strategy for decarbonising heat across the whole economy is set out within a three stage strategy in the ‘Carbon Plan’ published in 2011…. The non-domestic RHI and the Renewable Heat Premium Payment (RHPP) are already encouraging early uptake of low carbon heating, as well as innovation and building of supply chains for low carbon heat technologies. “ Those statements are inaccurate in two respects (i) burning biomass cannot in any way be called decarbonising heat; if anything where biomass replaces natural gas, heat is generated with more carbon intensity relying on replanting to soak up some of the carbon created and (ii) the RHPP is not encouraging early uptake of low carbon heating but it is encouraging the uptake of biomass.
2. Do you think that there would be advantages in phasing or piloting roll out of the scheme? On what basis do you think it might make sense to phase or pilot the scheme?
I think that there is no advantage in phasing or piloting roll out of those parts of the scheme which are ready. The renewable heat industry has suffered greatly in the past years when there has been no significant renewable heat incentive. More than half the businesses involved have closed down in that period. To increase confidence it is important that roll out happens all at once and as quickly as possible.
3. Do you think that there may be alternative or additional approaches to incentivising renewable heat deployment that we should pursue? What approaches do you think might add most value?
I think that different incentives should apply to different technologies, as I shall explain later. I think that solar thermal water heating is essentially different from space heating production and sufficiently so different as to require separate, simpler regime and incentives, such as a single payment incentive. I shall explain where this should be later in my answers to this consultation.
4. Do you have any comments on the proposed exclusion of second homes from the RHI?
I think that clean renewable energy (not biomass) should be encouraged whether in first or second homes. I think that there is a case for differentiation and would suggest that the second home incentive is one half of the main home incentive. In the case of solar thermal water heating summer second homes will use most of their heat for heating water and it is as important that this is decarbonised as heating in first homes, so I would not differentiate in the case of solar water heating.
5. Do you have any comments on the proposed approach to private landlords and their tenants under the RHI? Have you any suggestions about how to ensure that the RHI incentivises the installation of renewable heat in the private rented sector and does not disadvantage tenants?
This is not a problem for solar thermal installations as I see it. Solar thermal, unlike biomass and heat pumps, requires no fuel to be purchased by the tenant. With solar thermal the landlord should get the incentive as the home owner and the tenant will get the savings, which will be worthwhile.
6. What are your views on our proposals for the treatment of legacy applications for installations between July 2009 and the opening of the scheme?
The proposal in this regard seem sensible and practical.
7. Are there any other legacy applicants (aside from those that have received RHPP or installed renewable heating systems since 15 July 2009) that you think we need to consider?
No.
8. What are your views on phasing legacy applications over the first year and the option of setting a cut-off date for legacy applications?
I do not see the need to phase legacy applications; after all if the RHI was brought in when first promised there would be no legacy applications. A cut-off date seems sensible.
9. Do you agree with the proposed approach to the selection of eligible technologies for the domestic RHI scheme? Please include reasoning for your response.
You state that the technologies should be appropriately tested and certified and “should adhere to certain principles” but do not identify the principles so it is impossible to answer this consultation question. If you identify the principles I shall be pleased to comment upon them.
I agree with the technologies selected except I would add caveats in the case of all heat pumps. The heat pump standards for efficiency in the UK are extremely low, compared with Germany and I see no real “renewable” element in a heat pump that has a coefficient of performance that falls to 1 in very cold weather, which is when the heat is required. Further I can see little point in using a heat pump to heat water in summer, when the same carbon output is achieved by using natural gas. Electricity which drives heat pumps is not a renewable resource in the UK and will be unlikely to become one for many decades, long after heat pumps installed today have stopped working.
10. Do you agree with the proposed eligible technologies set out above? Are there others that should be considered for inclusion?
Subject to the caveat in 9 above, I agree. You should also include the new Genersys solar source heat pump as an eligible technology.
11. Do you agree that an approved suppliers scheme is the best option for domestic biomass heat installations to demonstrate their use of sustainable fuel? Please provide reasoning with your response.
Yes, but the sustainable nature of the fuel, proved by purchase invoices, is not the only sustainability criterion that you should consider. The distance that the fuel travels to the installation is particularly important with biomass which has high volume in relation to calorific output. If you fail to do this you run the risk of incentivising long distance transport of biomass, in effect.
12. Do you agree that as part of the approved biomass supplier list we should assume a level of boiler efficiency? Please provide evidence to back up your response.
I am not an expert in biomass boiler technology but fail to understand why efficiency standards should not apply to biomass boilers as they do to every other fuel consuming boiler. Efficiency is important where the technology consumes significant fuel or electricity. Efficiency is barely an issue where the technology consumes no fuel and virtually no electricity.
13. Do you agree that April 2014 is an appropriate date from which to start requiring users of domestic biomass heat installations to provide proof of meeting the sustainability criteria? Please provide reasoning with your response.
I would prefer an earlier date.
14. Is the air quality approach set out appropriate for the domestic RHI sector? Please provide your reasoning with your response.
No. the air quality standards are far too low. Air quality is an important issue and the United Kingdom risks fines from the EU if it fails to improve air quality in some cities. Air quality standards should be improved for biomass quite significantly to take account of the UK’s urgent need to improve air quality. However, there is one serious omission. In the case of biomass boilers air quality depends not only on the standards of emissions of the boilers, BUT ALSO ON THE REGULAR SERVICING OF THE BOILER BUT THE RHI PROPOSALS MAKE NO PROVISION FOR PROOF OF REGULAR SERVICING OF BIOMASS BOILERS.
15. Do you have any views on our proposals for excluding certain technologies? If you would like to suggest changes, please provide evidence to support your view.
I have no views.
16. Do you agree with our proposed approach to efficiency requirements for heat pumps?
No. I think it is perverse to support heat pumps of a SPF of 2.5 while saying that you want to encourage the use of better specified heat pumps. Efficiency is very important in heat pumps and there is no reason why the standard for heat pumps should be at the lowest level permitted by the EU.
17. Do you agree with our assumption that heat pump systems, using technology that meets MCS efficiency specifications, should meet an SPF requirement of 2.5 providing they are designed, installed and used appropriately?
No. I think that there is no margin for error in your assumption.
18. Do you think that the ‘Green Ticks approach’ to an energy efficiency requirement is appropriate to the RHI? Please provide reasoning for your response and further information on any exceptional cases you think might arise
It is appropriate except in the case of solar water heating. Insulating a home well or badly makes no difference to the performance of solar water heating, where you need to insulate the pipework and the cylinder, for a difference to be made. Home insulation – the green ticks – is essential for space heating in order to justify the space heating subsidy. However, this is not the case for solar water heating. There was no requirement that properties should be insulated which applied for Photo voltaic electric feed in tariffs and it is illogical to require Green Ticks for solar thermal except to the extent that pipe works and cylinders must be properly insulated.
19. What are your views on our proposal to require consumers to have installed energy efficiency measures and provided proof to Ofgem before they become eligible for the RHI? Can you suggest an alternative approach that guarantees the installation of the green tick measures, but provides RHI subsidy at an earlier point?
I have no comment to make about them, save in respect of solar thermal where these energy efficiency measures will not make the solar water heating work better or more efficiently.
20. Do you think that solid wall insulation should be excluded from the energy efficiency requirements or be introduced in a phased way? Please provide evidence for your response.
Solid wall insulation is difficult and expensive and I think it should be excluded from the requirements, but with a marker put down to the effect that this will be reviewed from time to time, otherwise you run the risk of those needing the subsidy the most will not be able to afford the solid wall insulation and should therefore be excluded.
21. Do you think that 7 years is a suitable time period for tariff payments under the RHI to be made? Would a different time period for tariff payments suit different technologies? Please provide evidence to support your view.
At this stage I think that we must distinguish between technologies. The problem that you have with paying for 20 years heat over seven years is that not all technologies will have a lifetime of 20 years.
Most boilers will not last 20 years, I can say from my personal experience.
Well made solar thermal flat plates like those of Genersys have a 20 year guarantee and a 35 year life expectancy, so that there is no problem with paying in advance for a good solar water heating installation.
There are potential problems with evacuated tube solar water heaters because not every manufacturer offers a 20 year guarantee and there may be difficulties in enforcing such guarantees where the manufacturer is outside the EU and the distributor is not financially sound. However most domestic solar water heating installations are now made using with flat plates, rather than evacuated tubes.
22. Please provide evidence on the potential lifetimes for the different renewable heating technologies, particularly where they are expected to last less than the 20 year period that we are assuming.
I can only provide evidence in relation to Genersys solar thermal flat plate panels (all types). In the United Kingdom Genersys has had a significant market share of the flat plate solar panel market, probably in excess of 25%.
We have been selling these panels in the United Kingdom since 1999. Every installer is asked to complete and register a guarantee form with us after the installation has been completed to the customer’s satisfaction. Genersys guarantees the panels for 20 years and the ancillaries for 2 years.
Since 1999 we have not had a single panel guarantee claim. We have not had a single pump station guarantee claim in that time and have had merely a handful of faulty controller claims. Controllers and pump stations are modular and easy to replace. These matters have been a feature of the company’s accounts and statements filed at Companies House.
It is therefore submitted that high quality thermal solar water heating will last significantly in excess of 20 years.
23. What is the risk of switchback after the period over which tariff payments are made? Do you think this applies solely to biomass?
Our customer research at Genersys tells us that people are very happy with their solar water heating so I think there is no risk of switchback in the case of solar thermal.
With biomass there is a risk of switchback when the incentives stops being paid especially if the cost of biomass is then significantly higher than an alternative. In these circumstances I deem it risky to pay for 20 years biomass performance over seven years, especially when the biomass boiler may not last more than ten years.
24. Do you think that either of the proposed solutions would mitigate the risk of switchback? Which approach would be better? Is there any other action we could take to ensure the continued use of biomass in this way?
I have no ideas that would assist you.
25. What do you think are the other risks associated with paying a tariff over a shorter period, say 7 years, but assuming heat delivered for 20 years? How do you think we should mitigate these risks?
The risks are:-
1. Switch back to fossil fuel for biomass due to cheaper fuel
2. Switch back to fossil fuel for biomass due to boiler failure
3. Switch back to fossil fuel for heat pumps due to high electricity costs
4. Switchback to fossil fuel for heat pumps if heat pump fails and is more costly to replace than with a fossil fuel alternative.
5. I do not see any such risks associated with solar water heating which of course does not use fuel and will last more than 20 years.
I would therefore think it wise to pay the incentive in the case of biomass boilers and heat pumps over the whole 20 year period, but pay the solar thermal water heating incentive upfront in one lump sum.
26. Do the tariff ranges above accurately reflect the costs faced by consumers installing renewable technologies? Where possible we would welcome cost-based evidence that supports your views.
It is not easy to say, in the case of solar thermal. The costs of installing solar thermal almost always include the cost of installing a new cylinder to store the water. A new cylinder built to modern specifications means that the house user will produce fewer emissions when the solar thermal is not providing energy.
27. What are your views on the support for solar thermal as set out? What evidence is there to support a tariff higher than the renewable energy cap? Do you have any suggestions / views on other ways in which a subsidy for solar thermal could be paid, for example, through a capital grant or through increasing the tariff beyond the cap?
Historically solar thermal has been the favoured and most popular microgeneration technology until the market was distorted by over incentivised feed in tariffs for PV. Since then DECC’s policies rather than being “technology agnostic” have discriminated against solar thermal.
Solar thermal is essential different from the other heat technologies being incentivised because (a) it requires no fuel of energy from fuel based electricity (b) it does not need high levels of maintenance, as the consultation document acknowledges, in that it is a “fit and forget” technology” (c) it does not require home insulation to work properly or efficiently (d) efficiency is not an issue because the source of energy – light – is free (e) it does not produce any emissions directly or indirectly thus assisting the improvement of air quality and (f) it can be fitted in conjunction with biomass and ground and air source heat pumps making them consume significantly less fuel and electricity respectively. Therefore I submit that it makes sense to make a substantial one off grant for solar thermal.
I submit that the evidence to support a cap higher than 17.3 p per kWh lies in DECC’s own statistics of (a) the take up of the present £300 grant, which has been very small and (b) the very poor take up of solar thermal in the non-domestic RHI. For householders solar water heating is a very easy to understand technology, it has no on-going costs and traditionally it has been very popular in the UK until the market was distorted by the PV FIT.
I advise that (a) the subsidy should be increased beyond the cap significantly and (b) it should be made as a single payment based on the size of the system being installed. This will level the playing field and enable a reasonable take up of solar water heating. It will also enable, quite easily, the householders off the gas grid to enjoy significant savings in energy costs which will finance the non-subsidy element of the cost of an installation.
28. What are your views on the support for ground source heat pumps as set out? What evidence is there to support a tariff higher than the renewable energy cap?
I have no views.
29. What are your views on differentiated tariffs for ground source heat pumps?
The RHI should pay according to the efficiency carbon benefit, not a single flat rate.
30. Do you have any data that you can share on the current market split between borehole and ground array GSHPs, associated costs and the likely future demand of these?
No
31. Are there other factors which should be taken into account when calibrating the tariff levels for either air source heat pumps or biomass boilers if the value for money cap were to become applicable to those technologies?
No
32. Do you believe that the introduction of a domestic RHI tariff for new build is appropriate? If so, what additional costs and/or savings should DECC take into account if setting a new build tariff?
Yes, unless the building regulations are upgraded to make installation of renewable heating mandatory.
It is easier to fit these technologies ab initio than retrofit them.
An installer will be able to provide better evidence than a manufacturer in the case of solar thermal. There will be no savings of items to be fitted – in fact the hot water cylinder required will be general more expensive than the one the new builder would have fitted because it requires twin coils, and is larger. The savings will be in the installation because (a) plumbers will be working in a house in the course of construction which is always easier and quicker than working in an occupied home and (b) installers can use the builders’ scaffolding, saving the installer a very substantial cost of scaffolding to fit the solar panels on the roof.
33. Do you have any evidence on the percentage cost reductions associated with fitting a renewable heating system into a new building, compared with retrofitting it?
I have no evidence, but my best guess, talking to installers is that a complete system will cost 20% less in retro fit, and more if builders can take advantage of the economies of scale.
34. If you do not agree with a domestic tariff for new build along the lines proposed, can you propose alternative ways to incentivise the uptake of renewable heating in the sector?
No comment.
35. In light of the above, do you think we should introduce a domestic RHI tariff for social landlords? Why/why not?
I think that a domestic RHI for social landlords should at this stage be limited to solar water heating. Many social landlords have had experience of solar water heating and could arrange to install it in individual homes. I do not think, notwithstanding their ability to get cheaper finance, support should be at the same levels as the rest of the RHI, but limited to solar water heating.
36. Do you think that the proposed 7 year period for tariff payments would be appropriate for social landlords too or would another timeframe within the 20 year life of equipment be more appropriate?
My comments previously made about time frames still apply here.
37. Do you have any evidence on the percentage differences to costs/benefits of fitting individual renewable heating systems into social housing?
No
38. Is there an alternative way in which you think we should incentivise renewable heat in the sector?
No
39. Do you agree that deeming, as opposed to metering, is the most appropriate approach on which to base the calculation of RHI payments? If not, why not?
Yes for solar water heating.
40. Do you agree that a calculation by the MCS installer, or equivalent, is the best approach and that the above criteria are adequate for developing an effective calculation?
Yes
41. Do you have any views on which calculation would be most appropriate for deeming heat? Please provide evidence to support your claim.
In the case of solar thermal I suggest a simple approach is used. The great danger is deeming heat is that the methodology will choose the hottest collectors, thinking that they will produce the most heat, but that will be flawed, because collectors designed to produce a great deal of heat have a very short life. I explained the flaws in the SAP approach in http://robertkyriakides.wordpress.com/2009/07/24/sap-2009-consultation-the-solar-thermal-aspects/ . I repeat the most relevant parts for this consultation here:-
The home building industry (reports one of our major distributors) is purchasing solar thermal panels on the basis that they have to “conform” to draft SAP2009, and have a linear heat loss coefficient of less than 4.
We should explain that Genersys’s panels designed for domestic use (not for industrial use) have a linear heat loss coefficient of more than 4. This is not because we do not know how to design the (roughly) quarter of a million square metres of panels produced by our associated factories in Slovakia and Greece, or because we wish to save money on insulating the panel. There is no problem (as our competitors show) in reducing the linear heat loss to below 4, so why does Genersys require its panels for residential water heating to have a higher linear heat loss co-efficient that its competitors?
Different testing stations even though they test to the same principles have different results for the same panels. According to One test station Genersys 1000-10 panels has a heat loss coefficient of 4.954 while another logs this as 4.391.
We fail to understand why it is assumed for the purpose of SAP2009 that a heat loss co-efficient of arbitrarily set at less than 4 provides better performance and greater carbon savings that a higher linear heat loss co-efficient because:-
(a) Solar panels must be balanced; if they are designed to have a low heat loss coefficient then the panels and the systems will over heat regularly. Overheating will lead to high stagnation temperatures. This means high wear and tear on the absorber surface and failure on joints seals and valves caused by overheating.
(b) You can design a solar panel with a very low heat loss co-efficient – it is not difficult – simply use very high insulation. However the wear and tear on the panel and the system as a result of heat loss would mean a short working life of the panel. This is important because all the panel testing only measures heat when the panel is new, not after years of working life.
(c) Replacing failed panels and systems caused by overheating is pointless, in terms of carbon saving. Genersys panels are provided with a 20 year guarantee because they have a higher than average heat loss co efficient. If we were required to produce panels with a lower heat loss co efficient by the market’s reaction to SAP2009 then we would do so but (i) only for the UK market and (ii) only with reducing our panel guarantee from twenty years to ten years.
(d) Keeping more heat within the panel will also lead to quicker degradation of polypropylene glycol used as a heat transfer anti-freeze fluid. This has carbon and cost implications for dwellings.
(e) The difference in heat gained with a heat loss co –efficient of 5 or less than four is not significant[ii], because the solar system is available to collect energy in all daylight hours.
(f) Far greater savings of carbon can be achieved by (i) properly and fully insulating the heat exchange pipe circuit to prevent loss of useful heat rather than calculate loss of heat that is not useful in the collector and (ii) specifying and calculated the heat loss from the cylinder; that is significant because it is useful captured heat losses that should be measured not theoretical uncollected heat.
Third Submission; Efficiency at Zero Loss is also a concept that should not form part of the algorithm used under SAP
The Genersys 1000-10 panel measures (in its latest test report) efficiency at zero loss at 0.776. The building industry is taking SAP2009 as requiring a “better” zero loss performance of 0.814 or higher.
In fact this is a complete misunderstanding of the efficiency of solar collectors which unfortunately SAP2009 is unwittingly encouraging. It should be noted that the output from the panel at zero loss efficiency is 1380 Watts.
The efficiency of solar collector ŋ0 is influenced by: Optical heat losses (absorption of selective coating and transparency of glass), these two values are NOT related to any temperatures
Thermal losses; which are dependent on delta T of absorber surface and air temperature around the collector.
If you heating a swimming pool, the mean temperature of glycol inside the collector (Tm) is almost the same as air temperature around the collector (Ta). (x=0). In this case the optical efficiency of collector with selective coating or without selective coating is similar or equal to 80% efficiency.
Higher efficiency, around 90%, is achieved by unglazed collectors (plastic mats) because there are no optical losses. Lower efficiency, around 60%, is reached by evacuated tubes. Evacuated tubes have higher optical losses than flat plate panels which are caused by round sides of tubes and their lower absorber surface area.
X = Tm-Ta (m2KW-1 )
Gk
Tm – mean collector temperature
Ta – air temperature
Gk – global radiation
When you heat potable hot water, in most cases satisfying temperature Tm should be 35 -40 K higher then Ta which with average global radiation 800W.m-2 which is equal to x=0.05. In case the efficiency of good quality flat plate panel (with selective coating) and evacuated tubes is the same, around 55%. Due to high thermal losses collectors without selective coating (cheaper flat plate panels) reach efficiency only 40% and lowest, 20%, is achieved by unglazed solar collectors.
If you use solar collectors to support space heating (low energy heating) delta T (Tm-Ta) is 40-55K, but the average solar radiation is only around 400-500 W.m-2 In this case x = 1 and highest efficiency, 45%, is achieved by evacuated tubes or vacuum flat plate panel where the vacuum eliminates thermal heat losses. Good quality flat plate collector has at this point around 28-30% efficiency, which is around 2/3 of vacuum collector. Using low quality flat plate collectors (without selective coating) is inefficient.
The real efficiency of solar collector is related to overall quality of solar collector, and the yearly working efficiency of collector is related to details such as quality of selective coating, type of glass, collector ventilation (breathing holes) and thermal insulation. Combination of all these matters defines difference between good and poor quality panel.
The collector efficiency at zero losses is absolutely ideal state and it change within seconds. In terms of thermal insulation: if you review all above, unless you substitute insulation drastically, (e.g. mineral felt for vacuum as in the Genersys 1450), the overall efficiency is not influenced. The important thing is type and quality of coating on absorber.
We have checked the specification of one of our competitor’s panel the Worcester Bosch. Worcester Bosch’s most popular panel has 55 mm thick thermal insulation, where the Genersys 1000-10 has only 40 mm. It is obvious why the Worcester Bosch’s thermal insulation is better.
Most of the panels perform very well at their first year, but no one ever check how panels perform after years of usage. Genersys panels are constructed to last and provide sufficient output for years but are being penalised by using inapplicable SAP methodology.
Comparisons
The web address sets out the key comparators between Genersys and Worcester Bosch to illustrate my point:
If the SAP 2009 calculations take account of Zero Loss Efficiency then the market will be pointed towards panels that have short working lives and are prone to overheating. Overheating is very significant in thermal solar systems for many reasons. For example regulations require three different safety devices in thermal solar systems to overcome dangers from overheating, even if automatic mixing valves are installed.
Conclusion
Domestic water systems need to heat water to around 42ºC – 45ºC. A good low carbon solar system does not seek to collect as much energy as it can, but to manage the energy that it collects most efficiently. Draft SAP 2009 is written to encourage the collection of as much energy as possible without regard to the management of the collected energy, its usefulness or the effects of overheating on solar systems.
Those observations were made in July 2009 and are still relevant.
Having given careful consideration I suggest that deeming is carried out, in the case of flat plate panels, on the basis of panel size (it does not really matter if you use the gross or net surface area and cylinder size, on the basis that two square metres of flat plate will heat 100 litres of water. the average UK installation will be four sq metres of panels and 200 litre cyliner with larger homes having six sq m and 300 litres.
42. Do you agree with the approach outlined here for the treatment of bivalent systems?
Yes. I think that the bivalent approach in the consultation document is very well thought out.
43. Do you anticipate that financing offers will come forward from the market to provide support for renewable heat in conjunction with the RHI? If not, is there anything DECC could do to support this?
Financing offers will only come if the incentive is attractive enough for the financing company to see a margin for itself and for the customer.
44. To what extent do you believe the ability for some consumers to fund their renewable heat installations through Green Deal and the RHI will improve deployment of renewable heat?
I am not sure that the Green Deal is developed enough conceptually to be able to make a prediction.
45. Do you agree that a metering and monitoring service package like the one we have outlined would be effective at driving long-term system performance improvements?
Efficiency in the sense used in this section of the consultation is not a concept that applies to solar thermal water heating, because the “fuel” is free. It makes no difference if your water water heats up slightly more quickly or slowly because you rely on stored hot water which you mix with cold water to get domestic hot water in your taps.
Having said that solar water heating systems can be monitored and there is robust technology for remote monitoring over the internet.
Metering and monitoring is important for renewable space heating where fuel or electricity is concerned.
46. Do you think that the additional financial support in option 1 should be distributed as a flat-rate increase to the RHI tariff, a one-off upfront payment or in some other way?
I prefer a one off payment to cover the additional monitoring set up and equipment costs.
47. Do you offer a system that already provides some of the requirements outlined in option 1? If so, please can you provide details of how your system works and whether you would be interested in helping us develop this proposal further.
Yes; Genersys has systems for monitoring solar water heating including remote monitoring connection to the internet which may be of use to you and we would gladly work with you on this.
48. Should consumers’ RHI tariffs for heat pumps vary according to the measured or estimated performance of the system? Do you think installers would offer performance guarantees if this was offered in the RHI? Please comment on the method we have described in option 2.
It is critical that tariffs for heat pumps should vary according to the performance of the system. The Genersys solar source heat pump (not yet available for a RHI incentive) uses a high performance heat pump with a COP in excess of 4 and such heat pumps are inevitably more expensive. We need to encourage quality not cheap products, because nothing will damage consumer confidence more than poorly performing renewable heat products.
49. Do you think that setting a minimum SPF higher than the EU minimum for air source and ground source heat pumps could be an effective driver of performance? What figure do you think might be suitable?
Yes it will drive the raising of performance standards. I suggest raising the SPF to 3.
50. If we took this approach, should the minimum SPF required increase over time? Please comment on how quickly you think the required SPF should rise and to what level it should rise.
The SPF should rise beyond 3 every year in increments of .1.
51. What are your views on the use of the RHI budget to pay for metering equipment to be installed for the purpose of policy evaluation?
The RHI budget should be used for the RHI incentives, not policy evaluation.
52. What are your views on the proposal that we should share data with MCS Certification Bodies so that it can be used to improve MCS installer surveillance?
It sounds very sensible and should drive standards upwards.
53. What are your views on the requirement to make all installations meter ready and the use of an Installer Checklist?
I have no views except in the case of solar thermal making the installations meter ready is not necessary.
54. Do you agree that there should be a financial penalty for consumers who do not ensure their installation is ‘meter ready’?
Yes, save for solar thermal, but perhaps the penalty should be on the installer, rather than the consumer.
55. Should the penalty for consumers who do not make their installation ‘meter ready’ be the loss of the first year of their RHI payments or a reduction of all of their payments? What other penalty might be appropriate?
I think no penalty should apply to the consumer.
56. What are your views on providing a tariff uplift for systems where solar thermal is installed alongside other renewable technologies?
I think that the consultation document has understood a very important point. A typical Genersys solar water heating system properly sized will make the use of back up heat for hot water unnecessary for at least six months of the year. That is a large saving in fuel costs and in carbon dioxide emissions. An uplift of sufficient amount to encourage solar water heating systems will make the other renewable heating system more effective, and will make it last longer as it will not be used to heat water in summer and will be used more for space heating and less for water heating.
57. Do you have any evidence on the size of tariff that should be provided in order to encourage the deployment of these systems?
I have no evidence.
58. Are there any other approaches that you think could drive continued improved performance of renewable heating systems?
A successful and thriving market for renewable heat, particularly high quality renewable heat, will create the conditions for the research and development of the products necessary to sustain this market effectively. At the moment there is no effective UK market for domestic renewable heat.
59. What are you views on the options for the proposed pattern of payments?
Quarterly payments in advance
60. Do you think that MCS (or equivalent schemes) will provide sufficient consumer protection for the RHI or should additional consumer protection be built into the scheme? If you think more is necessary, please explain what you think is required.
I have no doubt that MCS and solar key mark provide plenty of consumer protection, as does the existing law. As always mis-selling may be a problem so there should be a code of conduct for selling renewable heat for RHI incentives.
61. Do you agree that our proposed approach of an annual consumer self-declaration, supported by supplementary spot checks is the best way to ensure that equipment installed under the RHI continues to be operational and generate heat optimally over time? What should the penalties for non compliance be? If you think that the proposed approach is not the best or could be improved, please set out your reasoning and any evidence to support that.
I agree with that approach.
62. Are there other risks of fraud or gaming that we have not identified in the table above?
None that I can identify.
63. In terms of communicating the RHI scheme to consumers and other interested parties, what do you consider that the role of government should be?
I have no views.
64. Do you have any comments on how RHI information to support and guide consumers along the journey should be provided? If so, please set them out.
No
65. Do you have any comments on or additions to the identified events and issues affecting the consumer along the Customer Journey? If so, please set them out.
No
66. Are there any specific customer journeys that you feel would be helpful to analyse? If so, please set them out.
No
67. Do you have any comments on or additions to the actions identified here? If so, please set them out.
No
68. In particular, do you have any comments on how to make the RHI and Green Deal relationship as seamless as possible in order to minimise disruption to the consumer? If so, please set them out.
I have no comments.
69. Do you agree that the system of degression described would provide us with a sufficient means of controlling the costs of supporting the domestic RHI scheme? If you would prefer a different approach to budget control then please set out what that might be and how it might operate.
I understand the rationale for the “degression” approach although if used it will inevitably create uncertainty amongst the market, which is not a good thing.
70. Do you agree that we should build in greater flexibility to the system such that degression might not occur if overall deployment levels are low? If yes, how do you think this could be achieved?
Yes. “degression” should be able to work upwards if take up levels are too low.
71. How do you think we should set triggers which would result in tariff reductions to ensure fairness, value for money and certainty? Do you agree with the options presented, or would you prefer we took an alternate approach?
I would prefer you took a different approach. I cannot see that triggers that are pre set create certainty; if anything they enhance uncertainty. It is better to reserve the right to “degress” and use it sparingly and modestly.
72. Would you prefer a system which announces any tariff rate reductions every two months (with up to a one or two week notice period before the reduced rate comes into effect), or on a quarterly basis (with up to a months’ notice period)? If you would prefer a different period please set this out and explain why.
I prefer a quarterly basis with one months notice.
73. Do you agree that the system should specifically recognise legacy applicants when calculating whether trigger points have been met? Do you agree with the options presented, or would you prefer we took an alternate approach? If yes, then please provide details.
Yes.
74. Do you agree that we should base degression calculations and triggers on pounds spent, or do consider it would be more appropriate to use an alternative approach, such as installed capacity and renewable heat produced? Please provide reasons for your preferred approach?
If the rationale for degression is financial budget management then you have no option but to base it on pounds actually spent (not “committed” because the commitments might not come to fruition. You have to have a “use it or lose it” policy with people who apply for incentives.
75. Do you agree that we should not apply EPA or a similar option to the domestic scheme? If not, why not? How could this work?
I agree that the EPA should not be applied to the domestic scheme.
Filed under: carbon emissions, climate change, energy, global warming, solar, solar energy, solar panels Tagged: genersys, renewable heat, renewable heat incentive, RHI, RHI Tariffs, solar panels, solar water heating 
2012-10-03 23:42:27
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