LGA submission to Governments consultation on Phasing out the installation of fossil fuel heating in non-domestic buildings off the gas grid

LGA polling in June 2021 found that 73 per cent of respondents most trusted their local councils compared to 17 per cent that most trusted government when it came to local decision making. Based on the results of this polling, government should strongly consider forming a close working relationship with councils, via the LGA, to help facilitate consumers in making the right technical and economic choices.


About the LGA

The Local Government Association (LGA) is the national voice of local government. We are a politically-led, cross party membership organisation, representing councils from England and Wales. 

Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems.

Summary

  • ​​​​​​Councils want to work as partners with central government to tackle climate change and are well-placed to do this as place-shapers, convenors of communities and partners, delivery agents, commissioners and owners of assets. Net zero can only be achieved with decarbonisation happening in every place across the country and this will require local leadership.
  • LGA polling in June 2021 found that 73 per cent of respondents most trusted their local councils compared to 17 per cent that most trusted government when it came to local decision making. Based on the results of this polling, government should strongly consider forming a close working relationship with councils, via the LGA, to help facilitate consumers in making the right technical and economic choices. With funding, local authorities could provide a concierge service or a one-stop-shop service (depending on what works best locally) to help both consumers and local businesses make the best decisions.
  • A council led approach has the potential to further address financial barriers to heat pump deployment. Area based approaches to the installation of fabric energy efficiency measures have shown that an area-based approach can provide the market with certainty, facilitate economies of scale by coordinating consumers, increase efficiency by reducing travel costs and lost time on site and provide comfort to the consumer as the council can act as a trusted intermediary. A council led approach is very likely to have resource implications in the first instance but the potential to stimulate the market and somewhat de-risk deployment could have significant economic benefits.
  • Early indications from the BEIS Energy Efficiency Supply Chain Demonstrator Project are showing that the range of offerings from a concierge service to a one-stop-shop give both the consumer and the market confidence and increase affordability by commissioning work on a local area wide basis.
  • Councils continuously engage with groups protected under the Public Sector Equality Duty.  Partnering with councils to deliver net zero activity will ensure businesses and communities, affected by the proposals experience a smooth transition to clean heat.

Answers to consultation questions

Q1. Do you agree with the principle of using the natural replacement cycle to phase out the installation of fossil fuel heating systems in non-domestic buildings off the gas grid?

The principle of working with the natural replacement cycle is sensible in theory, however a 2026 end date for the installation of fossil fuel heating systems may unfairly impact those that have to replace their boiler in 26/27 due to market infancy. Rather than government offering a fixed price grant for early adoption, grant schemes should be made available to achieve cost parity whilst still driving competition in the market. One option could be to offer a percentage reduction to avoid price fixing in the market.

Q2. Do the 2024 and 2026 timescales for introducing this policy provide sufficient lead in time for non-domestic off-gas grid consumers to prepare for their transition to low carbon heat?

Q3. Would an implementation date of 2024 (for large buildings) and 2026 (for smaller buildings) provide sufficient lead in time for industry to prepare for the increase in demand?

Q4. Do you agree with our proposal to introduce this policy for the largest buildings first?

If government intends to focus on large buildings first there is an opportunity to work in partnership with Local Government to ensure public buildings are the early adopters. This approach enables to market to develop and grow, can facilitate local area-based planning achieving greater economies of scale, whilst also showing public sector leadership.

Q5. Do you agree with our proposals to take a heat pump first approach to the replacement of fossil fuel heating systems in off-gas grid non-domestic buildings?

Q6. Do you agree that most non-domestic off-gas grid buildings will be suitable for a heat pump?

Q7. What types of buildings are likely to fall into the ‘hard to treat’ category? Please provide evidence to support your response.

Q8. What low carbon heating systems do you foresee being used as alternatives to heat pumps in ‘hard to treat’ buildings? Please provide evidence to support your response.

Q9. Will these alternative low carbon heating systems align with the net zero, sustainability, air quality and consumer experience criteria set out as bullet points in the ‘Alternative low carbon systems’ section?

Q10. Are there instances where both heat pumps and alternative low carbon heating technologies will be unsuitable for meeting a building’s space heating and hot water demands – i.e., ‘untreatable buildings’?

We welcome Government supporting and promoting heat pumps as a preferred technology to provide zero carbon affordable heat for buildings as that provides a clear message to the market. However, the heat pump first approach needs to be put into context. Fabric energy efficiency measures should always be considered as the first intervention either before heating system replacement or at the same time. Following the consideration of fabric energy efficiency measures, in some cases, the first approach should be to connect to existing district heating schemes using waste heat where they currently exist. The consultation document does not recognise the additional benefits of fabric energy efficiency on lowering energy bills and increasing the overall capacity in the electricity generation, transmission, and distribution system. Smart systems and storage will have a key role to play but the first step should always be to minimise the amount of energy required in the first place.

Q11. How do you foresee the costs associated with installing a heat pump in non-domestic buildings changing over the next 10 years? Please consider a range of system sizes in your response and provide evidence to support your answer.

Q12. How do you foresee the costs associated with installing alternative low carbon heating systems in non-domestic buildings changing over the next 10 years (i.e., other than heat pumps)? Please consider a range of system sizes in your response and provide evidence to support your answer.

Q13. How can the government support cost reductions in low carbon heating technologies suitable for non-domestic buildings, particularly heat pumps? Please consider buildings of differing sizes and energy use.

Q14. How accurate is our indicative modelling for the cost of transitioning to low carbon heat?

Q15. How can we support the green finance market to develop the products and investor demand that businesses will need to fund their transition to low carbon heat?

The cost of installing alternative low carbon heating systems should reduce over the coming years but the LGA doesn’t have any evidence to submit to support this assumption.

Connecting to existing district heating schemes should always be considered early on and co-locating new sources of waste heat such as energy from waste plants with large potential customers of waste heat should be encouraged.

​​​​​​​The future use of solid biomass should be limited to rural, off gas grid buildings, where air quality can be better controlled. Heating and health are intrinsically linked, and it is essential that the health implications of poor air quality from burning biomass are fully considered when determining solutions for ‘hard to treat’ properties.

Q16. In what situations are fossil fuel back-up systems common and how frequently are they used? Please provide evidence to support your response.

Q17. What low carbon back-up solutions are available for buildings with a heat pump as their primary system? Please provide evidence to support your response.

Q18. Taking into consideration existing certification schemes, are businesses adequately protected when installing a low carbon heating system up to 45-kilowatts?

Q19. Do businesses that install low carbon heating systems with a capacity over 45-kilowatts require consumer protection?

No evidence to submit

​​​​​​​​​​​​​​Q20. Do you have any views on how best to ensure compliance with the proposed regulations laid out through this consultation? Please provide evidence to support your answer.

Building Regulations is a long standing and well understood process. The scale and rate of change is likely to increase and therefore local authorities will need to be funded sufficiently to enforce compliance if demand grows. This potential increase in demand would need to modelled and reflected in a local authority funding settlement. In addition to capacity, there may also be a need for additional training to ensure building control teams have the knowledge and skills to sign off work.

​​​​​​​Q21. What is the typical lifespan of a non-domestic heating system used in an off-gas grid building? How does this vary by system capacity? Please provide evidence to support your response, which should include the type and size of heating systems.

Q22. What are the potential implications for businesses of introducing an end date by which all buildings must have transitioned to low carbon heating (e.g. in the early 2040s)?

Q23. What are the potential implications for businesses of introducing trigger points for installing a low carbon heating system, in addition to the natural replacement cycle, such as at the point of let or sale?

​​​​​​​No evidence to submit

​​​​​​​​​​​​​​Q24. Do you have any evidence on how groups protected under the Public Sector Equality Duty may be affected by our proposals to phase out high carbon fossil fuel heating in non domestic buildings off the gas grid?

Q25. Do you have any views on what more could be done to ensure businesses and communities affected by our proposals experience a smooth transition to low carbon heat? Please provide evidence to support your answer

​​​​​​​Councils continuously engage with groups protected under the Public Sector Equality Duty and partnering with councils in the role of all net zero activity that is community facing will ensure communities, affected by your proposals experience a smooth transition to clean heat.

​​​​​​​As leaders of local communities, only councils can mobilise and join up the collective action to achieve net zero in our villages, towns, and cities, and are able to impact on more than a third of local emissions through housing, transport and the natural environment.

​​​​​​​Councils want to work as partners with government, industry and communities to meet the UK’s net zero target by 2050 or earlier and are well placed to do this. The LGA’s A local path to net zero campaign sets out why councils should be trusted partners to tackle the climate challenge as place-shapers, convenors, delivery agents, commissioners and owners of assets. Net zero can only be achieved with decarbonisation happening in every place across the country and this will require local leadership.