LGA submission to Governments consultation on phasing out the installation of fossil fuel heating in homes off the gas grid

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.

• 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 domestic 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.
• 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 household facing net zero activity will ensure households and communities, affected by the proposals experience a smooth transition to clean heat.

Q1. Do you agree with the principle of working with the natural boiler replacement cycle as the key trigger to deploy low carbon heat? Please provide evidence to support your response.

Q2. Would a 2026 end date for the installation of fossil fuel heating in homes off the gas grid give industry and consumers sufficient time to prepare for the regulations? Please provide evidence to support your response.

• ​​​​​The principle of working with the natural boiler replacement cycle is sensible in theory, however a 2026 end date for the installation of fossil fuel heating systems may unfairly impact those householders that have to replace their boiler in 26/27 due to market infancy. Householders, especially those on low incomes, that need to replace their existing boiler in the short-term post 2026 should not be unfairly impacted with what could be higher initial costs of transition from traditional systems to heat pumps or biomass technologies.

• A 2026 end date for the installation of fossil fuel heating in homes off the gas grid is also significantly earlier than the 2035 end date for homes on the sag grid network further disadvantaging homeowners and occupiers off the gas grid. 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.

Q3. Do you agree with a heat pump first approach to replacement heating systems in fossil fuel heated homes off the gas grid that can reasonably practicably accommodate a heat pump? Please provide evidence to support your response.

Q4. Do you have any views on the design or content of guidance that will help households and installers determine whether it is reasonably practicable to install a heat pump? Please provide evidence to support your answer.

Q5. Do you have any additional evidence on the size and characteristics of the cohort of homes off the gas grid that have the greatest deployment potential for ground source heat pumps?

• We welcome Government supporting and promoting heat pumps as a preferred technology to provide zero carbon affordable heat for many homes 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, especially for new developments off gas grid, the first approach should be to connect to existing district heating schemes using waste heat where they currently exist. The consultation document recognises the role of fabric energy efficiency measures to facilitate the use of low-temperature heat pumps but does not recognise the additional benefits of fabric energy efficiency on increasing householders’ thermal comfort, lowering energy bills and increasing the overall capacity in the electricity generation, transmission, and distribution system.

• The design and the content of guidance should consider the wider energy system and the user and not just focus in on the technical requirements of heat pump technology. It should be clear and accessible to allow consumers to make informed choices and enable the consumer to understand the installation process and question it if things don’t seem right.

​​​​​​​Q6. Do you agree that the performance of replacement heating systems in homes off the gas grid that cannot reasonably practicably accommodate a heat pump should reflect the current high standards of performance that can be delivered through high temperature heat pumps and solid biomass systems? Please provide evidence to support your answer.

Q7. Do you agree that future use of solid biomass to decarbonise heat in homes off the gas grid should be limited to rural, off-gas grid areas where air quality can be better controlled, and in ‘hard to treat’ properties that are not suitable for other low carbon heating technologies? Please provide evidence to support your response.

Q8. Do you have any views on the development of heating fuels and systems which will be consistent with wider government objectives on net zero emissions, environmental sustainability and air quality, and offer a secure and affordable fuel supply to consumers, from 2026? Please provide evidence to support your answer.

• ​​​​​​​The performance of replacement heating systems in homes off the gas grid that cannot practicably accommodate a heat pump should reflect the current high standards of performance that can be delivered through high temperature heat pumps and solid biomass systems; however, householders should not be unfairly disadvantaged with higher costs in this situation. Government should work with industry to expedite solutions that are effective, affordable and accessible.

• ​​​​​​​The future use of solid biomass should be limited to rural, off gas grid properties, where air quality can be better controlled. Heating and health are intrinsically linked and it is essential that the health implications of not being able to afford to heat your home to 19-21­­ degrees centigrade plus the health implications of poor air quality from burning biomass are fully considered when determining solutions for ‘hard to treat’ properties.

​​​​​​Q9. Do you agree with an end date for the use of remaining fossil fuel heating in homes off the gas grid by the late 2030s? Please provide evidence to support your answer.

​​​​​​​Q10. Do you have any views on measures the Government could introduce to ensure that fossil fuel heating will no longer be used in homes off the gas grid by the late 2030s? Please provide evidence to support your answer.

• ​​​​​​​An end date for the use of remaining fossil fuel heating in homes off the gas grid by the late 2030s would provide greater certainty to industry and provide confidence to businesses to invest and prepare for a ramp up in clean heat deployment. It would also encourage consumers to consider their most suitable future heating system at an early opportunity. However, for this to happen, the consumer will need to be informed and have the confidence to make the right decision.

• ​​​​​​​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 services (depending on what works best locally) to help both consumers and local businesses make the best decisions.

​​​​​​​​​​​​​​​​​​​​​Q11. 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 be 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.

Q12. Do you have any views on what more could be done to address financial barriers to heat pump deployment? Please provide evidence to support your answer.

Q13. Do you have any views on how we should encourage smart-enabled heating in homes off the gas grid? Please provide evidence to support your answer.

Q14. Do you have any views on what more could be done to galvanise supply chains for low carbon heating? Please provide evidence to support your answer.

• ​​​​​​​A council led approach has the potential to further address financial barriers to domestic 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.

​​​​​​​​​​​​​​Q15. Do you have any additional 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 homes off the gas grid?

Q16. Do you have any views on what more could be done to ensure households, and communities, affected by our proposals experience a smooth transition to clean heat? Please provide evidence to support your answer.

Q17. Do you have any further comments to make on our proposals to phase out high carbon fossil fuel heating in homes off the gas grid? 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 household facing will ensure households and communities, affected by the 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 they 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.