No doubt those of you who like reading the equivalent of Tolstoy’s War and Peace have already read through the 200-plus pages that constitute OFGEM’S Renewable Heat Incentive Guidance Consultation. Never before in the history of incentive schemes has there been such an intimidating document, probably capable of putting you off saving the planet altogether. Its complexity beggars belief. Measuring renewable heat for cash was never going to be a simple exercise. Nevertheless, OFGEM will not exactly be celebrating the handover of such an ill-conceived policy from their earnest colleagues at DECC. It may be hailed as a world-first but it could also end up as the world’s only RHI scheme – and short-lived at that!
For starters, the document emphasises a core distinction between domestic and commercial systems. Systems serving a single private residential dwelling are not intended to be eligible for the RHI; expect, then, plenty of attempts to capitalise on the grey areas in this definition. No doubt there are already householders devising cunning plans to start small businesses from their spare rooms to qualify early for the RHI.
Under the proposals, the RHI will also only apply to heat used for certain ‘eligible’ purposes within a building. A building is defined as any long-lasting structure – fixed or moveable – which, except for doors and windows, is wholly enclosed on all sides with a roof, ceiling and walls. Now this is intended to exclude, say, external swimming pools. But indoor swimming pools seem to be included, even though they may in fact have large sliding patio windows or even a sliding roof to the outside.
The document continues to attempt to plug loopholes such as where heat is ‘rejected’ from a system. This would include, for example, a heat dissipation circuit of a solar thermal system – which would then be ineligible. All well and good; but what, apart from the speed of heat-loss, is the difference between heat export through a solar collector and that simply lost through an insulated structure?
In any case, however admirable the objective of excluding such systems, this is unlikely to be successfully accounted for without failsafe control equipment. There are clearly solar thermal designs on the market which advertise themselves as having a heat export function intended to operate when the internal insulated storage is becoming too hot – a situation which arises most commonly when storgae is inadequately sized for summer heat. Perhaps, then, the RHI will finally see an end to these.
Where it gets particularly convoluted is in the stated intention to avoid paying out for so called ‘parasitic loads’. Read what you will into this, but most renewable thermal systems of any note contain electrical readouts, safety controls or electrical circulation pumps. These will inevitably contribute to the heat within the system. In some cases the circulation is necessary to avoid safety discharge such as in biomass boilers. Ignitions and fans must energise for safe combustion. There is, mind you, mention of permitted “ancillary purposes” – so plenty more grey areas here.
Furthermore, it appears non-renewable content of biomass feedstock of up to 10% is also eligible. In the case of municipal waste streams, up to 50% is permitted. So it seems the ‘R’ in the RHI has been rather diluted in the attempt to keep solid fuel heating in with a chance.
Anther peculiarity concerning biomass fuel types relates, ironically, to wood fuel too close to its natural form – namely the log! Many, I am sure, would like the idea of being paid to watch a roaring fire. But the RHI intends to make such applications ineligible on the basis that it could allow the burning of coal, or oil-impregnated briquettes. For avid flame-watchers, relaxing in front of a pellet stove with a back-boiler may be the only option.
The consultation document, which is in two large volumes, also includes baffling attempts to include only distribution technologies that use liquid or steam. Air, for example, is excluded. Rather contrived when we consider that any space heating system will inherently use air to heat our bodies – where is the line on this rule meant to be drawn?
It appears to be fairly easy to take pot shots at the unenviable task of supporting renewable policies; cue a recent independent evaluation of the Low Carbon Buildings Programme (LCBP), the RHI/FIT precursor, a grant scheme which ran between 2006 and 2011. At over 100 pages, the evaluation does not make pretty reading, and picks over the pieces of a scheme that was in its time deeply unpopular. Some may remember, for instance, the closed tenders schemes, monthly quotas and crashing websites. Even the providers of the scheme evidently had little good to say of it. However, going back a little further, we come to the Clear Skies scheme, circa 2003. Here was a scheme that was enormously popular with both householders and installers – easy application forms, easy for installers and manufacturers, and easy money for the end-user.
So why, given this far more successful model, have we seemingly grasped defeat from the jaws of policy victory?
Despite the lack of formal evaluation, Clear Skies was a success for one very good reason. In a world of increasing complexity and over-funded self-analysis, it was a beacon of simplicity. Something much under-rated in government circles, it would appear.













