GSHPA response to Commercial RHI Consultation
GSHPA has responded to the RHI Consultation: Renewable Heat Incentive: Expanding the non-domestic scheme.
You will see from the GSHPA response that we do not believe DECC has addressed the central issues of why the take-up of RHI has been so low for all technologies - except biomass boilers. The way that the RHI has been introduced has provided a major setback for the GSHP industry and the key fault of DECC has been to introduce great uncertainty and confusion into the market.
The RHI was introduced at very low levels 20 months after DECC introduced very favourable rates for FiTs for PhotoVoltaic installations. DECC urgently needs to publish and support realistic balanced RHI tariffs that reflect the costs of installation of the different renewable heat technologies and the carbon saving potential of those technologies.
However, the most damage has been done by introducing the totally unscientific notion of requiring a heat pump to generate heat from "naturally occurring energy stored in the form of heat from the ground".
This concept, as understood by DECC, has no grounding in physics, economics or the EU's Renewable Energy Directive and has caused confusion to the point that Ofgem has been unable to accredit ground source installations other than the simplest systems with restricted efficiency.
The ground is never the ultimate source of heat. Heat is constantly on the move (from warmer bodies to colder bodies) and it is of the essence of ground source heat pump installations that they exchange heat with the ground in a dynamic way. GSHPs can transfer heat from the ground to buildings in winter and they can transfer excess solar heat from buildings down to the ground in summer. This is how GSHPs can play a vital role in combating climate change by recycling solar energy.
The unnatural interpretation placed by DECC on requiring heat to originate from a finite source has blocked innovation in the ground source industry and caused unemployment in the sector at the same time as the Ministers in DECC have been stating that it is the intention of the RHI to support innovation and provide employment in renewable energy technologies.
We call upon DECC to understand the potential for GSHPs and to support the recycling of solar energy as an efficient means of combating climate change instead of attempting to block the use of this uniquely efficient renewable energy technology.
Please see the full GSHPA Response to Commercial RHI Consultation.
Please also see Ten reasons why DECC should support Ground Source Energy.