An ambiguity in building regulations regarding the circumstances a boiler can be reinstalled to replace an underperforming low carbon heating system is creating confusion for consumers and the wider heating industry.
That’s the message from OFTEC which has called for clearer guidelines for installers and an increased focus on ensuring consumers are aware of the types of heating system they can install in their home.
The government’s drive to transition homes to low carbon heating means the number of heat pumps replacing fossil fuel systems must increase significantly over the coming years. Many of those installations will be part funded through government incentive schemes, such as the Boiler Upgrade Scheme, which can now be done regardless of any building fabric recommendations included within a homes' Energy Performance Certificate.
OFTEC argues there is a potential this could sometimes result in less-than-optimal outcomes for consumers, particularly if unscrupulous installers deliberately cut corners, or sub-standard work is carried out by inexperienced installers which results in an inefficient heating system.
If a new heat pump system is underperforming, typically the installer works with the customer to resolve any problems. If that fails, there are other legal options the owner can pursue. However, in cases where the owner has been unable to resolve the problems and has lost confidence in the system and the installer, they may call in a new heating company and want to revert back to their old heating system.
OFTEC highlights that this scenario is problematic because the way building regulations are framed implies this shouldn’t happen. Approved Document L states that, in existing buildings, a replacement fixed building service, such as a heating system, where the same fuel is being used, should have an efficiency that is not worse that the service being replaced.
Furthermore, if a different fuel is being used to the service being replaced, the new system should not produce more CO2 emissions per kWh of heat and should not have higher primary energy demand per kWh of heat. This means a low carbon heating system should not be replaced by a less efficient or more polluting alternative.
Therefore, homeowners who replace their fossil fuel heating system with a heat pump will face difficulties complying with the regulations if they want to switch back and reinstall their boiler. This applies even in scenarios where the boiler will run on a renewable liquid fuel such as Hydrotreated Vegetable Oil (HVO).
OFTEC is calling for greater clarity as the terminology ‘should’ in the regulations creates unhelpful ambiguity, and it is clear that an increasing number of installers are using this confusion as a justification to reinstall a fossil fuel heating system. OFTEC has recommended:
- Support for the use of HVO compatible systems to provide more consumer choice if a heat pump isn’t suitable for their home or circumstances.
- Clearer guidance in building regulations on the types of heating systems that can be installed when replacing an underperforming heat pump or other low carbon technology.
OFTEC has created a calculation tool for technicians to provide greater clarity on what heating systems can be installed to be compliant with the Approved Document L regulations.
Previous analysis of the government’s online heat pump calculator revealed many off-grid properties such as those on oil heating could face costs of over £20,000 to install a heat pump and make all the recommended energy efficiency improvements for the technology to work effectively. This could include installing new radiators, new piping and a hot water tank.
Consumers need to be aware that if they switch to a heat pump without making these changes and subsequently find their heating system underperforms, or is more costly to run, the alternative options that are compliant with building regulations may be limited.
This could create further difficulties for homeowners and also technicians who have to advise their customers and potentially turn down work because the requested boiler installation request is not compliant.
Andrew Mathews, Technical Director at OFTEC, commented: “With an increased awareness and focus on heat pumps in the domestic market, there is naturally some confusion amongst consumers. Whilst heat pumps are a sensible choice for many properties, for harder to treat off-grid homes there can be significant technical challenges and cost implications to overcome.
“It’s essential consumers do their research to ensure a heat pump is suitable for their situation as it won’t be straight forward to revert back to a boiler. Homeowners in breach of building regulations could face a fine, an instruction from the local authority to rectify the issue or difficulties when it comes to selling the property.
“We fully recognise for technicians it can be a very difficult conversation if their customers request their boiler is reinstalled and that it could lead to the work being turned down. However, as an industry, we must uphold compliance and best practice as otherwise it’s a slippery slope if all the rules aren’t carefully followed. Our calculation tool will help technicians advise their customers on the options they have.”
More information can be found at www.oftec.org.