CLA Cymru has responded to Welsh Government’s consultation on the Draft Heat Strategy for Wales. While we welcome the Welsh Government’s focus on meeting net-zero, our response raises questions about the suitability of current technology for some buildings and the need to meet targets.
In December 2022, the Government published a Net Zero Plan. This consisted of 54 initiatives – a comprehensive series of projects tackling efficiencies, materials-use, emissions reduction, waste avoidance and behaviour throughout society. Its focus is on decarbonisation and meeting the net zero targets. One part of this effort is the challenge to shift heating, heating water and cooking away from fossil fuel technology – notably delivered fuels such as oil and Liquid Propane Gas (LPG) used in off-grid properties.
Heating and net zero
The Heat Strategy is Welsh Government’s plan for decarbonising the heating of homes, commercial properties and industry as part of its Net Zero commitments. With heating accounting for 50% of energy use in Wales, 75% of which is generated using fossil fuels, there is a lot of work to be done.
However, compared to the rest of the UK, Wales has greater challenges to overcome to decarbonise its heating. Homes in Wales are more likely to be old and energy efficient, and more than 20% are off the gas grid. In addition, many Welsh businesses are Small and Medium Enterprises (SMEs), which are less able to afford the costs associated with decarbonising heating.
We were concerned to see the Strategy had a major focus on using heat pumps as a way of decarbonising. Although heat pumps can be very effective, there are many properties where they will not be suitable.
Our response highlighted the need to consider alternative to heat pumps for properties which are not connected to mains electricity, and the need for good quality insulation to be installed for heat pumps to be effective. We also expressed a concern that we hear a lot from members – that the operating costs of running a heat pump make them too expensive.
We called on Welsh Government to consider other strategies for decarbonising home heating, like small scale renewables and better insultation, and to recognise that heat pumps are not always suitable. We also raised the need for Westminster to extend the VAT exemption to heat pumps which are not bought and installed by the same person.
More positively, we were pleased to see the Strategy recognise the high cost of heat pump installation is a barrier, as is the requirement for planning permission. The Strategy proposed a “long-term finance package” to help with installation costs, and a review into the use of Permitted Development Rights to make installation more accessible.
Traditional and listed properties
The Strategy does acknowledge that listed properties and traditional properties can face extra barriers in terms of decarbonising and proposed the use of demonstration projects. In our response, we stressed the need to engage with organisations like the CLA to ensure that the projects are informed by stakeholders. We also called for specific funding to be available to these properties to help them decarbonise.
With Net Zero commitments entrenched in law, there will be a need to decarbonise all homes and commercial properties over the coming years and decades. The CLA will continue to lobby for a fair deal for rural and traditional buildings, but nonetheless these buildings must decarbonise one way or another.
The CLA has been successful in lobbying for the Government to scrap policies forcing private landlords to raise the Minimum Energy Efficiency Standard (MEES) of their properties. However, the work does not stop there. We are lobbying for Reduced data Standard Assessment Procedure (RdSAP) - the methodology that sits behind an EPC on an existing building - to be updated to make it more accurate for buildings of traditional construction. We are also feeding into a review into the scope of EPCs.
We are also calling for Boiler Upgrade Scheme grant levels for biomass to match the increased levels for heat pumps, and for more innovation in alternative low carbon fuels so that heat pumps are not the default or are improved so they perform better in buildings of traditional construction.