BACKGROUND

  BEAMA is the long established and authoritative trade association for manufacturers in the electrotechnical sector. Our membership includes manufacturers of electric heating, hot water and heat pump technologies. Without doubt, each of these technology categories has a role to play in helping the UK tackle its climate change commitments through reduced CO₂ emissions in the long term, if the right policy framework is in place to facilitate the reduction. We have raised particular areas of concern with the Chair of the EFRA Select Committee, the Rt Hon. Michael Jack MP. A letter sent to Mr Jack in January 2008 by TEHVA follows this paper.

  BEAMA understands that the Secretary of State is attending the Select Committee on 20th February 2008 and we would like to make the Committee aware of a number of questions that we feel should be asked.

QUESTIONS

  1.    BERR's recently published "Heat Call For Evidence" asks about the prospects for encouraging electric heating (of all types) to reduce carbon emissions when linked to a de-carbonised grid. Electric heating is clearly an option for reducing CO₂ emissions but the government is currently working on building regulation policy that will effectively ban this type of heating? If Communities and Local Government puts into action its 2007 published "Forward Thinking" paper for regulations then there will be no market for electric heating in new dwellings beyond 2010. Can the Secretary of State give an assurance that electric heating will not be ruled out for the long term by imminent building regulations until a full and thorough analysis of its contribution has been completed?

  2.  Table 3.1 of the Energy White Paper refers to heat pumps as a measure within the basket of Distributed Heat Technologies that will contribute to CO₂ reductions overall. This market will not be viable beyond 2010 and certainly not able to compete by 2016 as heat pumps use electricity and the Government is removing the building regulations fuel factor allowance for electricity using technologies from 2010. Also, the compliance tool for building regulations managed by DEFRA (the Standard Assessment Procedure) does not take into account the future de-carbonising nature of electricity due to the UK's renewables target and nuclear build programme. Can the Secretary of State explain whether he thinks it is prudent to ignore the relationship between long term energy and housing strategies such that short term policies including building regulations, the figures used in the Standard Assessment Procedure and the Code for Sustainable Homes completely remove the market for high efficiency heat pumps and electric heating?

  3.  Heat pumps are defined within the BERR "Heat Call For Evidence" as a renewable microgeneration technology and are funded within the Low Carbon Buildings Programme. Consequently it can be assumed that heat pumps are deemed to be a viable technology for the reduction of CO₂ emissions. However, local authorities applying the so called "Merton rule" of 10% renewables for new build projects do not recognise heat pumps as being renewable as they use some electricity (typically 1kW input for 2-5 kW output). Can the Secretary of State explain why there appears to be a lack of clarity in the policy field for encouraging renewable technologies and why DEFRA has not been active in ensuring diverse departments across Whitehall have a unified approach to the definition and treatment of technologies linked to CO₂ emission reduction?

  4.  Clearly, the strategy for reducing CO₂ emissions in the domestic sector draws on the need for long term and well defined energy and housing strategies. Whilst these are not firmly within the remit of DEFRA, the common theme of their contribution towards reducing emissions is of major interest to the Department. Can the Secretary of State commit that his Department will work to ensure that long term carbon reduction solutions such as those offered by heat pumps and electric heating will not be marginalised in the imminent changes to building regulations until a thorough assessment of their contribution is made. Also, will the Secretary of State be in a position to raise the issue of conflicting policies for heat pumps (eg the definition of renewables and use of carbon factors for electricity) to ensure growth in the market?

Kelly Butler

Association Director

February 2008