Further to our December meeting regarding the Government's response to the EFRA Select Committee report on climate change and the individual, I have put together some points for you as promised. TEHVA strongly believes that now is the time for Government Ministers to deal with the practicalities of the detail within the Energy White Paper and we are pleased that the Committee is calling for an additional session with the Secretary of State.

  The key issue, in our view, is the lack of detail supporting the White Paper's claim that the Government was considering options for "producing heat from low carbon electricity" (section 3.25). We know that BERR has not discussed the link between low carbon electricity and electric heating for new build housing—from a response by Malcolm Wicks MP on 19 November 2007 to a written question tabled by Dr Ian Gibson MP. Whilst not specifically relevant to DEFRA, this does demonstrate a failure in the political process to deliver against rhetoric within the White Paper as there is of course a significant link between low carbon electric heating and new build housing. This should also clearly be an item for discussion within the Government's 2016 Task Force as it is a practical issue for resolution yet we know this has not been discussed, probably due to the absence of the appropriate stakeholders on that forum (including TEHVA). TEHVA has repeatedly suggested to DEFRA, BERR and CLG Ministers that the time is now right to sit down with industry and discuss the role of all forms of electric heating (including heat pumps) as we move towards a lower carbon grid and decentralised electricity generation. It may well be worth asking the Secretary of State why direct and meaningful engagement has not been had.

  As we covered in our meeting, there are two ways of ensuring production of heat from low carbon electricity and both suffer from market and policy barriers:

  1. Policies are needed to provide a firm platform for encouraging "electric heating" for new build linked to a low carbon central grid. There is obviously a time issue here as the grid will need to decarbonise over the next 20-25 years as new nuclear is deployed along with the realisation of both large scale renewable projects and carbon capture and storage technology. However, a building lasts for notionally 60-100 years—probably more in reality—so a more strategic thought needs to be applied to deliver lifetime zero carbon. In this scenario, the TEHVA carbon milestone approach could be employed and linked to building regulations but the Secreatary of State will need to show willing to explore this idea and seriously consider how it can be implemented by working with organisations such as TEHVA.

  2. Provide a regulatory framework which encourages the link between electric heating—most probably heat pumps achieving an efficiency of between 250 and 500%—and private wire decentralised electricity networks (in line with government aspirations in paragraph 22 of its own response to the EFRA Select Committee report). This option is just not possible under current building regulations and compliance tools—ie the Standard Assessment Procedure 2005—and will need urgent consideration with measures for correction in place by the end of 2008 to enable industry to confidently prepare from building regulation changes in 2010.

  Table 3.1 of the Energy White Paper refers to heat pumps as a measure within the basket of Distributed Heat Technologies. This market will not be viable beyond 2010 and certainly not able to compete by 2016. There is a simple reason for this. Heat pumps use electricity and the Government is removing the building regulations fuel factor allowance for electricity using technologies from 2010. In addition, we have no compliance tool for recognising the low carbon impact of linking heat pumps to private wire electricity generation. The Government has on no occasion asked to discuss directly with the technology manufacturers how housing policy can be shaped to sustain and build the heat pump or electric heating market.

  Against this background we believe the EFRA Select Committee should ask the Secretary of State 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 and the Code for Sustainable Homes completely remove the market for high efficiency heat pumps and electric heating. Furthermore, the Secretary of State should perhaps explain why there appears to be little direct interaction with the electric heating technology manufacturers on the barriers presented by the missing link between energy and housing strategies.

  This is a critical year for the electric heating industry. As we face new consultations for building regulations in 2008, it is absolutely vital that the fundamentals are in place from the first consultation publication to prevent a game of "catch up" in the subsequent year. This requires much strategic thought and a degree of leadership on how the low carbon electricity generation of the future can be best recognised in policy making today.

  I very much hope that you will have an opportunity to put the points outlined above to the Secretary of State and would of course be delighted to provide you with any more information you require.

Mr Kelly Butler

Director

The Electric Heating and Ventiliation Association