Heat Network Regs call for a common sense approach
The Heat Network regs are a little difficult to get your head around, particularly noting the moving goal-posts (or at least the lack of the feasibility calculator that was promised).
A quick summary of Heat Network Regulations
If you have a building where you supply heat from a central plant-room to a number of occupiers you will likely need to do something to comply. Compliance in the highest order will mean installing heat meters and providing bills to individual tenants, or, at the lowest order, just completing a notification to the scheme administrators that you have a heat network provisioned within your building(s).
The supposed common-sense being applied is that if it's not cost effective to do something (here defined as a payback within 10 years), you do not need to do it. I'm sure some businesses 'investing to save' over 10 years would be a poorly ranked investment, so it will be interesting to understand where the line-stops in determining how the scheme is administered.
However, for now, unless a saving can be achieved within 10 years there is no rationale for installing either heat cost allocators, TRV's or Heat Meters. My problem with this is that determining the payback will depend on what view you take, whose figures you use, the demographics of your occupants and how/if you motivate behaviour change. Achieving 10 years payback can be argued either way to combat this argument a calculator to complement the new regs was launched, although recently 'pulled' so we await a new calculator to be able to inform clients further.
In any case, understanding the scheme's objectives will assist in future compliance, particularly noting the scheme requires assessment every 4 years (so whilst you may comply on this round via a simple notification you may wish to future proof your business for round 2 with a gradual roll-out of heat metering). It is also worth understanding the implications for any new builds you have underway.
It is particularly important to note that: new heat networks or those undergoing renovation, individual properties or units housing final customers will require individual sub-meters to be installed, without exception.
Where compliance is required, in summary, the heat supplier (definitions further down the page) must wherever technically feasible and cost-effective, sub-meter all connections to final customers and accurately bill them using actual meter readings.
Any person or organisation currently operating a heat network must notify the scheme administrator (the National Measurement Office). Notification is performed through a controlled process using a standard notification form. Details must be provided on the location of any district network or communal heating system, its capacity, the number of final customers, fuel types and heat generating plant, and any existing metering and billing systems.
For new heat networks or those undergoing renovation, individual properties or units housing final customers will require individual sub-meters to be installed, without exception.
Heat networks currently being constructed or late in their design will likely be subject to the same technical feasibility and cost-effectiveness tests as existing networks (which does allow for some exempting of properties via the cost-effectiveness model).
Any new connections made to existing heat networks will require sub-meters to be installed, without exception.
On all existing district heating networks or communal heating and/or hot water systems, sub-meters will be required to be retro-fitted unless it can be shown that this would not be technically feasible or cost effective.
Cost-effectiveness is defined within the regulation as having a payback within 10 years.
Where it is shown that sub-meters are not feasible or cost-effective, instead the heat supplier must install Heat Cost Allocators (HCA) and thermostatic radiator valves (TRV) to any radiators, again unless it can be shown that this would not be technically feasible or cost-effective.
The regulations will affect anyone who operates a heating or cooling network, be that a district heating scheme or a communal heating / hot water system & affect most types of buildings including purpose built student accommodation & PRS (noted exclusions: hotels, prisons, nursing homes, industrial sites, leisure centres).
Furthermore, the regulations apply whether the supply of heat is currently billed to the end user or supplied as part of package, paid for indirectly through rent, a service contract or other means. Such a payment does not need to explicitly mention the supply of heat providing there is a reasonable expectation that heat or hot water supply is part of the service.
The Heat Network (Metering and Billing) Regulations 2014, recently amended in 2015, implement the requirements of the EU?s Energy Efficiency Directive (EED) with regards to the supply of distributed heat, cooling and hot water.
The EED is the tool used to promote energy efficiency in the EU with the aim of meeting a 20% improvement in energy efficiency by 2020. The regulations require metering and billing to be implemented across all new and existing heating or cooling networks
The regulations use the following terminology to determine who is affected and responsible for implementing the required action.
Heat Supplier: a person or organisation who supplies and charges for the supply of heating, cooling or hot water to a final customer, through communal heating; or a district heat network.
Final Customer: a person or organisation who purchases heating, cooling or hot water for their own end consumption from a heat supplier.
District Heating: the distribution of thermal energy in the form of steam, hot water or chilled liquids from a central source of production through a network to multiple buildings or sites for the use of space or process heating, cooling or hot water.
Communal Heating: the distribution of thermal energy in the form of steam, hot water, or chilled liquids from a central source in a building which is occupied by more than one final customer, for the use of space or process heating, cooling or hot water.