Ofgem Consultation: Renewable Heat Incentive Guidance
ACE has submitted a written response to Ofgem’s consultation on the Renewable Heat Incentive Guidance.
To read our full response please written response
ACE is concerned that the RHI Regulations and the draft Guidance document do not come close to ensuring that the renewable heat supported through the RHI is used as efficiently as possible.
RHI payments for non-domestic participants are paid based on metered generation without any requirement for energy efficiency measures or improvements over time. Generators are paid for each unit they generate, with total payments increasing as the amount generated increases. This gives the participant an incentive to generate as much heat as possible, particularly where the RHI payments for each unit of heat exceed the fuel costs. If a participant can create additional demand, perhaps by opening windows, or increasing the temperature of heated water, it would be logical and profitable for them to do so.
It seems impossible that, with the Guidance document as proposed, Ofgem can fulfil its obligation to ensure only eligible heat is consumed and that the installations – funded by the taxpayer – are generating genuinely useful heat.
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