IGEM Response: Raising Product Standards for Space Heating

The Institution of Gas Engineers & Managers (IGEM) is the UK’s Professional Engineering Institution, supporting individuals and businesses working in the global gas industry. IGEM was founded in 1863 with the purpose of advancing the science and knowledge of gas engineering for the benefit of the public. 

As a not-for-profit, independent organisation IGEM acts as a trusted source of technical information, guidance and services for the gas sector. In today’s net zero context, IGEM is focused on engineering a sustainable gas future – we do this by: 

• Helping our members achieve and uphold the highest standards of professional competence to ensure the safety of the public.  

• Supporting our members in achieving their career goals by providing high quality products, services and personal and professional development opportunities.  

• Acting as the voice of the gas industry when working with stakeholders to develop and improve gas policy. 

Our role across various industry and governmental groups sees us working directly with gas network companies, manufacturers, consultants, contractors, safety experts, academia, regulators, policy advisors and policy makers, to assess the evidence base and develop informed recommendations on the future of the gas grid. 

We welcome the opportunity to respond to this consultation and aim to represent the collective views of IGEM Members and our gas industry stakeholders.  

IGEM are supportive of the government’s drive to improve the efficiency of heating appliances and agree that greater efficiencies, resulting in demand reduction, will have a positive impact on consumer bills and carbon emissions. We value the government’s position that hybrid heating systems can play an important role in heat decarbonisation and welcome the proposal to clearly define what is meant by hybrid heating systems and hybrid heat pumps.  

Please find our responses below to the questions most relevant to IGEM. 

Consultation questions: 

25. Do you agree with (a) the proposed definition of hybrid heat pump and (b) adjusting the definition of a heat pump space heater to reduce duplication? Yes/No/Don’t know. If not, what elements do you recommend should be changed and why? Please provide evidence or reasoning to support your answer. 

No. 

Our members have indicated some concern over this definition, in the context of the non-domestic market. There is a lack of clarity on whether the definition refers to a package of new appliances (new heat pump and new boiler being installed at the same time), or whether a new appliance is being retrofitted with an existing appliance. 

Although there is support for the definition as it applies to the domestic market, it has been indicated to IGEM that a separate definition may be needed to cover the non-domestic retrofit market.   

Additionally, although the term ‘hybrid heat pump’ is prevalent, the heat pump appliance itself is not hybrid, and neither is the boiler hybrid. It is the system of two appliances working together that is hybrid and as such – a hybrid heating system. IGEM urge government to be mindful of how it refers to heat pumps as being hybrid. 

As an additional consideration regarding definitions, it is important to understand that a gas boiler isn’t a ‘fossil fuel system to heat homes’, rather it is a system to heat homes which is currently fuelled by fossil fuel, but which can be also fuelled by renewable fuel (e.g. carbon negative biomethane). Much in the way that heat pumps were driven by marginal gas and coal not long ago, with the expectation that by 2030 they will be 95% driven by renewable/low carbon electricity, a boiler running on decarbonised gas in the future would be classed as a low-carbon heating system. 

Questions 26 – 28: 

Our members have indicated their support for the UK to align with the European position on MEPS for hybrid heat pumps, which is to be 110%. They also indicate that due to potential challenges with the use of hybrids in the non-domestic retrofit market (where two appliances haven’t been tested together as a package) a method for calculating the performance of systems in these circumstances would be beneficial. As such there is not support for medium-temperature (55°C flow temperature) hybrid heat pumps. 

Our members have signalled that they cannot support a mid-2027 date for new MEPS regulations to come into effect, due to the lead times for product development, administration and unexpected barriers. However, there is some support for a minimum three-year lead-in from the date of publication of the final set of standards - notwithstanding any potential changes in Europe.  

Questions 29 – 30: 

Our members have signalled their support for either test methods (combined or separate) for testing seasonal space heating energy efficiency for hybrids, with specific reference made to alignment between UK and European standards. 

With regard to the use of BS EN 14825:2022 and BS EN 15502-2-3:2023, there is support for their continued use, despite access being at a cost. 

Regarding seasonal average efficiency (SCOP), it is reasonably useful for basic energy system planning; however, it is entirely inappropriate for the dynamic functioning of the energy system and fully understanding the scale of assets required. The ‘live’ COP of a heat pump is critical (and predicted 24 hours ahead for system scheduling), given the impact of low COP on the electricity system, and the switch to the gas system in those periods that can ease the burden on DNOs. Equally, the ‘live’ COP helps to optimise for lowest total system carbon, by allowing the use of either gas in power generation or gas in boilers to achieve the lowest emissions outcome – an assumed SCOP will fail the climate and miss opportunities for reduced emissions, and minimising cumulative emissions. 

34. On the balance of pros and cons, should we encourage and enable hybrid heat pumps to play a significant, and potentially widespread, role in heat decarbonisation? Yes/No/Don’t know. Please provide evidence or reasoning to support your answer. 

Yes, we should encourage and enable hybrid heating systems to play a significant and widespread role in heat decarbonisation. 

Hybrid heating, which has been under-supported by the government thus far, has the potential to minimise system costs, improve heat pump deployment rates, relieve electricity grid constraints, make significant carbon savings and provide a pragmatic pathway for citizens to adopt. 

Heat pump uptake and carbon savings  

Uptake of electric heat pumps have been an ongoing challenge for government1 and although the increase in funding available through the Boiler Upgrade Scheme has had a positive impact on installation rates, barriers such as heat pump running costs, consumer acceptance and costs of installation and building retrofit appear to be hampering the government’s target of installing 600,000 heat pumps per year by 2028. 

Greater uptake of hybrid heating systems has the potential to address some of these barriers, and count towards the government’s heat pump installation rates, while making an immediate contribution to carbon emissions reduction and keeping cumulative emissions as low as possible. A recent study by Gemserve concluded that hybrid heating systems can offer 52% lower carbon emissions than a standalone gas boiler and 72% lower emissions than an oil boiler2. 

Hybrid heating systems can also be optimised to achieve lowest total system carbon. Utilising natural gas in the boiler at times of low heat pump efficiency is lower carbon than using natural gas in power generation to power a heat pump. Therefore, a hybrid heating system, optimised to deliver least cost heat and with a backstop function to optimise for lowest system carbon, delivers a lower carbon outcome than a heat pump alone. 

Whenever there is not enough low carbon generation available and gas fired generation is required (assumed 40% efficiency of on-off usage of turbines and engines), the threshold of live COP (heat pump efficiency) that the heat pump needs to exceed to be lower carbon than a boiler is 2.4. This reduces with greater power generation efficiency and improvements in electricity system losses. This also acts as an efficiency threshold for most efficient use of a low carbon gas, like biomethane or hydrogen. It is important to distinctly separate the live COP and the seasonal coefficient of performance (SCOP). Taking the average (SCOP) over the year is inappropriate and avoids maximising emission savings that a hybrid offers. 

Grid flexibility and cost savings 

Hybrid systems can shift heat demand to the heat pump during periods when there is a lot of low-carbon electricity available, and shift back to the boiler when renewable generation is more limited in supply. 

This switching behaviour on the basis of renewable electricity availability and periods of peak demand is also likely to represent cost optimised switching – taking advantage of low cost renewables and reducing the need for consuming expensive flexible back-up generation, which is what dynamic electricity tariffs offer today. 

Widespread adoption of hybrid systems can support the government’s Clean Power by 2030 Mission: 

• Hybrids allow electrification of some heat demand without putting added pressure on the electricity distribution networks. Hybridisation alleviates the cost and time pressure associated with reinforcing electricity distribution networks, allowing a greater focus on reinforcing the electricity transmission system for the unprecedent ramp-up of connections for more renewable power. 

• Furthermore, hybrids help the Clean Power Mission by not increasing the electricity demand peak and thus minimises the generation capacity challenge that electric-only solutions present. 

• Hybrids also support the Clean Power Mission by providing flexible demand for otherwise curtailed renewables, which reduces the overall gas volume needed to heat buildings and reduces the cost of balancing the electricity system. 

Moreover, this approach provides more flexibility in our future energy system design, allowing for the option of greater roles for green gases, such as biomethane and hydrogen, which enhances our fuel diversity and energy system resilience. 

With the growth of the biomethane market and the role of hydrogen in the gas network, hybrid heating systems can offer an enduring solution, not simply a transitionary one. With biomethane certificates costing around £10-15/MWh to a consumer willing to purchase renewable energy, and assuming a 75% reduction in gas consumption in a hybrid system, the residual volume of gas provided by biomethane would currently cost ~£30-45/year as a premium for a typical home normally using 12MWh of gas per year – a compelling, low cost approach to achieving decarbonisation of heat in such homes. 

There is enough biomethane already connected, or in the process of connecting, that is enough for 1.2 million homes heated by a gas boiler, or enough for around 5 million homes heated by a hybrid system3. 

In terms of heat decarbonisation costs, research by Imperial College London on the Freedom Project indicates that responsive, smart hybrid heating system deployment could provide an energy system cost saving of £7.4 bn/year compared to standalone Air Source Heat Pumps (ASHP)4,5 – this is as a result of reduced investment need in new generation capacity and electricity grid reinforcements. 

Research commissioned by The Carbon Trust indicates that an energy system that embraces the flexibility of optimised hybrid heating systems could offer a £19.2b/yr saving on whole systems cost, compared to an all-electric approach (in their high flexibility scenario, or £20.5b/year cheaper in a low flexibility scenario)6. 

Subsequent research by Imperial College London for BEIS7, on whole energy system modelling for heat decarbonisation, showed that with different input assumptions the cost of the options analysed were very close, but hybrids with natural gas being the lowest cost – indicating that department-led work points towards low regrets uptake of hybrids. 

Overall, hybrids offer the opportunity for optimisation for lowest total system cost by avoiding over investing in underutilised new assets and getting the best utilisation out of the existing assets we have.  

Housing stock and consumer acceptance 

Not all homes are currently well-suited to standalone heat pumps, especially older, poorly insulated buildings with high heat demand or space constraints for external units8. 

Installing a hybrid heating system in existing housing stock can offer lower levels of consumer disruption compared to electric heat pumps, as significant building retrofit (e.g. installing a hot water cylinder, insulation, changing radiators, replacing microbore pipework etc.) is not a prerequisite, whereas these types of changes will often be required for a standalone heat pump to operate efficiently and cost-effectively9. 

Consumer acceptance is key. Hybrid systems provide a valuable, pragmatic approach to decarbonising homes. They minimise ‘warmth anxiety’ by offering a familiar heating backup (the boiler) and allowing time for consumers to gradually upgrade the thermal efficiency/ internal systems of their properties and potentially transition to fully electric systems in the future. There is also a strong cost incentive to install a hybrid system, since they always deliver least cost heat between both appliances and energy vectors. 

The HyCompact research trial10, looking at consumer attitudes to low carbon hybrid heating systems, identified that consumers prioritise heat comfort and reliability and that 70% of participants would welcome a hybrid heating solution to maintain that. This research demonstrates the important role that hybrid heating systems can play in strengthening consumer buy-in to heat decarbonisation. Although hybrid heating was not formally part of the briefings and surveying of the UK Climate Assembly, they were explained in the briefing session on hydrogen heating, and the assembly members reacted positively to them. 

The strategic role of hybrid heating systems should be actively supported by government as part of a diverse and adaptive heat decarbonisation strategy. Hybrid technologies should be regarded as a catalyst for the acceleration of heat pump uptake, with the potential to unlock decarbonisation for a much wider segment of UK buildings and prepare the groundwork for a fully decarbonised heating future. In light of HM Treasury seeking significant savings across government departments, hybrid heating systems can offer a lower cost pathway to accelerate heat pump uptake. 

35. Do you agree that we should not currently be looking to introduce mandating a minimum efficiency of more than 100%, which would, in effect, phase out installation of standalone fossil fuel boilers? Yes/No/Don’t know. Please provide evidence or reasoning to support your answer. 

Yes, IGEM agree that the government should not yet introduce a mandate for minimum efficiency of more than 100%. 

Learning from Germany’s recent heating controversy has shown that government policies based on mandating change, or effectively banning certain technologies without appropriate communication, time and support, risks significant public backlash and can undermine society’s confidence in the net zero agenda. 

In the Netherlands, however, the positive reaction to signalling of the Dutch (Hybrid) Heat Pump Action Plan and pathway towards mandating change, led to a significant installation rate for hybrids. Hybrids became the norm to adopt – noting the recent coalition government has indicated this may not come into force11. 

The hybrid heating innovation experts in the UK, along with other international leads such as Natural Resources Canada, supported the International Energy Agency (IEA) on a hybrid heating research project (Annex45), only for the host country, The Netherlands, to take the learning and race into the lead. With the Clean Power 2030 Mission, the UK has the chance to regain competitive advantage with adopting hybrids in the UK and exporting innovative hybrid heating products and services. 

Consumer optionality must not be underestimated, so for those unable to bear the burden of costly building upgrades, alternative options (such as hybrid heating systems) should be made available. 

Any potential phase out of standalone fossil fuel boilers must include realistic and fair timescales for all consumers, with appropriate levels of financial support, particularly for vulnerable consumers and low-income households. 

Any such measure shouldn’t exclude opportunities for boilers which run on natural gas to use biomethane instead, or for the opportunity of hydrogen-ready appliances to be adopted and fuelled with hydrogen in the future. Natural gas, biomethane, hydrogen-ready and hydrogen boilers can all be hybridised.  

There are also concerns that the heat pump installation workforce is not sufficient to meet the government’s heat pump deployment targets, currently12. The introduction of a de facto ban on standalone fossil fuel heating systems, without appropriate timelines and market support, would exacerbate this issue.  

Questions 52 – 54: 

Our members have indicated that there are unlikely to be cost rises if manufacturers can accept testing that has already complied with CE marking for products. However, if tests have to happen in the UK in addition to Europe, then there will be a considerable additional cost to businesses, potentially into the thousands of pounds, and there could be delays as a result.  

There is also support from members on the intention to review compliance with the boiler regulations after 18 months and to revert to third-party testing for the new requirement if the compliance, as evidenced by the OPPS, is inadequate.  

With regard to dual marking, our members indicate that manufacturers would prefer to continue to use CE marking as the UKCA is considered to be an unnecessary added burden. They have also called for mutual recognition between Europe and notified bodies on this matter.