Ofgem Lobbying

From: Peter Gubb
Subject: RHI; Ofgem Draft Guidance

I am in receipt of your briefing document.
I have two major concerns;

The interpretation of the point at which heat is measured.
This has the potential to unfairly discriminate against certain installations and could act as a disincentive to potential developers and funders.
• A boiler heating a thermally inefficient factory or building would receive full RHI on the full output from the heat meter even though the majority of the heat produced disappeared through the fabric of the structure.
• A boiler heating a modern, insulated District Heating Scheme to modern, insulated houses would lose RHI on the heat loss through the DH system.
This is great for the first boiler owner [but not great for the Exchequer or for reducing the effects of climate change], but not so good for the second boiler owner and a possible disincentive to developers who invest in relative certainties rather than complete unknowns [heat loss calculation for DH schemes is not an exact science].
Keep it simple, and keep the costs of administering RHI low. Measure the heat produced from the boiler, at the boiler, and pay the RHI at this point.

New Equipment
The stipulation regarding “new Equipment only” is counter intuitive to the climate change argument. Perfectly good, virtually new, biomass equipment could be scrapped for no reason other than it fails to qualify for RHI. The realisation that second hand equipment is effectively worthless is a real disincentive to invest in any biomass equipment at all.

Regards,
Peter Gubb
Chief Operating Officer
Woodpecker Energy UK

www.ofgem.gov.uk/e-serve/RHI/Pages/RHI.aspx