DESNZ consultation on Boiler Upgrade Scheme and certification requirements for clean heat schemes - Which? response

Executive summary

Which? welcomes the government’s consultation on the Boiler Upgrade Scheme (BUS) and certification requirements for clean heat schemes. If the government is to make progress towards the Climate Change Committee’s target for half of UK households to have a heat pump by 2040 it is important that these schemes are able to support a broader range of consumers in the transition to low carbon heating systems. In order to support these changes we recommend:

• Consumers are supported to make informed choices. The options presented in this consultation illustrate the increasing complexity of this market. In order to choose the technology and finance that meets their needs, consumers will need good quality independent assessments, information and advice. The government should also consider requirements for financial products to include links to independent information and advice, the adoption of key information sheets that support comparison between products, and the regulation of comparison sites or brokers to improve transparency about market coverage and commissions.

• New Third Party Agreements should be effectively regulated. We welcome the government consulting on third party ownership to be eligible for the BUS as this creates the opportunity for new hire agreements and Heat as a Service agreements to enter the market. However the long term nature of these agreements, the bundling of services, and the complex nature of the consumer protection landscape can create risks for consumers that should be fully addressed before these agreements are made eligible for BUS funding. 

• Other actions will also be needed, and may have a greater impact on heat pump adoption. For example the consultation notes that the government is also considering the development of a low interest loan. This may be a more attractive option for some consumers. Improving awareness of heat pumps, addressing concerns about running costs, and finding effective ways to make consumers aware of new and existing financial products will also help to improve uptake. 

• MCS should be the sole certification scheme for government and Energy Company Obligation(ECO) funding schemes. In this case we support a sole provider model as there is a risk that competition will lead to lower standards as schemes compete for business by reducing costs and making concessions to installers, However we encourage the government to consider mechanisms to ensure MCS maintains high standards and provides an efficient and cost effective service for installers.