| Roddy Yarr Assistant Director (Sustainability) roddy.yarr@strath.ac.uk |
Response from the University of Strathclyde to the District Heating Regulations Consultation, 18th April 2017
The University is in the process of installing its own DH scheme which will serve 16 buildings in Phase 1. The scheme has been designed so that other phases can be added in the future and there is capacity to use the network to supply heat to others. The University is working closely with Glasgow City Council regarding how we can collaborate on the development of a city centre low carbon zone that includes the deployment of a district heating network for use by a range of organisations.
Q1. Do you agree that local authorities should have a duty to produce and implement a Local Heat & Energy Efficiency Strategy (LHEES) as outlined above? Please explain your view.
Yes – the infrastructure and planning needed to construct a DH network and the organisation of the implementation and regulation is best managed by a local authority.
Q1b. What are your views on the appropriate geographical scale for the preparation of LHEES? Should each local authority produce a single strategy for its area, or would it be possible for local authorities to work together to prepare strategies jointly for a wider area?
Each local authority area should have the necessary skills and resources to develop its own plans and to then manage these through the implantation and operation phase. There may be a role for a regional body(ies) to help to co-ordinate cross-boundary elements of district heating. Resourcing for such a body and including the engagement with each of that regions local authorities will need to be put in place.
Q2. Do you agree with the proposed scope and content for LHEES? In particular do you agree LHEES should (a) set targets for energy efficiency and decarbonisation and (b) include a costed, phased delivery programme that will meet local targets? Please explain your views.
Yes.
Q3. Please provide any evidence you have regarding the data available (or that could be available) to local authorities that would be useful or key to preparing and implementing such plans beyond the Scotland Heat Map and the EPC Register (including data held both within and outwith the public sector).
The University has detailed data on its energy consumption by building available. This will continue to be available as we have robust energy metering in place. Some of the resourcing needed to enable the local authority to understand the DH opportunity will need to be deployed to the upkeep of the area’s heat map. The opportunity can only be fully realised when there is robust data.
Q4. What are your views on the broad principles for regulation outlined above? What else do we need to consider? What should be prioritised in cases where principles may not always be compatible?
Broad Principles
The University agrees with the broad principles identified in the DH consultation document. It is encouraging to see that the government is moving this agenda forward. The University considers that there is a real opportunity for organisations in the city to benefit from the ability to tap into major infrastructure that can enable the distribution and sharing of energy in a transition to a low carbon economy. There is sufficient guidance and impetus provided to enable the development of DH systems.
Q5. What are the key principles or approaches that should inform how our regulatory approach manages risk for district heating across the whole system?
- There need to be effective processes and procedures in place to ensure that DH operators can construct and operate networks in designated zones for sufficient periods.
- There would need to be concessions/licences issued of sufficient duration for DH operators to be able to invest.
- The concept of managing fuel poverty should be a major principle of the proposals moving forward.
- There would need to be some mechanism that enables users to want to join the network.
Q6. What are your views on local authorities having the power through LHEES to zone areas for district heating? Please provide any relevant evidence.
Agree that this is the right approach.
Q7. How should district heating zones be identified? For example, how should national targets, socioeconomic analysis, local priorities feed in to the designation of zones within the strategy?
Detailed analysis of the heat loads for each area will be necessary. A process of determining future heat loads is also needed.
Q8. What are your views on taking district heating zones, or parts of district heating zones, and establishing an exclusive concession for either private- or public-sector heat network developers to fulfil that part of the LHEES? How will this alter the risk profile of district heating development?
Agree. Term of the concession will be important.
Q8b. Do you agree that local authorities should be responsible for issuing and enforcing concessions in their areas? Please explain your answer.
Agree but also consider that there may be a role for a wider regional approach. A bit like the Municipality and Principality approach.
Q9. What considerations should inform the design of concessions (target users, envisaged network growth, concession length, etc.)? Please provide any evidence you have to support your views.
Agree with those aspects suggested. Certainly concession length combined with the existing and potential heat load development and cost of installation.
Q10. What are the implications of zoning and concessions for existing district heating networks?
There would need to be consideration as to how one network might join up with another. This is a concern for the University assuming that this became an option. The nature of the commercial agreement and the incentive to collaborate/join is part of this discussion.
Q11. Do you think the broad rights and responsibilities of concession holders set out in this document are appropriate? Why? Please provide any examples or evidence.
More detail is needed on this aspect.
Q12. How can a balance be struck between ensuring LHEES are responsive to changing conditions while ensuring security and stability in long-term district heating development models?
I think that any fuel poverty benefit will need to be considered as part of this.
For existing buildings
Q15. What are your views on the proposed power to compel existing buildings to connect to district heating?
More detail is needed on this. May need different rules for new build connection and existing buildings.
If the heat price is at an appropriate level then this obviously the building user make a decision to connect. There is also a potential benefit in terms of savings that could be made on the maintenance of existing boiler/generation plant.
Q18. What are your views on the relationship between LHEES and local development plans and how planning policy and development management should support the anticipated role of LHEES for new buildings?
Agree that getting the two elements aligned would be a significant enabler for the installation of large scale city wide infrastructure and needs to be carefully thought out.
Existing industrial plant
Q19. What challenges and opportunities do you see for existing industrial plant to connect and sell waste heat to nearby district heat networks, both now and in the future?
Large scale industrial heat sources should be a fundamental part of the city-wide network, particularly if they have a local authority function/contract e.g. a waste to energy plant. Smaller scale privately owned assets may need a different approach. Ideally they should all be willing partners. The nature of the heat, its volume and longevity will all play a part in the discussion.
New industrial plant
Q23. What are your views on requiring new industrial plant to be ‘district heating-ready’?
Ideally yes.
Q25. Do you agree that as district heating becomes more widespread it will need to become a licensed activity? Please explain your answer.
Agree. An operator needs to be licensed. There needs to be a set of guidance and rules that are transparent and logical for all parties to be use. For instance, would an operator have similar powers to an existing utility company for pipework installation?
Q36. What are you views on the wider regulation of the heat market to ensure decarbonisation?
Low carbon heat sources and waste heat should have some form of preference over those from fossil fuels.
Q39. Please set out any further views on issues covered in this consultation that you have not already expressed, providing evidence to support your views.
The University is encouraged by the level of interest in its district energy scheme which is currently being developed. There have been a number of approaches from third parties who are interested in connecting to the DH network once it is up and running. This brings home many of the issues raised in this consultation such as the size and scale of the network; security of supply; or what sort of commercial agreement may be required. So the University would be keen to assist in any further discussions on city-wide district heating networks and in collaborating with others on this important issue.