BEAMA has submitted a comprehensive response to the Department for Energy Security and Net Zero’s Alternative Clean Heat Solutions consultation. Our position remains clear and consistent: consumer choice must sit at the centre of the transition to heat electrification.

 

Government must urgently level the equitable treatment of available electrification technologies which can support decarbonised heat, for example with storage-related technologies. This must be the case across all relevant policy instruments, while normalising heat electrification through MCS, fiscal incentives, and trusted consumer advice linked to the forthcoming Warm Homes Agency. 

The consultation demonstrates a concerning lack of understanding around how heat is actually deployed across different housing types and consumer segments. The assumed technology archetypes used for solutions such as high heat retention storage heating, among others, make this clear. BEAMA has consistently raised these concerns in recent years and continues to highlight the need for a more practical and representative approach. 

Government needs to better recognise the concept of whole-house heating using mixed systems. Too often, the vision for heat deployment remains centred around the traditional model of a single central heating appliance. However, successful heat electrification does not operate in this way. In practice, a whole-house system is increasingly defined by the intelligent control and integration of multiple technologies working together to meet consumer needs efficiently and flexibly. 

Industry has significant concerns around the prospect of replacing potentially critical flexible energy infrastructure technologies with air-to-air heat pumps. This risks undermining both the 12GW flexibility target and the estimated 6.4GW opportunity for storage replacement technologies. 

This raises important questions around Smart Secure Electricity Systems (SSES) ambitions and the wider direction of Government policy. Manufacturers are being encouraged to develop flex-ready technologies, yet the addressable market for these solutions risks being weakened by conflicting policy decisions. There appears to be a continuing institutional blind spot around the role of flexibility within heat electrification policy, despite these concerns having been raised consistently by industry. 

Action is required to avoid market distortion  

Overall, there is still substantial work required within a very short timeframe if the sector is to avoid significant market distortion across the Warm Homes and Boiler Upgrade Scheme frameworks. 

BEAMA remains ready to engage constructively with Government and stakeholders to address policy gaps, improve linkages across schemes, and support a more balanced and effective pathway towards heat electrification.