Gemserv are pleased to submit our response to the Government’s Heat Networks: Building a market framework consultation. In preparing our response, we would like to draw attention to an important factor which underpins the views outlined in our detailed response below – this being the nascent condition of the existing heat network market. Given that the decarbonisation of heat is critically important to achieving the UK’s goal of net-zero carbon emissions by 2050, the level and nature of the regulation of the heat network market could have a significant impact on the development of the market.
It is important that the regulatory model for heat networks is fundamentally risk-based, focussing attention on protecting and informing consumers from actual risks, whilst also promoting innovation and investment in the market. It is important to acknowledge that technological advancements often outpace regulation, and therefore regulatory framework should be flexible enough to support, and not inhibit, the development of appropriate technical solutions to local needs. The emergence of new and innovative business models in the heat network market is encouraging, indicating that these projects are considered investable. To maximise the sector potential, we feel that it is essential that the market framework which emerges from this consultation should continue to support this innovation and investment, whilst also providing the equivalent protections afforded to gas and electricity consumers.
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