In this next post in our series of Renewable Heat Incentive (RHI) we recorded our response to the call for evidence relating to IRMAs.
As always we are on hand at TEAM to answer any additional questions you may have about IRMA’s for RHI to help you through the application process.
1. What is the average cost of an IRMA? How does this figure vary by sector, renewable technology, and scale of installation, region, or any other key factors?We cost the IRMA on a time basis, allowing for travel, site visit, creating the IRMA report and allowing for the Heat Loss Assessment. For the vast majority we allow one and a half days. We have recently increased this charge for GSHP as it takes more time. The guidance on GSHP could be better communicated and consolidated. Scale of installation also has an impact, large installations or district heating installations with an extensive network of pipework simply take more time.
2. What are the impacts of any other barriers imposed by the requirement for an IRMA?
This is a question for the participant. I would imagine the barrier is in finding a suitable IRMA Author and being prepared to pay for their expertise.
Benefits of IRMAs
3. What benefits do IRMAs bring to installers, manufacturers, consultants, applicants and participants of the RHI scheme?
The requirement for an IRMA means that the installer and the applicants (or participants) have, in the first incarnation, a “snagging list”. Any errors of installation have to be corrected before the IRMA is submitted.
The participants have the advantage of an inspection of the works, ensuring that the installation is compliant and if it is not compliant, what can be done to make it so. The installer benefits by the learning opportunity presented during a site visit when the installation is reviewed and observations on the installation are made. We find that when working regularly with an Installer, over time the quality of the installation improves.
Ofgem benefits by having an unbiased and knowledgeable engineer review the installation and the documentation. Inadequacies and gaps are identified before being submitted to Ofgem and subsequently filled. This could mean a re-draw of the schematics, locating adequate documentation to support the application or providing consultancy services in terms of metering.
4. Are IRMAs used by applicants to help with completing an RHI application? If yes, do IRMAs make the process of completing an application simpler or quicker?
When we provide the IRMAs to an applicant or participant, we will advise that whole passages of the IRMA can be used to appropriately fill in the submission. There is a lot of duplication of effort between the IRMA, the HLA and the submission.
5. How often are on-site issues or errors identified by the IRMA author and resolved as a result of having an IRMA completed?
All the time, these only fade away somewhat when we work regularly with an installer.
6. Are there other forms of evidence Ofgem could rely on to satisfy itself that the metering arrangements of an installation are compliant with the RHI Regulations?
Inspect every installation before accreditation?
7. Are the criteria under which IRMAs are currently being requested appropriate for delivering the most benefits? If not, what criteria would be more effective?
The change from complex/simple to multiple/standard has led to confusion regarding when an IRMA is required, especially with the “properly insulated pipework” and “buried pipework” distinctions. Frequently it is when the submission is at the stage where the software requires an IRMA that one is commissioned. Once these issues are sorted out the need for IRMAs will diminish.
8. Are there any improvements that could be made to the IRMA template currently being used?
Yes. As previously stated, there is duplication of effort between the IRMA, the HLA and the submission.
Want to know more about RHI?
If you would like to know more about TEAM’s Independent Reports on Heat Metering Arrangements for RHI visit our RHI Services page or our Energy Consultancy Service section.
More about TEAM’s RHI Author
Justine Grant is the Energy Services Renewable Heat Incentive expert and course leader. Justine’s expertise lies in IRMA for RHI applications, non-domestic Display Energy Certificates and Advisory Reports, she is a technical author and trainer and is qualified as a CIBSE certified ESOS Lead Assessor. You can read her biography on the TEAM website here.
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