Those supplying and charging tenants for heating, cooling or hot water should have notified the National Measurement and Regulation Office (NMRO) by 31st December 2015. Failure to comply with the regulations is an offence and landlords could be facing thousands of pounds worth of fines.
The new regulations implement the requirements of the European Energy Efficiency Directive and apply to ‘heat suppliers’. Understandably, landlords don’t identify with that title and many assume they don’t need to take action.
However, a ‘heat supplier’ under the Regulations is any person or company who supplies and charges for heating, cooling or hot water, through either communal heating or a district heat network. Even a building owner/manager with a small area sub-let is classed as a supplier if the sub-tenant is charged for heating, cooling or hot water from the communal systems. This include those situations where the supply is included within a service charge or all-inclusive rents.
But it’s important to note that landlords who only supply heating, cooling or hot water to the common parts within a building, but not individual tenants’ premises, are not heat suppliers.
You might have missed the 31st December 2015 deadline but you still need to comply and the sooner the better.
This involves completing a notification (template spreadsheet) identifying all your communal/district heating arrangements, including existing meters to the NMRO along with energy consumption data. This will have to be updated every four years.
The heat metering viability tool which was intended to identify all those areas where heat sub-metering must be installed has been found insufficiently effective and has been suspended until a replacement is launched.
Any notifications already done (and viability checked using the old software tool) must check viability once more with the revised tool once it becomes available.
Pending revision of the tool, the requirement to install heat meters to measure final consumption from a heat network in buildings occupied by more than one final customer will not be enforced by the National Measurement and Regulation Office (NMRO).
Should the application of the revised viability tool indicate that you require sub-metering on your heat network, you will have to prepare for individual tenant billing. If this is not currently part of your core business you will need professional support to get it right at minimum cost.
My advice would be to act now, the NMRO is actively searching out for landlords who have not notified and there is the risk of fines for non-compliance. To maximise the potential benefits of the new regulations, and minimise the costs of meeting them, TEAM can ensure compliant notifications are produced and submitted on behalf of ‘heat suppliers’ and further down the line, provide a system for cost effective accurate billing methods depending on scale.
TEAM’s Energy Services can help organisations comply with the Heat Network Regulations 2014. Want to find out more? Get in touch by calling our experts on 01908 690018 or email firstname.lastname@example.org.
Justine Grant, TEAM Senior Energy Consultant, RHI expert and training course leader, is the lead author of the B&ES’s Guide to Good Practice: Heat Metering for the RHI. The guide was recently updated and the new version is available from the B&ES publications. She has written and delivered numerous training courses across the UK, on behalf of CIBSE, ESTA, B&ES and TEAM.
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