10 Feb 2026
CIH responds to DESNZ consultation on the role of alternative clean heating solutions
Introduction
The Chartered Institute of Housing (CIH) is the professional body for people who work or have an interest in housing, with approximately 15,500 members across the UK.
A significant proportion of our members work in retrofit, sustainability, and energy-related roles in housing associations and local authorities, and we draw on their experience and expertise to inform our policy work. In addition, we are a registered charity with a duty to act in the public interest.
We welcome the opportunity to respond to the Department for Energy Security and Net Zero (DESNZ’s) consultation on alternative clean heating solutions. We agree that while heat networks and heat pumps will be the main technologies for heat decarbonisation, there is potential for other solutions to play a small but significant role.
To inform our response to this consultation, we have consulted with our members to understand their experiences of trialling and installing alternative clean heating solutions. We have also explored their views on the consultation at a roundtable held with officials in January 2026. Our response is shaped by their wide-ranging expertise, and knowledge of their homes, residents, and clean heating solutions. We also draw on published evidence from evaluations undertaken by CIH partner organisations across our response.
We have responded only to those questions where we can offer an informed view. To assist DESNZ’s understanding of our response, we have split our response into two sections:
- Covering the points and principles that we feel are relevant across all alternative clean heating solutions
- Providing responses to individual consultation questions.
We have also highlighted where our responses are based on real-world data (e.g. from trials) or the experience of our members, which is occasionally anecdotal and/or based on their experience of carrying out installations in the past.
Enablers for alternative clean heating solutions
CIH believes that for any alternative clean heating solution to be acceptable, it must be focused on reducing fuel poverty, delivering thermal comfort, and offering control to residents.
We would like to make the following general points that apply to all alternative clean heating technologies:
- All alternative clean heating solutions, as well as low temperature heat pumps, will be more affordable when supplemented by microgeneration and storage. This is especially important for solutions that are less efficient, as the consultation recognises. It is also vital for residents with health- or medical-related requirements for higher indoor temperatures, who may face additional electricity costs maintaining their home to a safe temperature.
- Similarly, alternative clean heating solutions will operate best when installed in homes with a high fabric performance. As the role of alternative clean heating solutions is explored, a parallel focus on fabric improvements, heat retention, airtightness, ventilation, and heat recovery should be maintained.
- Even if accompanied by microgeneration and storage, the high price of electricity relative to gas may make alternative clean heating solutions unaffordable for residents, especially in social housing, where household incomes tend to be lower. We urge the government to continue its work to remove levies and policy costs from electricity bills, and accelerate work on the Review of Energy Market Arrangements (REMA) to ensure alternative clean heating solutions can provide thermal comfort at an affordable cost to all.
- The role of tailored advice and support will be critical to the success of alternative clean heating solutions. In particular, alternative clean heating solutions that work most efficiently when they are left on all the time, are a completely unfamiliar form of heating (e.g. infrared), or require the use of load shifting and Demand Side Response (DSR), will be difficult for many residents to understand and benefit from. This emphasises the importance of good communication, advice, and aftercare in the installation of alternative clean heating solutions.
- There is a vital role for monitoring and evaluation, especially through approaches linked to the Internet of Things (IoT), SMETERs, and smart meters generally. If alternative clean heating solutions begin to be installed more widely, landlords, tenants, and homeowners alike should have access to robust data that helps them to install and use these solutions more efficiently, and in ways that work best for them.
- In rented housing, some smaller landlords (e.g. private landlords, small housing associations) may face greater risks and challenges associated with trialling and/or installing alternative clean heating solutions. Smaller landlords will require support if they (and their residents) are to benefit from alternative clean heating solutions in homes that are unsuitable for low temperature heat pumps or heat network connections.
- There is a critical need for correct installation, rigorous standards, strong consumer protection, and ensuring optimal performance. This is essential across any heating type, but innovative solutions may be more unfamiliar to existing installers. Any installations will therefore need to be undertaken by experienced, competent professionals who understand the manufacturer instructions and importance of aftercare.
- DESNZ must make sure through its work on Minimum Energy Efficiency Standards and the Home Energy Model that alternative clean heating solutions that are less efficient (and therefore more expensive to run) will not be considered to meet a future HEM Heating System metric minimum standard (i.e. ‘Heating C’) unless it leads verifiably to improved thermal comfort and reductions in energy bills. We are concerned that inefficient electric heating could be installed by some landlords because it is cheaper than a low temperature heat pump, but considered to meet Heating C. In other words, government needs to set the Heating C MEES target in a way that avoids incentivising actions with a lower capital cost, but that may lead to lower thermal comfort and higher energy bills for residents in both rented sectors.
- Finally, for all alternative clean heating solutions, it will be important for DESNZ to take steps to stimulate the emergence of a reliable supply chain for maintenance and decommissioning, as well as manufacture and installation. This is especially important for social housing providers, who will need to factor in maintenance and replacement costs to their long-term asset management programmes if they begin installing alternative clean heating solutions at a larger scale.
Responses to consultation questions
We agree. The use of thermal storage systems and microgeneration and storage can lead to very substantial electricity bill savings, especially if installed in homes with electric heating as this reduces the cost of heat as well as power.
Anecdotal and experiential evidence from our members, some of which is based on their experience of installing infrared heating in homes, has pointed towards some of the opportunities and challenges with infrared heating.
In terms of opportunities, our members told us they are interested in the role that infrared heating could play in combination with other clean heating solutions. For example, ASHPs or High Heat Retention Storage Heaters (HHRSHs) could be used to provide a low-level background heat and keep the temperature gradient low, with infrared heating used on demand to provide boosts to thermal comfort where desired by a resident. Infrared heating could also be used in Passivhaus homes, as explored in a recent academic paper. We would be interested in exploring how multiple forms of heating and design could be used in this way, including how they might be treated by SAP and HEM.
However, feedback also pointed towards some of the challenges with infrared heating. These are:
- Infrared heating is currently heavily penalised in SAP, which disincentivises its use. It was noted that this will become a larger disincentive when the rented sectors are regulated to meet Minimum Energy Efficiency Standards (MEES) by 2030.
- When switched off at night, the lack of residual background heat can cause temperatures to drop sharply. As an example of this, one of our members shared a previous example of a resident, despite feeling the infrared heating provided adequate thermal comfort during the day, who had to wear extra clothing in bed to stay warm.
- As has recently been found in research commissioned by DESNZ, the thermal comfort provided by infrared heating can be exceptionally subjective, and may be dependent on occupant line-of-sight being maintained to the emitter. This was also found in evaluation research undertaken by National Energy Action (NEA), which found “the infrared heating panel on the ceiling heated the upper half of the body and left the lower half cold”.
Research by NEA also noted that advanced time-of-use tariffs can benefit households with infrared heating, but suppliers can limit access to their tariffs to certain technologies. Research undertaken by Nesta also highlighted that residents with infrared heating had mixed experiences, especially in relation to using and controlling the system.
Overall, we agree with the conclusions of recent DESNZ research that further field research is required to ascertain if infrared heating can play any more than a very minor role in heat decarbonisation. Some of our members are trialling infrared heating, and we would also welcome the opportunity to connect DESNZ to these members to share any findings from monitoring or evaluation.
We agree that panel heaters should play a relatively smaller role in decarbonising heat, but we do think they can provide an important alternative in some archetypes.
CIH works closely with the housing association Midland Heart. Midland Heart’s Project 80 delivered the UK’s first Future Homes Standard compliant homes with social housing residents in situ. Monitoring and evaluation of this project demonstrated that panel heaters can provide an efficient, low-carbon heating option and are considered acceptable and useable by residents.
The interim findings of this evaluation are available here (see p.10 and p.12 for the detailed specification for each house type). Type 2 homes were fitted with panel heaters. A full evaluation report will be published imminently.
CIH would be pleased to facilitate a conversation between DESNZ and Midland Heart to discuss their use of panel heaters and the outcomes of their evaluation.
We agree.
SNG, a national housing association, has trialled the use of high temperature heat pumps (HTHPs) in six homes. CIH works closely with SNG, and we support the research they have undertaken alongside this trial. Their evidence shows the following benefits:
- There is a lower capex cost. The ability to use the existing microbore pipework and radiators in some homes has reduced the cost of installations. This is because the pipework and radiators do not need to be replaced, and through the avoidance of costs associated with redecoration. This means up to £2,000 per home lower capex cost.
- There are lower refusal rates. One of the most significant challenges experienced by housing providers when retrofitting ASHPs relates to resident refusal of access. While in some cases this is the result of poor practice by the housing provider, it can also be because of the level of disruption involved (e.g. because of replacing pipework, radiators, and redecorating) and the time taken by the installation (e.g. for ASHPs, this can take five days). SNG found that HTHPs can be installed in two days, around 40 per cent quicker than an ASHP, as well as reducing the disruption. Overall, this mitigates a significant time and cost barrier to large-scale heat pump retrofitting in homes.
Their evidence also shows that, while a small drop in efficiency due to higher flow temperatures can lead to higher running costs for HTHPs relative to ASHPs, there are ways of mitigating this, especially for housing providers, by:
- Ensuring HTHPs can adjust to weather conditions and operate at a variable flow.
- Utilising some of the capex saving to install solar PV and/or batteries, to reduce running costs. This is especially beneficial for residents with health- or medical-related needs for higher indoor temperatures, who can face higher energy costs to maintain the home at a safe temperature.
Overall, we feel there are significant opportunities associated with HTHPs, and would encourage DESNZ to engage further with SNG and other housing providers that are trialling their use.
Members have informed us about the following barriers in domestic properties:
- In Paragraph 5.10 of Approved Document L (Conservation of fuel and power), there is a 55 degrees C limiting factor that restricts the use of HTHPs in new build. As this is fixed flow, it also restricts the use of variable flow, which was one of the benefits explored in SNG’s trial (see our response to Q6).
- In Paragraph 6.37 of Approved Document L, the minimum Coefficient of Performance (COP) in Part L is stated to be 3.0. As SNG’s trial utilised weather compensation, the COP can vary by seasonal conditions and therefore dip below 3.0 in extremely cold temperatures.
These barriers could be removed by making small adjustments to Approved Document L to recognise the slightly different way HTHPs operate. However, we would note we would like to see data from other, larger HTHP trials to ensure these actions are supported by additional evidence.
We agree.
Orbit, a national housing association, trialled the use of low-load, air-to-air heat pumps. They found that it reduced carbon emissions and energy use compared to traditional storage heaters. It also led to improved comfort and control, giving residents app-based temperature management and the ability to pre-heat or pre-cool their homes.
Orbit also found benefits including improved indoor air quality, reduced installation costs (20 per cent compared to hydronic heat pumps), avoided grid reinforcement costs, and improved cooling capability.
CIH works closely with Orbit and would be pleased to facilitate the further sharing of evidence from this trial with DESNZ.
CIH strongly agrees with the commitment in the Warm Homes Plan to integrate passive cooling measures into government fuel poverty and retrofit schemes, and the parallel commitment to integrate cooling measures into the Home Energy Model (HEM). Many housing professionals working in sustainability-related roles recognise the risks posed to their residents by heatwaves and extreme heat, and have previously told us that SAP disincentivises the installation of shutters, reflective paint, and similar cooling measures by not recognising them.
The integration of cooling measures in HEM and the government’s fuel poverty and retrofit schemes should accelerate the installation of these measures. CIH has a longstanding programme of policy and research work on overheating, and would welcome the opportunity to support the government’s work on cooling. We have included links to our key reports on this topic below.
Feedback from our members suggests that there is an interest in the role of heat batteries to separate heating and hot water provision. In a well-insulated home, the hot water load can be more significant than the heat load. Separating these out, for example by having a heat battery installed alongside an ASHP, supplemented by solar PV, could help.
We would be interested in exploring how multiple forms of heating could be used in this way, including how they might be treated by SAP and HEM.
Anecdotal and experiential evidence shared by our members suggests that with the correct electricity tariffs, the proper use of Demand Side Response (DSR) and load shifting, and the provision of tailored, accurate advice about their use to residents, High Heat Retention Storage Heaters (HHRSHs) could be an affordable solution that provides thermal comfort for many homes.
However, experiential and anecdotal information shared by our members highlighted that one the main challenges with HHRSHs is that they can be hard to control effectively by residents, and that this can lead to feelings of alienation and dissatisfaction.
This correlates with evidence from evaluations of previous fuel poverty projects that included discussions of storage heaters. One evaluation, for example, found that “interviewees with storage heaters in their properties frequently described them as difficult (if not impossible) to control effectively”.
This evidence suggests that the quality and consistency of advice given to residents will be a critical enabler for the use of HHRSHs, even more so than for other heating technologies.
Our members highlighted there is also a possible role for HHRSHs in providing a low-level, background heat that keeps the temperature gradient low, but that can be supplemented with infrared heating to provide boosts in heat and comfort when desired by a resident. We would be interested in exploring how multiple forms of heating could be used in this way, including how they might be treated by SAP and HEM.
While we acknowledge that hydrogen is outside the scope of the present consultation, we would urge the government to bring forward its consultation on the role of hydrogen in home heating as soon as possible.
As we described in more detail in a submission to a Public Accounts Committee inquiry in 2024, anecdotal feedback from our members suggests that uncertainty over the role of hydrogen is affecting the decarbonisation strategies of social housing providers. Specifically, this feedback suggests that some providers with a significant number of homes on the gas network will only make key strategic decarbonisation investment decisions once the government makes a policy decision on hydrogen.
CIH feels the evidence is strong enough to largely exclude hydrogen from plans for our future home heating mix, and we welcome the signal given in the Warm Homes Plan that hydrogen is only likely to play a limited role in heating in the future. The government should continue to follow this evidence, and confirm in its pending consultation that hydrogen will have no role in home heating, or a very minor role, and not for several years. This would give some housing providers the certainty to move forward with heat electrification, including trialling some of the technologies discussed in this consultation.
As we have noted elsewhere in our responses, SAP can be a barrier to the trialling of alternative clean heating solutions in social homes. This barrier is likely to become larger as Minimum Energy Efficiency Standards (MEES) are introduced to the social rented sector. It is possible providers will be unwilling to trial new technologies that are penalised in SAP (or HEM) to avoid compromising their regulatory compliance.
Pilots and trials are essential to understanding the real-world utility of alternative clean heating solutions. The government could consider allowing a suitable authority, perhaps the Regulator of Social Housing, to grant time-limited exemptions to MEES for social housing providers that wish to undertaken small-scale trials of innovative clean heating solutions that are penalised (or unrecognised completely) in SAP or HEM, and therefore pull the home below SAP C or a future ‘Heating C’ on the new EPC regime. This would allow providers to trial innovative solutions in the future without risking their regulatory compliance. Any exemption of this kind would need to be closely monitored to ensure it did not result in negative outcomes for social housing residents, such as increased energy bills.
For more information on CIH's response, please contact Matthew Scott, CIH policy manager, matthew.scott@cih.org.
