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Heat strategy for Wales: Consultation Answers

gas boiler

Welsh Government’s ‘Heat strategy for Wales’ will impoverish Welsh households and will destroy what’s left of Welsh industry. Please fill in their form and send them some common sense.

https://www.gov.wales/heat-strategy-wales

For anyone that’s interested my answers are copied below.


Section 2: A vision for heat in Wales

Question = Vision: Do you agree with our vision? (Yes/No) Please suggest amendments if you think it could be stronger.
No
Answer = Your whole emphasis is wrong. The UK produces less than 1% of the worlds carbon emissions. 59 countries produce more carbon emissions per capita than us. Furthermore Wales uses less than the UK average. Your proposals will not make any meaningful difference to global carbon emissions, but your virtue signalling does threaten to impoverish the Welsh people. https://www.worldometers.info/co2-emissions/co2-emissions-by-country/

Question = Objectives: The Heat Strategy for Wales policies are broken down into 17 objectives within six groups. Do you agree they adequately cover the areas where Welsh Government needs to focus? (Yes/No) If you think there are any areas missing, please explain what they are.
No
Answer = The Welsh Government should be focused on bringing down the cost of clean energy in the form of electricity generated by Small Modular Nuclear Reactors and modern Gas-fired Power Plants. Dramatically increasing the supply of electricity will force the price to drop. When clean electricity becomes cheaper for heating than carbon-emitting alternatives we can rely on the free market to reduce emissions, without resorting to draconian measures.

Section 3: Our enabling framework

Question = Planning: Our Strategy identifies that the current permitted development rights related to heat pumps are a barrier to heat pump installation rollout. Do you agree? (Yes/No) Please explain.
No
Answer = The main barriers to heat pump rollouts are the fact that they are expensive, inefficient and unsuitable for most of Wales’s existing housing stock.

Question = Planning: Each local authority in Wales is producing a local area energy plan (LAEP).  This strategy proposes the LAEPs should be used to help deliver place-based heat decarbonisation. Do you agree with this approach? (Yes/No) Please provide evidence, where relevant.
No
Answer = Local authorities have no specific expertise in heating or energy solutions, so are not suitable to produce energy plans. The best way to ensure Wales produces less carbon is to reduce the cost of clean electrical energy, which will ensure free market decision making reduces our carbon emissions.

Question = Understanding and engagement: Does the strategy suitably address the advice needed to install low carbon heat? (Yes/No) Please explain which groups should be involved in raising awareness and providing advice.
No
Answer = Your strategy is doomed to fail, so any associated advice is a waste of time and money. You should be encouraging a dramatic increase in the generation of cheap clean electrical energy. As soon as clean electrical energy is cheaper then carbon emitting alternatives the public will switch without advice or duress.

Question = Standards: Do you believe the public available specification (PAS) standards are sufficient to ensure high-quality work and a whole-building approach? (Yes/No) Please explain.  How can the adoption and implementation of these standards be further encouraged?
No
Answer = We do not need public available specification (PAS) standards. A bad idea remains a bad idea no matter how it is defined.

Question = Skills: Do you agree that Welsh Government has a role in understanding and subsequently supporting the development of the necessary skills for heat decarbonisation? (Yes/No) Please highlight any emerging skills/roles which we should support.
No
Answer = Welsh Government’s focus should be on enabling a dramatic increase in clean energy production to ensure significant reductions in price. This can be achieved by allowing permissions for new Small Modular Nuclear Reactors and modern Gas-fired Power Plants, combined with long-term tax cuts for Welsh based energy producers. If Wales has access to cheap and clean energy, not only will it replace carbon emitting alternatives but also stimulate a boom in Welsh business.

Question = Costs: Do you agree with the position set out in the strategy that the UK Government should move environmental levies from electricity bills to general taxation? (Yes/No) What additional policies should be implemented to ensure a fairer distribution of costs?
No
Answer = We are already one of the highest taxed countries in the world and our energy costs are near the highest worldwide. Our current energy and taxation costs will inevitably impoverish the Welsh people and destroy Welsh business. We should be looking at reducing both electricity bills and also reducing taxation. Our emphasis should be on encouraging a dramatic increase in clean energy generation by encouraging investment in new clean power stations from an invigorated private sector.

Section 4: Transforming our networks

Question = Electricity networks: Do you agree that upgrading Welsh electricity networks for net zero will require clear leadership and plans from Welsh Government and local authorities? (Yes/No) Please explain your reasoning and highlight any further roles for Welsh Government on this challenge.
No
Answer = Free market forces should be the only stimulus required for investment into the electricity networks. For example, if EV owners need charging points, then the potential profit associated with selling the electricity should attract private investment.

Question = Heat network zoning: Do you agree that local area energy plans (LAEPs), led by local authorities, is an appropriate method for identifying areas for heat networks? (Yes/No) Please explain.
No
Answer = Local authorities are unsuited to select appropriate locations for heat networks, except in their own new developments, for example council offices, new social housing etc. They lack the commercial and technical knowledge to make the right decisions in general housing, commercial and educational contexts. The fact that heat networks have the potential to reduce bills should be enough for them to be rolled out where appropriate just based on free market forces; every well managed organisation wants to save money. Furthermore local authorities LAEP’s, if imposed on 3rd parties, could lead to bureaucracy and even corruption.

Question = Heat network connections: Do you agree that new housing developments and large commercial buildings should be required to connect to new district heat networks? (Yes/No) Should small scale, ambient temperature, heat networks be included in this obligation? (Yes/No)
No No
Answer = If heat networks provide cheaper heating, are convenient and practical then developers will incorporate them without government interference.

Question = Heat network support: Do you agree heat network development requires further funding and support? (Yes/No) Please explain.
No
Answer = Ultimately any government support of heat network development will either lead to higher taxation or more debt. Furthermore the governments track record of allocating subsidies is dismal and often leads to corruption. If heat networks really save money then business will incorporate them without help from the tax payer.

Question = Hydrogen for heat: The strategy states that based on evidence gathered, heat pumps will be the championed solution for most building heat. Hydrogen’s role will be in defined zones for high-temperature industry, as well as for wider net zero solutions prioritised by how useful hydrogen will be (known as ‘the hydrogen ladder’). Do you agree that a clear statement is needed on hydrogen’s role in meeting Wales’ heat decarbonisation ambitions? (Yes/No) Please explain.
No
Answer = It has been known that hydrogen is a clean burning flammable gas since 1650. Every student that’s passed O level Chemistry knows how to make hydrogen and understands its properties. Therefore all Welsh people already knows about hydrogens use as a fuel and most also know about its energy storage potential. If the Welsh Government insists on telling educated people about hydrogen, then wasting time and money is all that you will achieve.
https://www.thechemicalengineer.com/features/uses-of-hydrogen-in-industry/

Section 4: Improving the energy performance of our homes

Question = A clear framework: Do you agree that stronger regulation is needed to encourage the uptake of low carbon heat and more energy efficient homes? (Yes/No) What other interventions must be implemented alongside stronger regulation to ensure no one is left behind?
No
Answer = Welsh households already suffer from some of the highest costs of energy worldwide, so have every required incentive to make their homes energy efficient. Currently Wales produces less carbon per capita than almost every other developed country worldwide. There is no need to introduce more regulations to solve a problem that doesn’t exist.

Question = Holistic approach to fuel poverty: The Warm Homes Programme has been offering new gas boilers, where appropriate, to those eligible., Do you agree that our future investments in energy efficiency must, where possible, simultaneously support our heat decarbonisation pathway? (Yes/No) Please explain and expand on opportunities to address fuel poverty holistically.
No
Answer = Fuel poverty and energy efficient heating are 2 separate problems and require different solutions.
Fuel poverty is a direct consequence of Welsh people being too poor and our energy prices being too high. We need to lower taxes to ensure people have more money to spend on fuel, combined with dramatically increasing the supply of energy to ensure price drops. This can be achieved through increasing the approval of Small Modular Nuclear Reactors and modern Gas-fired Power Plants.
Energy efficient heating can be encouraged through public awareness campaigns calling for higher standards in new house insulation, double glazing, heat pumps and boiler design. If people are made aware that there is a more efficient and cheaper way to stay warm then they will change without government interference.

Question = Traditional buildings: Do you agree that demonstration projects for historic and traditional building retrofit are needed? (Yes/No) Are there further interventions needed to grow the market for traditional building retrofit?
No
Answer = Many of Wales’s traditional buildings are simply unsuited to heat pumps. Furthermore there traditional building that are suited to convert to heat pumps already suffer from very high heating bills. Owners of these properties will seek out cheaper heat alternatives, without government help, if their properties are suitable. Demonstration projects could never represent all the various property types and nuanced challenges. What you should be doing is producing Case Studies detailing money saved from real retrofits and then letting people make up their own minds. Property owners are typically well educated and always want to save money, they don’t need the government to ‘spoon feed’ them information that doesn’t directly relate to their circumstances.

Question = Smart meters and variable tariffs: Do you agree that emphasis on smart meter rollout and variable tariffs are important to address now, to minimise bills during the transition to low carbon heat? (Yes/No) How best can Welsh Government support this, while advocating for those who are unable to participate in energy flexibility?
Yes
Answer = Smart meters and variable tariffs do make sense for some households, for example encouraging people to charge cars overnight. However for other people with inflexible energy use patterns, for example home workers operating office hours, variable tariffs and smart meters will not help reduce their bill. Everyone I know that has an electric car already uses variable tariffs and charges their car in the early hours of the morning. Again you can rely on successful people to take advantage of these cost saving techniques without government intervention of encouragement. The government should just get out of the way and let the free market encourage variable tariffs and smart meters.

Question = Upfront cost of heat pumps: Do you agree that dedicated long-term finance packages are needed to support the installation of heat pumps? (Yes/No) Please explain.
No
Answer = The average household debt in the UK is £65,434 in 2023, up by £1,852 compared to 2022. Household debt is approximately 131% of household disposable income. The last thing Welsh households need is to be encouraged to take on more debt. If heat pumps promise to save money then household and landlords will find the money to save on bills, without government forcing people to take out finance packages.

Section 4: Evolving our businesses

Question = Regulation: Do you agree that stronger regulation is needed to phase out fossil fuel boilers, on and off-grid, in commercial properties? (Yes/No) What other interventions must be implemented alongside this stronger regulation to ensure this transition does not have adverse impact on businesses.
No
Answer = The best way to phase out fossil fuel boilers in commercial properties is to ensure clean electrical heating alternatives are cheaper than fossil fuel boilers. We need to increase the number of Small Modular Nuclear Reactors and clean Gas-fired Power Plants to dramatically increase the supply of electricity, forcing the price to drop.

Question = Accelerator programme: Do you agree that an accelerator programme is needed to share best practices and build confidence in low carbon heat, across different commercial building types? (Yes/No) Please explain.
No
Answer = People who own and run commercial building are not stupid and are fully motivated to cut costs and be as efficient as possible. They don’t need an accelerator programme. For example, commercial properties did not need an ‘accelerator programme’ to adopt double glazing, they did so to save money without government encouragement.

Question = Net zero targets and tracking: Do you agree that heat decarbonisation will require us to foster a culture of transparency and accountability for businesses? (Yes/No) With reference to heat decarbonisation, what more should Welsh Government do to ensure reliable information is communicated to customers?
No
Answer = We already have a ‘a culture of transparency and accountability for businesses’ in Wales, with businesses being regulated from a financial, environmental and ethical standpoint through various agencies. Furthermore Welsh business exists in a competitive environment, where seeking out cost cutting efficiencies can make the difference between profit and failure. The way to make Welsh business decarbonise is to make clean electrical energy cheaper than fossil fuel alternatives.

Section 5: Future-proofing our industry

Question = Industrial roadmaps: Do you agree that we should create decarbonisation roadmaps across key industrial applications, and if so which champion the best available techniques? (Yes/No)  Should Net Zero Industry Wales have a role be in this process? How can the identified techniques be effectively disseminated and further incentivised?
No
Answer = Welsh industry operates in a global marketplace and is more qualified to understand decarbonisation opportunities than the Welsh government. Furthermore no two industrial processes are identical, so central government generated roadmaps risk being patronising and irrelevant. Successful industry is already incentivised to save money; if decarbonising will cut their bills and increase their profit then they will change without government ‘roadmaps’.

Question = Small and medium-sized enterprises (SMEs): As an integral part of the industrial sector, what specific resources or assistance are needed to help industrial SMEs with their heat decarbonisation?
Answer = Much cheaper electricity

Question = Industrial hydrogen: Do you agree that Welsh Government has a role in understanding and mapping future demand for hydrogen from high temperature industrial heat, to ensure the infrastructure is in place to allow fuel switching? (Yes/No) Please explain and expand on Welsh Government’s role, if applicable.
No
Answer = Most educated people already know about hydrogens potential as a fuel and as a storage medium for power. We don’t need the government to state the obvious to successful managers and engineers within industry. What industry needs is cheaper electricity so producing hydrogen becomes cheaper. If hydrogen is cheaper for industry than fossil fuels then industry will switch without government help.

Section 6: Leading the way with public services

Question = Leading the way: Public buildings provide vital services across Welsh communities. Do you agree that a near-term focus for this Heat Strategy should be to improve resilience, by continuing to decouple our public buildings from fossil fuels and improve their energy efficiency? (Yes/No) How can this help lead the way to decarbonise the rest of Wales’ buildings?
No
Answer = Our national and local government finances are precarious, combined with Welsh households suffering under record high taxation and debt. Therefore Welsh government should only encourage public buildings to change when there is a clear cost-cutting argument. Energy efficiencies is a separate question to what fuel type is used. Well managed public buildings will already seeking energy efficiencies. The focus should be on reducing the cost of cheap and clean electricity and let public buildings upgrade to electrical heating to save money.

Question = Collaboration: Our Strategy states the need for public bodies to collaborate effectively to ensure successful and cost-effective transitions. How best can Welsh Government support effective collaboration and shared learning?
Answer = Energy efficiency and clean energy generation is a global problem. Many of the brightest minds are already working on this from industry and academia worldwide. The global scientific community already share best practices, research data and collaborate on solutions. The Welsh Government is not a concentration of scientific expertise, so is unsuited to ‘support effective collaboration and shared learning’. You’re better off leaving scientific collaboration to the experts.

Question = Resource and skills: We have identified that skills and capacity building in public bodies are essential to support local area energy planning, resource local planning authorities, and deliver the transition on the public estate. Do you agree that the Energy Service is best placed to support this upskilling and provide additional resource? (Yes/No) Please explain.
No
Answer = The government shouldn’t be developing an in-house energy efficiency department like the Energy Service, as it risks becoming outdated, bloated, politically motivated and bureaucratic. It is far better to hire in private sector expertise to advise and enhance capacity building in public bodies.

Section 7: Taking action

Question = Our asks of others: Do you agree that we have identified the main asks of others? (Yes/No) Please explain.
No
Answer = You have missed the most important factor that would help Wales, without impoverishing itself, to decarbonise. The key to success will be to bring down the cost of clean electricity which will cause Wales to switch without duress. Welsh government should be encouraging the setup of new Small Modular Nuclear Reactors and modern Gas-fired Power Plants to dramatically increase the supply of clean energy, which will bring the price down.

Question = Costs and savings:  The costs set out in the strategy are drawn from the Climate Change Committee analysis.  Is there additional  evidence on the costs and potential savings that we should consider?
Answer = Stop seeing the solution as a top-down command and learn how to tweak the free market to produce a solution. Your proposed approach to the carbon emissions problem promises to bankrupt Wales. If we bankrupt ourselves chasing unrealistic targets we will discourage others to follow.

Question = Our routemap: Do you agree that our policies routemap is sufficiently clear? (Yes/No) Please explain.
No
Answer = Your ‘roadmap’ seeks to obfuscate the true costs to Wales of your proposal, so is unclear by design. The average person would have no idea how impractical and expensive your proposal is without research. I presume this was done to minimise the political impact of your bad proposal.

Question = Our pathway: The strategy is based on the Climate Change Committee’s Balance Pathway.  Do you agree with this approach? (Yes/No) Please explain.
No
Answer = The UK produces less than 1% of the worlds carbon emissions. 59 countries produce more carbon emissions per capita than us. Furthermore Wales uses less than the UK average. Your proposals will not make any meaningful difference to global carbon emissions, but your virtue signalling does threaten to impoverish the Welsh people. https://www.worldometers.info/co2-emissions/co2-emissions-by-country/
The only realistic and viable solution to decarbonise Wales is to make clean energy cheaper than fossil fuel alternatives.