RHI - consultation on change to heat metering requirements

Welcome to our first blog post of 2013.  

In the spirit of 2012 we will commence the year with yet another consultation on the RHI!

Whilst this latest consultation is fairly straightforward it will have important implications for installers, particularly those that have been preparing their own IRMAs (Independent Report on Metering Arrangements).

Also, as the proposals are likely to incur additional costs for both installers and consulting engineers looking to provide IRMAs it may well be worth taking a few minutes to read the consultation and send your feedback to Ofgem.

Ofgem's current guidance on metering can be found here.

The consultation has been prompted by the apparent low quality of IRMAs received by Ofgem to date:

• Early site audits of RHI applications revealed a high level of errors in metering arrangements, particularly in the location or installation of meters.
• Many of these errors would impact on the accuracy of heat generation data but had not been identified in the IRMAs submitted.
• IRMAs received to date are often inconsistent with other documentation or show poor understanding of the RHI eligibility requirements. As a result, Ofgem has been unable to rely on IRMAs to verify the eligibility of metering solutions, thus considerably reducing their value to applicants and Ofgem.
• Overall the errors found in IRMAs to date are felt to be indicative of two main issues: inadequate levels of independence and inadequate levels of scheme and technical knowledge.

In response to these challenges Ofgem is now consulting on six proposals:

Proposal 1:

The applicant will need to stipulate that ‘the IRMA author must have no contractual or other relationship (beyond any contractual arrangement to produce an IRMA) with the metering installer, the applicant or the system designer’.

Proposal 2: 

RHI applicants will need to verify the eligibility and competence of their IRMA author by asking the author to confirm a series of statements within the RHI IRMA report template:

• The author has read and is familiar with the RHI Guidance documents and RHI Scheme Regulations 2011, in particular the metering requirements;
• The author is able to detect meters which have been fitted and/or located incorrectly alongside any other defects or system configurations which could adversely affect the meter‟s ability to accurately measure heat production;
• The author is familiar with the metering requirements of the MID Annex 1 and is able to determine whether or not a meter is compliant with MID Class 2 metering requirements;
• The author understands the difference between „simple‟ and „complex‟ metering arrangements as specified in the RHI Guidance documents and is able to determine which of these arrangements applies to the applicant‟s circumstances; and
• The author is able to determine whether or not a schematic diagram accurately reflects (in sufficient detail) the applicant‟s physical installation and heating systems.

Proposal 3:

For further clarity, the following additional changes be made to the RHI IRMA report template:

• questions in the report template will be made more explicit;
• questions relating to external pipe work and additional buildings will be included;
• a higher level of evidence for compliance will be set including the provision of photographs;
• additional questions will be included on the evidence of MID Class 2 accuracy of meters;
• to support the questions on evidence of meter accuracy and meter conformity, specific evidence (in the form of document copies and/or photographs) must be appended to the template. For example, this can include photocopies and photographs to confirm MID Class 2 accuracy. This will be in line with the evidence requirements set out in our published „RHI Frequently Asked Questions – Metering‟7; and
• inclusion of the following additional declaration which the IRMA author must sign to confirm that the installation has met the RHI eligibility criteria (see here for guidance).

Proposal 4:

To recommend that all IRMA authors undergo assessment to increase their technical and scheme knowledge via a recognised assessment programme.  Ofgem suggests that such assessment programmes are in development (e.g. via The Building and Engineering Services Association (B&ES), Building Services Research and Information Association (BSRIA), Chartered Institute of Building Services Engineers (CIBSE) and Energy Services and Technology Association (ESTA).

Proposal 5: 

That all meters be robust against tampering.

Proposal 6: 

The sharing information on the quality of IRMAs with the IRMA authors themselves and with their assessment, trade or professional body, in order that those bodies are able to address any issues and provide the appropriate protection to the public.

The consultation letter can be found on the Ofgem website using the following link:

http://www.ofgem.gov.uk/Pages/MoreInformation.aspx?docid=47&refer=e-serve/RHI

The consultation extends for 8 weeks with responses due by the end date of 4th March 2013.