Heat networks will only play their intended role in the transition to low-carbon heat if they work consistently for residents. That means reliable service, fair pricing and systems that are properly designed and maintained. 

Our response draws on members’ experience of running a large and varied portfolio of heat networks. It focuses on how the proposals would operate across both new and existing systems, particularly where older networks, mixed-tenure buildings and funding constraints create real delivery challenges.

We set out where the current model is unlikely to work as intended. The proposed framework is complex and resource-intensive, with requirements that do not reflect the starting point of many existing networks. Without changes, there is a clear risk of higher costs for residents and a slowdown in improvement, rather than the step change in performance the scheme is aiming for.

We propose a more workable approach, with a clear distinction between new and existing networks, a defined transition period, and a focus on outcomes that can be delivered and sustained over time. This includes minimum service standards, transparent pricing and a practical route to upgrading legacy systems.