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Heat Strategy for Wales: Broadening the Vision to Encompass Energy Efficiency


In August, the Welsh government launched a consultation on its Heat Strategy for Wales document, designed to support the commitment to achieve net zero by 2050. This consultation has now closed, and Elmhurst was pleased to respond on behalf of its members.


What is the Heat Strategy for Wales?

The Heat Strategy for Wales document outlines the Welsh Government’s heat decarbonisation strategy, aiming to develop a decarbonised heat system that delivers the net zero ambitions.

The document covers various areas affecting heat decarbonisation across Wales as well as current schemes and initiatives in place to tackle barriers to entry for homeowners, landlords, and business owners. The strategy addresses the country’s short, medium, and long-term goals.

For more information on the Heat Strategy for Wales, visit our news page: Welsh Government outline their heat decarbonisation strategy for Net Zero 2050

Elmhurst’s Consultation Response:

We have summarised our response to each section below:

A vision for heat in Wales:

Elmhurst supports the vision of achieving clean and affordable heat for all in Wales. However, it is important that focus is also placed on the amount of energy being consumed in buildings.

Our enabling framework:

Elmhurst agrees that reducing the distance at which a heat pump can be installed means more homeowners can benefit from the low-carbon technology. However, it is important to ensure that the heat pump is adequately sized, and the fabric first approach is not lost.

We agree that the PAS standards are sufficient. However, funding provided to homeowners should mandate the use of the PAS process, ensuring recognised professionals such as Retrofit Coordinators are used.

Moreover, in order to ensure heat pumps are financially attractive, green taxes must be rebalanced to support the move away from carbon systems.

Transforming our networks:

Elmhurst supports the need for clear leadership and plans from the Welsh Government and local authorities to upgrade electricity networks for net zero. However, we also emphasise that funding and support are imperative to upgrade existing heat networks.

Improving the energy performance of our Homes:

Elmhurst agrees that stronger regulation is needed to encourage the uptake of low carbon heat. For this, we would like to see the enforcement and improvement in MEES (confirmed in non-domestic) back in the domestic market.

We agree that new gas boilers should be phased out, and low carbon alternatives included in the scope of further investment strategy. However, we do recognise that not all low carbon heating systems are viable for all homes. In order to properly measure the impact of addressing fuel poverty, an EPC should be updated whenever an improvement measure has been installed within a property.

Evolving our businesses:

There must be encouragement of net-zero through renewable opportunities to help support the move to electric driven heat systems. We also emphasise that the move away from fossil fuels must be tracked by measuring actual energy consumption in buildings, allowing government and businesses to understand the impact that energy related decisions.

Future-proofing our industry:

Any move away from one fuel type to another must be trackable and measurable in order to see the impact. The National Calculation Methodologies do not currently recognise Hydrogen as an available fuel type. This needs to be updated to ensure calculations can be done accurately.

Leading the way with public services:

Elmhurst agrees that it is important for public buildings to set a positive example for the commercial sector. To promote this, all public bodies should have an up-to-date energy certificate and publish the results. Any improvements made should also be shared or published.


Elmhurst supports the government’s vision of achieving clean and affordable heat for all in Wales. The proposed measures are poised to broaden access to low-carbon technologies and aid the country’s journey to net zero.

However, it is important for the government to not lose sight of the importance of energy efficiency in buildings. As we move towards net zero, the amount of energy being consumed is as important as the cost and fuel type used.

Moreover, further emphasis must also be placed on the funding available for consumers, as well as properly rebalanced green taxes, to ensure that low carbon technologies are affordable and a good investment.

Elmhurst awaits the government’s response to the consultation and will keep members informed of any updates.

Click the following link to read Elmhurst’s full consultation response – https://www.elmhurstenergy.co.uk/app/uploads/2023/11/Heat-Strategy-Wales-Consultation-response.pdf

Click the following link to view the government consultation –  https://www.gov.wales/heat-strategy-wales