The Chartered Institute of Housing Northern Ireland (CIH NI) has welcomed the opportunity to respond to the Department for the Economy's (DfE) consultation on heat networks. While heat networks are currently uncommon in Northern Ireland, the institute notes their potential to cut carbon emissions from heating, which accounts for about 44% of Northern Ireland's energy consumption. CIH NI supports DfE's plans to research where heat networks would be most effective and recognises the linked economic and employment opportunities. It also underlines the need to explore affordable, low-carbon alternatives to meet decarbonisation and net zero goals.

Given the scale of change and the expected growth in connections, CIH NI says the regulatory framework must maximise protection for customers while creating a stable, financially viable environment for operators to function and invest.

With fuel poverty affecting 24% of households in Northern Ireland — almost 180,000 households estimated to spend at least 10% of their income on energy — CIH NI stresses that those in or at risk of fuel poverty, and people with cold-related vulnerabilities, must be adequately protected. The institute welcomes DfE's proposals for clearer consumer information and a supplier code of conduct to strengthen protections and increase customer engagement. If this approach proceeds, it says consumers need clear, consistent guidance on the three-step complaints process so they understand the route and who to contact first.

On scope (Question 1), CIH NI agrees with the types of heat networks that should be covered and those that should be out of scope as outlined by DfE.

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On authorisation (Question 2), CIH NI supports an authorisation regime rather than licensing, including deemed authorisation for existing networks. It describes this as a pragmatic approach that avoids unnecessary administrative barriers, enables sector growth, and supports the transition to lower-carbon heat while maintaining appropriate standards and protections and improving energy efficiency and reliability.

On metering and billing (Question 3), the institute considers the existing approach under the HNMBR to be appropriate for the Northern Ireland market when implemented through the proposed authorisation framework.

On complaints (Question 4), CIH NI views the illustrative three-step route — first the operator, then the Consumer Council for Northern Ireland (CCNI), and finally the Utility Regulator (UR) for rule-compliance issues — as a sensible way to ensure customers are heard and grievances are handled constructively.

On a code of conduct (Question 5), CIH NI backs making a supplier Code of Conduct, developed with CCNI and the UR, an authorisation condition to provide robust consumer protection, supplier accountability, a level playing field and greater reassurance for heat network customers.

On a public register and customer information (Question 6), CIH NI recommends that the register include details of suppliers, network locations, development types (for example social housing, mixed tenure and commercial premises) and the average cost per resident, to support better policy-making as the market grows. It says consumers should receive best-practice advice on using their service to minimise costs and maximise efficiency, as well as clear information on their rights, the complaints pathway and helpline contacts. Information should be available in print, digitally and by phone, with recognition that some customers need more involved support and telephone contact rather than email or post.

On wider implementation (Question 7), CIH notes its close involvement in the development of heat network legislation in England and offers to work with DfE to share lessons and experience to help deliver a proportionate, effective framework in Northern Ireland. It highlights that heat networks are relatively well established in England's social housing — with around one in 12 social housing residents connected — whereas uptake in Northern Ireland remains limited. Given DfE's decarbonisation ambitions, CIH NI anticipates social housing providers may increasingly be encouraged to consider heat networks for both new and existing developments.

CIH NI concludes that early, meaningful engagement with the housing sector will be key to identifying challenges sooner, reflecting the needs of providers and residents in emerging regulations, supporting a smoother rollout and avoiding issues encountered in England. This, it argues, will improve the long-term viability, effectiveness and success of heat networks in Northern Ireland.