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Heat Networks

Raising the temperature, lowering the carbon

Heat networks sector expertise

Heat networks generate or take heat from a central source and distribute it to multiple homes and/or businesses via a network of underground pipes.  They are an alternative to each property having its own gas-fired boiler and heat is often supplied alongside cooling and/or private wire electricity.

They come in many shapes and sizes, whether simply supplying multiple units within a single building (communal heating) or serving multiple buildings or developments (district heating).  They will play a vital role in the transition to net zero by 2050, with Government aiming to grow the sector tenfold by 2050.

The sector is in the process of becoming regulated for the first time and so anyone who operates a network or supplies heat or cooling will need to understand how to comply.

Why choose our heat networks team?

Our dedicated team has collective experience of over sixty projects and we have acted for all manner of stakeholders, including new build property developers, landlords, commercial property owners, manufacturers, local authorities, investors, energy services companies (ESCOs) and outsourced service providers.

We offer a full service, covering any legal aspect of a heat network project, including project contracts, regulation, procurement, corporate, construction, real estate, sustainable development, banking and finance, environment, planning, data protection and tax.  

We provide end-to-end support across all phases of a project, including: 

Structuring, planning & regulatory

ESCO/service provider procurement Infrastructure, design & build
Contract negotiation & grant of land rights Board approval Implementation & team training

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“Freeths guided us through complex legal issues, breaking down intricate drafting into terms we could easily grasp. Thanks to their diligence we completed the agreement on time. We can't recommend Freeths highly enough to anyone seeking heat network legal advice - their commitment to clients is truly outstanding."

Senior Development Manager, National Housebuilder 

Heat network project advisory: all types and sizes

  • Long-term ESCO concession or evergreen arrangements where all risk is passed to an ESCO
  • Shorter-term outsourced services agreements for heat metering, billing, tariff-setting, operation and maintenance
  • Landlord-led schemes
  • Recovered heat off-take arrangements
  • Connections into existing heat networks
  • Multi-development networks
  • Joint venture arrangements
  • Retrofitting networks

Our heat networks legal experts can assist:

  • Residential and commercial property developers, landowners, local authorities or housing associations who are installing or connecting into heat networks
  • Landlords or other heat suppliers keen to ensure compliance with incoming regulation
  • ESCOs or service providers looking to offer heat-related services
  • Asset owners looking to retrofit an existing heat network
  • Sustainability officers setting and implementing a sustainability strategy
  • Company directors wanting to understand corporate responsibility under regulation
  • Investor looking for a new asset class / investment opportunity
  • Manufacturers or other industrial business looking to recover and use waste heat
  • Energy from waste or data centre operators looking to sell recovered heat
  • Contractors in the heat network supply chain
  • Community energy projects

What is a heat network?

A heat network is a system that uses one or more central sources to generate heat, which is then pumped through underground pipes to provide space heating and hot water to homes and businesses. They can operate at high or ambient temperatures and often the heat is supplied alongside cooling and private wire electricity. 

They are a common feature of new build residential and mixed-use developments, city regeneration schemes and commercial/industrial buildings. Capturing and supplying waste heat from sources such as incinerators or data centres can also create revenue opportunities. Boosted by government funding and first-time regulation, the UK market is rapidly growing and attracting private investment. 

Some heat networks are large enough to attract an energy services company (“ESCO”) to operate the network and supply heat to customers on a full-risk basis. Others are landowner-led where one or more services are outsourced to a service provider, such as operation, billing and customer services. Some schemes are best served by a hybrid of the two.

Heat generating technologies

The most appropriate technology can depend on the customer demand profile, density of the buildings to be supplied, the ground conditions and the proximity of the site to a waste heat source. Larger schemes can utilise more than one type of generating plant along the network.

  • Gas - the vast majority of the UK’s legacy heat networks are gas-fired high-temperature systems and can often be used to generate both heat and electricity, known as “combined heat and power” or “CHP”. They are no longer considered low-carbon and new installations will not meet planning or building regulation standards. Over time, existing systems will be phased out for lower-carbon solutions.
  • Heat pumps – these run on electricity. They take ambient heat from the air, water or ground and can boost and/or reduce the temperature to provide heat and/or cooling. They can also boost the temperature of waste heat from sources such as industry and data centres. Large-scale heat pumps are the most widely used alternative to gas-fired CHP and smaller-scale ground source schemes are ideal for low density housing.
  • Waste heat recovery – many commercial and industrial process create heat as a byproduct, which can be harnessed and either re-used by the owner or sold to third parties, perhaps neighbouring developments. Energy from waste plants and data centres are common sources.
  • Geothermal – heat can be taken from the ground at temperatures ranging from 10°C to 40°C degrees, depending on the depth of the borehole. Former coal and tin mines provide ideal extraction infrastructure.

Property rights

All heat networks run through land or buildings and so operators will have to ensure that they have sufficient access rights. Short-term service operators should be granted a simple access licence, whereas ESCOs taking long-term operational risk will expect a lease of the generating plant and a lease or easements over the network. It is imperative that landowners accommodate such rights in their development and disposal plans. 

Heat network regulation

The heat networks sector is at the start of a major transition, facing its first wholesale regulation with the introduction of the Heat Networks (Market Framework) (Great Britain) Regulations 2025. This creates new regulated activities of a heat supplier and a network operator, meaning that neither role can be carried out without authorisation.

The key aims of the regulations are to protect customers, improve technical standards, boost investor confidence and decarbonise the sector. It will be introduced in stages with the majority yet to be brought into force and much of the detail still subject to public consultation. The good news is that existing networks will automatically be authorised but operators and suppliers will have until January 2026 to make sure they can comply with the authorisation conditions and standards.

It is essential that anyone with an existing network (or planning one) understands their compliance obligations and the consequences of failing to meet them. Now is the time to understand what assets you control and which contracts may need amending to ensure compliance.

We can guide landowners, suppliers and operators through the regulatory requirements and future proof contracts for the changes to come. We can also support in the diligence of existing arrangements and how they may need to be adapted.

Heat network zoning

To help achieve its ambition of heat networks meeting one fifth of the UK’s heat demand by 2050, Government has sought to create customer demand and boost investor confidence by establishing heat “zones” – geographical areas identified as being suitable for a heat network to provide the lowest cost, low carbon solution.  

All new build properties, existing buildings with a communal heating system and non-domestic buildings above an energy use threshold, will likely be obliged to connect into the heat network.  

Heat zone co-ordinators will identify the zone boundary and potential heat sources, a role that will likely be undertaken by local authorities. They will procure and appoint an ESCO, which will be entitled to exclusively operate and make supplies within the zone. 

Government hopes to introduce regulation to govern the identification and management of zones at both a national and regional level during 2025. There has not yet been a formal response to the last consultation published in December 2023 but, in the meantime, a pilot scheme engaged with 28 local authorities to test and refine the methodology for identifying a zone.

Get in touch

Our specialist heat networks lawyers have extensive experience advising businesses on all types of heat network arrangements. Our team have acted for clients including public sector bodies, property developers, ESCOs, landlords and industrial businesses. Please reach out to the heat networks team below if you have any queries.

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Watch our latest webinars

  • Heat Networks - Part 1

    We hosted a follow up webinar discussing the decarbonisation and impending regulation of heat networks, and were joined by Barn Evans, Director at Turley and Arran Morning, Head of Heat Network policy at the Department for Business, Energy and Industrial Strategy:

    Heat Networks – Part 1 – an intro and hot topics – YouTube >

    Image of pipes
  • Heat Networks - Part 2

    We hosted a follow up webinar discussing the decarbonisation and impending regulation of heat networks, and were joined by Barny Evans, Director at Turley and Arran Morning, Head of Heat Network policy at the Department for Business, Energy and Industrial Strategy:

    Heat Networks – Part 2 – decarbonisation and regulation – YouTube >

     

     

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Utility Week

  • New to heat networks or need a quick refresher? This flyer breaks down what they are, how they work, and why they’re critical to the UK’s push for low-carbon heating. From energy centres to waste heat recovery and property rights, this is your go-to guide for understanding the fundamentals.

    Read more here...

  • Major regulatory change is underway. This flyer outlines the Heat Network Market Framework, explains the new roles of Ofgem and the Energy Ombudsman, and highlights what operators, landowners, and suppliers need consider to stay compliant. A must-read for anyone involved in heat delivery.

    Read more here...

  • Heat zoning is set to reshape how and where networks are developed. This flyer touches on how zones will be created, what they’ll require of developers and building owners, and the role of local authorities. Get up to speed on the policy driving mandatory network connections.

    Read more here...

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Meet our team

Patrick Adie's Profile

Patrick Adie

National Head of Housebuilding & Strategic Land

Sarah Rowe's Profile

Sarah Rowe

Partner and Head of Social Housing

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