So, I just reread the Ministry’s guidelines (Search: 65 percent renewable energies for the installation of new heating systems from 2024 Implementation concept). It is quite clear from this that:
- the regulation applies in the event of a gas boiler failure. For example, gas individual heaters are explicitly mentioned:
In gas individual heaters, the obligation to use 65 percent renewable energies generally applies when the first gas individual heater in the building fails after the regulations come into effect on January 1, 2024, and needs to be replaced.
- there are somewhat more relaxed regulations for hybrid heating systems, since here the heat pump only has to cover 30% of the building’s heating demand - which could financially be a somewhat tolerable model for our case:
Another option is the installation of a so-called hybrid heating system. This is a heating system where a maximum of 35 percent of the consumed heat is generated with fossil fuels. The remaining share of at least 65 percent must be provided by renewable energies (biomass, heat pump, solar thermal energy, green gases, or a heating rod or heating cartridge 5 operated with photovoltaic electricity from the roof of the building or from the neighborhood). Compliance with this requirement must generally be calculated in advance based on estimates. To simplify and facilitate the implementation of this requirement, in a hybrid heating system consisting of fossil gas or oil boilers combined with an electric heat pump, compliance with the 65-percent obligation is assumed provided that the power share of the heat pump is 30 percent or higher.
- there is a 3-year period within which a replacement must be made in the event of a failure. That means you can initially have a replacement device installed and then later supplement it with a heat pump:
In cases of heating system failures where the conversion to 65 percent renewable heat would only be possible in the short term through green gases or liquid biomass, the obligation to meet the 65-percent-RE requirement does not have to be fulfilled immediately upon heating installation, but only within three years after the heating replacement. During this transition period, the building owner may temporarily install and use a (possibly used) gas or oil heating system and then supplement or replace it within three years with a heating system that meets the requirements of the 65-percent-RE obligation.
- it is definitely possible to heat with biogas, but it is not necessarily recommended:
In gas heating systems operated with sustainable biomethane, green hydrogen, or other green gases, the permanent supply of at least 65 percent green gases must be contractually proven and verified via a secure certification system (mass balance system or certificate of origin system). Since medium- to long-term high demand for biomethane and other green gases is expected in other sectors, significant price increases for the supply of biomethane and other green gases are anticipated. Against this background, a tenant protection regulation is provided. According to this, landlords must cover costs exceeding the basic gas supply tariff in the event of using biomethane or green gases.