THE Consistory Court of the diocese of Winchester has granted a confirmatory faculty authorising Christ Church, Chineham, to make use of two alternative gas boilers that had been installed and not using a faculty and without proper consideration given to the Church Buildings Council’s net-zero guidance.
The Diocesan Chancellor, the Worshipful Cain Ormondroyd, said that the case presented “a cautionary tale in respect of the difficulties that may arise when proper consideration shouldn’t be given at an early stage” to the guidance.
The key points to be distilled from the guidance are that churches must be properly heated; that the proposed and certain use of the constructing should be considered, assessing its needs; that any proposed heating system should be inexpensive; that a correct appraisal of heating options will generally involve placing all possible systems so as of merit by way of meeting the net-zero goal, and identifying the highest-placed system that meets the needs and resources of the church; and that the court should consider whether conditions ought to be imposed when granting a college, particularly in relation to offsetting.
Christ Church, Chineham, is run as a single-congregation local ecumenical partnership between the Baptist Church, the Church of England, the Methodist Church, and the United Reformed Church. The Vicar, the Revd Jonathan Clark, who can be a petitioner for the confirmatory faculty, is, nonetheless, the lead and only minister.
The church constructing is comparatively modern: in-built 1987, it was prolonged within the early 2000s. It is in use throughout the week for church and community events.
The church had previously been heated by three gas boilers of various ages, each accountable for heating a unique a part of the constructing. From late 2023, the boilers began to fail, and, in March 2024, the petitioners sought quotations for alternative boilers.
An energy audit that had been undertaken was very positive about heat pumps. It observed that installing recent gas boilers “would lock the constructing into fossil-fuel use for one more 20-year period”, which was well past the goal date of 2030 for carbon neutrality.
On 22 July 2024, the petitioners decided to proceed with the work of putting in gas boilers. At that date, they’d not received any indication of a substantive objection to their proposals from the DAC. They believed that the authorisation for which they were asking would inevitably be granted in the end. Before the Chancellor, the petitioners characterised their approach as “naïve”.
The petitioners justified their decision to put in the brand new gas boilers on the idea that it was imperative that they get replaced in time for winter. The work was carried out badly, nonetheless, and a second contractor needed to be brought in to treatment the situation in February 2025, at a further cost.
The DAC didn’t recommend the grant of a college since it felt that the parish had not adequately explored more sustainable options for heating.
The Chancellor said that he had been left “within the difficult position of getting to come to a decision what to do now”. Making an order requiring the immediate removal of the unlawfully installed gas boilers could be “a drastic plan of action”, he said.
Winter was approaching, and it might impose an extra heavy burden on the petitioners in the event that they needed to do more work on an expedited basis to explore different options. That was in no one’s interest, the Chancellor said.
Therefore, the Chancellor concluded that the gas boilers ought to be allowed to stay for 3 years. That would give the petitioners sufficient time to contemplate matters with none undue pressure or hurry, while also allowing for the installation of a more sustainable type of heating before the 2030 goal date.
During the three-year period, a condition was imposed, as suggested by the guidance, requiring that any carbon emissions from the operation of the gas boilers be offset.

