Precisely - and it will be running at very low power anyway.
The problem is that for DHW, the heatbank needs to have very different characteristics.
If you segment the heatbank into two and deliberately run the lower half at a lower operating temperature, you are cutting into the storage for the DHW application. This implies either a larger or a separate heatbank to do the job.
This is why it is far better to treat the CH and the DHW as the two totally different systems that they are in terms of thermal characteristics and time constants and to simply drive the radiators from the modulating boiler. This is the intent of the manufacturer's design and without a more sophisticated set of sensors and controller than is inside the boiler, and a boiler that can be analogue controlled, if the gas boiler is the only source of energy, you won't improve on it.
.andy
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