The effect of vertical heterogeneity of permeability, on the onset of convection in a horizontal layer of a saturated porous medium, uniformly heated from below but with a non-uniform basic temperature gradient resulting from transient heating or otherwise, is studied analytically using linear stability theory. Two particular situations, corresponding to instantaneous bottom heating and constant-rate bottom heating, are studied. Estimates of the timescale for the development of convection instability are obtained.