so they are consulting on certain questions, but they aren't actually asking the question that we think they should ask, and the idea is for lots of people to respond to the consultation, challenging with a specific question along the lines of "I think you need to change this part of the standard as well"

for the avoidance of doubt you are referring to MCS020 clause 3.1(b) right?

@iancalderbank, valid point.

As a complete aside, I couldn’t help notice “41kWh of Battery storage (3x Powerwall 2)” in your signature. That is mightily impressive. 

There's a related change in regulations which will affect what MCS may do in future.

During 2024 there will be a new Independent System Operator and Planner (ISOP, aka Future System Operator) who will be responsible for operating all energy networks in GB (excl N. Ireland). They will also take on the role for advising HMG, and must implement strategies which result in us attaining Net Zero by 2050.

To provide regional input and democratic accountability, there are to be 14 Regional Energy Strategic Planning bodies (RESPs), whose remit and responsibilities are currently subject to an Ofgem consultation.

Note that the word 'Plan' occurs within the role of both the ISOP and RESPs.

I foresee that the ability of MCS to dictate matters regarding planning will need to be curtailed in favour of the ISOP who is actually required to deliver the 2050 objectives, which include Net Zero domestic heating.

It is also increasingly unlikely that a Local Planning Authority (LPA) can be expected to appraise Applications which are substantially related to energy. It matters not whether that's a homeowner wanting a heat pump or an entire offshore wind farm. On which point, have a look at this announcement from North Devon Council on 19th Dec, who are grappling with a highly contentious planning application to bring ashore an electricity cable through an SSSI:

An LPA simply doesn't have the time or experience to handle applications on such a wide range of size and differing technologies.

Perhaps there needs to be a new approach whereby any Application which is substantially energy-based must be assessed by both the LPA and the regional RESP. They could then issue guidance under which the majority of householder HP Applications can be granted consent under Delegated Authority, regardless of whether the installation is to be undertaken by an MCS-accredited company, or is DIY.

I've recently submitted evidence to the Commons Select Committee on ESNZ, detailing thirteen reasons why current planning regulations are inadequate to accept/reject energy applications.
I can post these here if you wish.

We live in a democracy. Whilst Parliament seems to be in the mood to devolve energy planning and implementation to us, then the least we should do is to respond to the consultations and tell them what we require in order to achieve Net Zero.

I must say, the MCS020 seems to me quite a straightforward calculation as it is set out at present. It takes 3 minutes to complete. There is room for improvement and clarity on some elements but I can't see a case for simplification. Noise can be a serious issue and installers need to take time to properly assess it. I think at times calls for simplification are founded in a feeling that the test is s bit of a nuisance and frustrating to have to plan round rather than embracing it and avoiding placement where issues could occur. 

If it is the content/calculations that are flawed, that's one thing (if the DENSZ research is anything to go by, these need to be tightened), but anyone could do the calculation.

I do think that if another body other than MCS is able to certify then standards must be aligned & the bodies must be brought more into public accountability eg FoI etc. Overall MCS compliance is a requirement of the Town and Country Planning Act and that's the law *inserts picture of John Thaw in the Sweeney*.