A Call for Fair and Legal Heat Pump Installations in the UK
Please consider responding to this consultation if you believe that the installation of heat pumps should be legalised in the UK.
- The Department of Energy and Sustainable Net Zero (DESNZ) authorised the Microgeneration Certification Scheme (MCS) to establish the regulations for Permitted Development (MCS 20).
- MCS has stipulated in their standard that heat pumps must be installed by MCS-certified contractors to comply with legal requirements.
- This regulation effectively makes it illegal for anyone to install a heat pump without obtaining planning permission.
DESNZ initially intended for MCS to develop "a noise standard." Under this guideline, if heat pumps were sufficiently small and quiet, they could be installed under Permitted Development. However, MCS seems determined to be the sole standard authority, restricting heat pump installation exclusively to MCS members. They have added extra requirements to the noise standard, effectively barring non-MCS installers from utilizing Permitted Development.
This approach is problematic. Planning Permission typically concerns visual and noise impact, not the qualifications of the installer. The appearance and sound output are what matter, not who installs the equipment. The Planning Rules for heat pumps should reflect this principle. MCS needs to eliminate the inadvertent requirement that effectively restricts Permitted Development to MCS members.
Your input in the consultation is crucial to clarify this situation. It will help determine whether this is an unintentional error or a deliberate attempt by MCS to monopolise heat pump installations.
Unfortunately, the MCS consultation form does not provide an option to suggest simplifications or streamlining of this process. Therefore, it's recommended to email your response directly to MCS, requesting confirmation that your input is acknowledged, despite not using the official form.
Addressing this issue is vital. If the regulation is intentionally restrictive, it's no longer a mere oversight but an abuse of the authority granted to MCS by the government.
Buy a copy of the The Ultimate Guide to Heat Pumps
Subscribe and follow our Homeowners’ Q&A heat pump podcast
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?
My octopus signup link https://share.octopus.energy/ebony-deer-230
210m2 house, Samsung 16kw Gen6 ASHP Self installed: Single circulation loop , PWM modulating pump.
My public ASHP stats: https://heatpumpmonitor.org/system/view?id=45
11.9kWp of PV
41kWh of Battery storage (3x Powerwall 2)
2x BEVs
@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.
Buy a copy of the The Ultimate Guide to Heat Pumps
Subscribe and follow our Homeowners’ Q&A heat pump podcast
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.
Save energy... recycle electrons!
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*.
- 26 Forums
- 2,208 Topics
- 48.7 K Posts
- 33 Online
- 5,868 Members
Join Us!
Podcast Picks
Latest Posts
-
RE: Inventor (Midea) Heat Pump short cycling advice
I installed the 80L tank (volumizer) things got better ...
By immunity , 1 hour ago
-
RE: Mitsubishi Ecodan F8 error
I absolutely love this. This is the quintessential heat...
By Mars , 8 hours ago
-
RE: Testing new controls/monitoring for Midea Clone ASHP
@papahuhu at the end of the day if you are happy with h...
By benson , 13 hours ago
-
RE: Can you recommend a Mitsubishi service engineer in the Rochdale area?
@dgclimatecontrol We'll all need annual servicing. How...
By Suzy-shadow , 14 hours ago
-
RE: Renewables & Heat Pumps in the News
@transparent I’ve understood your point now. The point ...
By Judith , 14 hours ago
-
RE: Octopus tariffs - a quick comparison
Does indeed need checking, @tim441. Neither Homely ...
By Majordennisbloodnok , 14 hours ago
-
RE: How not to install a heat pump
Delighted to hear that the buffer has been replumbed as...
By JamesPa , 15 hours ago
-
-
RE: Daikin 9kW to 8kW Swap Offer from Octopus
Yes but 9kW is similarly the 16kW derated. So 8kW subs...
By JamesPa , 17 hours ago
-
Actually, there's a rather greater degree of cattle-her...
By Majordennisbloodnok , 17 hours ago
-
RE: The Hidden Secret to a Successful Heat Pump: Pipe Size Matters
@davidnolan22 So far as I can tell from the 'other p...
By JamesPa , 21 hours ago
-
RE: 5 Star Service from Havenwise
I keep getting havenwise ads on my Facebook feed, so cl...
By benson , 23 hours ago
-
Automation options to maximuse efficiency & ToU tariffs
I started a conversation with ChatGPT. What automation...
By Tim441 , 1 day ago
-
RE: 4 Year Ongoing Heat Pump Battle With Poor Heat Pump Installation
@jamespa Oh, I know some that are good and some not so....
By ASHP-BOBBA , 1 day ago
-
RE: Samsung Heat pump with Yonos Pico circulating pump running all the time
I don't know how many pumps you have but I guess it's o...
By JamesPa , 1 day ago
-
RE: Help me keep the faith with my air source heat pump installation
That's just human nature unfortunately, not special to ...
By JamesPa , 1 day ago
-
@bontwoody how long has it been now since you started t...
By Mars , 2 days ago
-
RE: Bosch CS5800i 5kW - Experience So Far
Yes, over the last few days I've been keeping a very cl...
By Steelbadger , 2 days ago
-
Absolutely. I am one of those members and I most certai...
By Majordennisbloodnok , 2 days ago