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Air Source Heat Pump Policies – MCS Planning Standards

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(@persephone)
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I appreciate your thoughts on the following questions:

1- Who/which institution is responsible to enforce MCS Planning Standards? 

2- Who/which institution is responsible to enforce the requirements of Governmental funds for ASHPs? 


   
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(@derek-m)
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Two very good questions. When you find the answers please let us know. 🙄 

As far as I am aware MCS set standards, some of which may be questionable. They also provide accreditation to installers, I believe for a fee, though again I don't know for certain. I think that Mars interviewed the head of MCS quite some time ago, so that may be worth a view.

The major problem is that it would appear that no one seems to check that installers are actually following the standards set by MCS, and MCS seems very reluctant to help homeowners who get their systems installed by 'cowboys', even though they are accredited by MCS, as installers that is, not cowboys. 😋 

I have not really delved into who pays the BUS grant to whom, since I bought and installed my own Air to Air heat pump, which does not qualify for a grant.

 


   
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Mars
 Mars
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OK. This is not an easy question to answer, so I may be wrong, but this is my interpretation.

To start with, it's important to clarify a few terms and the context in which they're used:

MCS Planning Standards: MCS is national standard in the UK for the installation of microgeneration technologies such as solar panels, wind turbines and heat pumps. The MCS sets industry standards for microgeneration products and installers to ensure high-quality (cough, cough) installations and consumer protection.

Governmental funds for ASHPs (Air Source Heat Pumps): Governmental funds for ASHPs would likely refer to financial incentives or grants provided by a government to support the adoption of renewable energy technologies, including air source heat pumps. These incentives could be part of broader environmental, energy efficiency or climate change policies.

Given these definitions:

Enforcement of MCS Planning Standards: This is typically the responsibility of the organisation that oversees the MCS certification process. In the UK, the MCS is an industry-led and nationally recognised quality assurance scheme, supported by the Department for Business, Energy & Industrial Strategy (BEIS). Enforcement of these standards is usually carried out through the MCS's framework, which includes accreditation of installers and certification of products (see my article in Chinese heat pumps). Local authorities may also play a role in enforcement, particularly regarding planning permissions and adherence to building regulations that align with MCS standards.

Enforcement of the requirements of Governmental funds for ASHPs: This responsibility generally falls to the governmental department or agency that administers the fund or grant scheme. In the UK, these schemes are administered by various departments of the government, such as BEIS. These bodies are responsible for setting the criteria for funding, overseeing the application process and ensuring compliance with the requirements for receiving support.

It’s a complex system that runs behind the scenes. Good luck trying to fight it in light, I’m assuming, of your neighbour’s noisy heat pump, @persephone. The good news, for you, is that there are rumblings that MCS are under immense pressure in light of failing in their role.

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(@persephone)
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I have some questions about assessing the Noise Impact of ASHPs that have already been installed (a) in compliance with MCS Planning Standards and (b) not in compliance with MCS Planning Standards: 

1- Are there any specific legislations/policies for assessing the Noise Impact of ASHPs? If yes, what are they?

2- Can local councils make their own mix-and-match criteria for assessing the noise impact of ASHPs? For instance, only assessing the high frequency, but ignoring the vibration. Or assessing the general noise, but ignoring the noise of the defrost cycle? 

 


   
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Mars
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@persephone again, this is my interpretation because there are no clear-cut answers to most things relating to heat pumps post-installation

Legislation/Policies:

For MCS-compliant ASHPs

  • BS 4142:2014+A1:2019 "Method for rating and assessing industrial and commercial sound" is the standard reference for noise assessment in the UK.
  • MCS 020 "Planning Standard for Microgeneration Installations" specifies noise assessment procedures for MCS-certified air source heat pumps, aiming to achieve a maximum noise level of 42dB at neighbouring properties.

For non-MCS-compliant ASHPs:

  • BS 4142:2014+A1:2019 still applies as a general standard.
  • Local council planning regulations and environmental noise nuisance laws might be relevant, depending on the specific situation. This will vary from council to council.

Local council criteria

  • While BS 4142 and MCS 020 provide frameworks, local councils have some flexibility in interpreting and applying them.
  • Councils are unlikely to completely disregard specific elements like high frequency or defrost noise as these can contribute significantly to annoyance.

Not sure if that helps. Have you measure the noise of your neighbour's heat pump?

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(@persephone)
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@editor Thank you for the info. I have a lot of recordings, but they are of no value to my local council.

My council totally disregarded the defrost cycle noise. Here is 'condition' imposed by the Local Review Body for my neighbour's retrospective application:  

"Within six weeks of the decision being issued, an 'at-source' noise survey at the Air Source Heat Pump shall be undertaken and submitted to the Council for approval to demonstrate compliance with the predicted sound pressure levels at this source and the predicted sound pressure levels 1m from the first-floor facade of the adjacent residential property to the west [my house]". 

The short-term noise assessment was carried out "during a weekday daytime period" in June. The Environmental Health officer and the acoustic engineer who was employed by my neighbour agreed on the followings: 

- The ASHP should not need to undertake a defrost cycle at this time of year, due to the relatively warm ambient air temperatures.
- For this reason, sound level measurements do not need to be made during the defrost cycle. ... etc. 

If anyone is interested, I can share the assessment (it is a public document). The assessment also predicts the NR level at my house, but the prediction is totally wrong. I raised the issues related to the assessment to EH and Planning Services, but they state that they just  'assume' the assessment is correct.  


   
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Abernyte
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Posted by: @persephone

My council totally disregarded the defrost cycle noise

What defrost cycle noise? My Ecodan is silent and with no fan activity during defrost, apart from the water dripping out the bottom. Are others different?

 


   
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(@jamespa)
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@persephone  Im sorry to hear you are having your problems.  My understanding of the position is as follows:

 

Posted by: @editor

MCS Planning Standards: MCS is national standard in the UK for the installation of microgeneration technologies such as solar panels, wind turbines and heat pumps. The MCS sets industry standards for microgeneration products and installers to ensure high-quality (cough, cough) installations and consumer protection.

Governmental funds for ASHPs (Air Source Heat Pumps): Governmental funds for ASHPs would likely refer to financial incentives or grants provided by a government to support the adoption of renewable energy technologies, including air source heat pumps. These incentives could be part of broader environmental, energy efficiency or climate change policies.

Given these definitions:

Enforcement of MCS Planning Standards: This is typically the responsibility of the organisation that oversees the MCS certification process. In the UK, the MCS is an industry-led and nationally recognised quality assurance scheme, supported by the Department for Business, Energy & Industrial Strategy (BEIS). Enforcement of these standards is usually carried out through the MCS's framework, which includes accreditation of installers and certification of products (see my article in Chinese heat pumps). Local authorities may also play a role in enforcement, particularly regarding planning permissions and adherence to building regulations that align with MCS standards.

I dont see how MCS is responsible for enforcing MCS planning standards.  MCS is responsible for accrediting installers.  It might take action against the installer if they don't do things correctly, but I cannot see how they would or could take action against the householder who had been advised by the installer.  

Responsibility for enforcing planning requirements lies with the local planning authority (District/Borough Council or unitary).

The householder is responsible for complying for planning legislation, and may well have a case against the installer if they have been wrongly advised.  As you weren't party to the contract you don't have a case against the installer.

Posted by: @editor

Enforcement of the requirements of Governmental funds for ASHPs: This responsibility generally falls to the governmental department or agency that administers the fund or grant scheme. In the UK, these schemes are administered by various departments of the government, such as BEIS. These bodies are responsible for setting the criteria for funding, overseeing the application process and ensuring compliance with the requirements for receiving support.

Agree

Posted by: @persephone

My council totally disregarded the defrost cycle noise. Here is 'condition' imposed by the Local Review Body for my neighbour's retrospective application:  

"Within six weeks of the decision being issued, an 'at-source' noise survey at the Air Source Heat Pump shall be undertaken and submitted to the Council for approval to demonstrate compliance with the predicted sound pressure levels at this source and the predicted sound pressure levels 1m from the first-floor facade of the adjacent residential property to the west [my house]". 

The Council is entitled to disregard the defrost cycle if it deems that it is not of significance, fundamentally it is for the Council to interpret a planning condition that it has imposed.  The only recourse you might have is a JR against the Council challenging its interpretation of its own planning condition.  Good luck with that one!

(Incidentally I cant see how the last part of the condition is enforceable, since your neighbour has no right of access to your property to make the required measurement.  I guess the LPA will take the (reasonable) view that, if you care you will grant access and if you don't care it doesn't matter!)

Fundamentally you would need either to convince the Planning Department of your LPA to enforce, which from what you say seems unlikely, or convince the Environmental health Department (usually the same Council, but a different department) that the noise amounted to statutory nuisance (which would generally be a more severe hurdle).  Alternatively you can sue your neighbour for nuisance privately, but the test of nuisance is the same as that witch the local authority apply.

Posted by: @persephone

If anyone is interested, I can share the assessment (it is a public document). The assessment also predicts the NR level at my house, but the prediction is totally wrong

Are you able to prove its wrong and if so by how much.

As I say Im sorry to hear that you are having these problems, if you can give us some figures (noise levels) it would help.

This post was modified 3 weeks ago 4 times by JamesPa

   
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Mars
 Mars
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Posted by: @abernyte

Posted by: @persephone

My council totally disregarded the defrost cycle noise

What defrost cycle noise? My Ecodan is silent and with no fan activity during defrost, apart from the water dripping out the bottom. Are others different?

Our heat pump is also a lot quieter when it's in defrost because the fan goes off. We do have an audible clicking sound that comes from within the unit somewhere, but it's not very loud and wouldn't cause any annoyance. 

@persephone can you please explain why you think it's the defrost cycle that's making additional noise?

 

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Mars
 Mars
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Posted by: @persephone

If anyone is interested, I can share the assessment (it is a public document). The assessment also predicts the NR level at my house, but the prediction is totally wrong. I raised the issues related to the assessment to EH and Planning Services, but they state that they just  'assume' the assessment is correct.  

Yes, please share it.

Buy Bodge Buster – Homeowner Air Source Heat Pump Installation Guide: https://amzn.to/3NVndlU

Follow our sustainability journey at My Home Farm: https://myhomefarm.co.uk


   
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(@persephone)
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@jamespa I can prove that, based on the assessment, the predicted sound pressure levels 1m from my house is wrongly calculated by the assessor. I have asked a very reputable acoustic company to review the assessment, but so far they have refused to do it.  

@editor @jamespa My main issue, however, is the 'condition'. Apparently, the 'predicted sound pressure levels' is 42dBA. But what is the 42dBA? Is it a criterion specific to MCS, a PDR criterion, or just a general noise/nuisance criterion? If 42dBA is an MCS criterion or a PDR one, can it be used as a condition for an ASHP that needed a planning permission because it is non-compliant with MCS and is not a permitted development? 🤔 


   
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(@persephone)
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@editor I will send both assessments to you in case any redaction is necessary. But they are available on my local council planning portal.


   
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