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Air Source Heat Pump Policies – MCS Planning Standards

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(@elton)
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Posted by: @jamespa

That won't help op though, installation according to manufacturers spec wasn't a planning condition.

It is required under PD and I would assume the relevant element of needing to meet MCS standards carries over into any planning permission granted:

There is a requirement to meet MCS standards in the TCPA. MCS planning standards MCS020 states at 3a) that  the installation must meet MIS3005 (and if the installer is MCS registered [and its is a condition of the grant] they must fit according to manufactures spec as stated in MIS3005: 

"4.4.1 Heat pumps should be located according to the manufacturer’s instructions. For air source heat pumps, these will include consideration of factors that may detrimentally affect the performance of the heat pump system such as recirculation of chilled air."

 

There is one slight caveat though - no one is going to bother enforcing it, and the worst installers have learnt to install as a botch as no authority will bother to do anything about it.

 

 

... until a weight of issues reaches a critical mass and such issues become the next scandal leading to tainting of the heat pump rollout. Sad because its avoidable.

This post was modified 2 weeks ago by Elton

   
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(@elton)
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Looks like the PD consultation is out, including some HP elements:

Changes to various permitted development rights: consultation - GOV.UK (www.gov.uk)


   
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(@jamespa)
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Posted by: @elton

Posted by: @jamespa

That won't help op though, installation according to manufacturers spec wasn't a planning condition.

It is required under PD and I would assume the relevant element of needing to meet MCS standards carries over into any planning permission granted:

There is a requirement to meet MCS standards in the TCPA. MCS planning standards MCS020 states at 3a) that  the installation must meet MIS3005 (and if the installer is MCS registered [and its is a condition of the grant] they must fit according to manufactures spec as stated in MIS3005: 

"4.4.1 Heat pumps should be located according to the manufacturer’s instructions. For air source heat pumps, these will include consideration of factors that may detrimentally affect the performance of the heat pump system such as recirculation of chilled air."

 

There is one slight caveat though - no one is going to bother enforcing it, and the worst installers have learnt to install as a botch as no authority will bother to do anything about it.

 ... until a weight of issues reaches a critical mass and such issues become the next scandal leading to tainting of the heat pump rollout. Sad because its avoidable.

The PD rules apply only if the installation is under PD.  This one wasn't so the PD rules do not apply.  The only requirement is that it meets the planning conditions and installation according to manufacturers spec wasn't a planning condition and thus cannot be enforced by the LPA.

 


   
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(@jamespa)
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Posted by: @noburn

Personally I think the only thing that makes any sense is to define the equipment noise level.  Specifying the environment noise level is crazy.

The problem with this is that it doesnt take account of positioning/distance which matters.  its the effect on others that needs to be controlled and that depends on distance and positioning relative to other noise sensitive locations as well as the noise at the equipment itself.  So whilst this would be, in an ideal world,  desirable, its not currently technically feasible, nor is it likely to be technically feasible in the forseable future.

Posted by: @elton

The long and the short is that the heat pump should always be WELL below background noise levels at all times, not on a par or close. 

I fundamentally disagree

In many areas background is sufficiently low that it cant be heard inside.  At this point there is absolutely no need for heat pumps (or any other equipment that is used principally when people are indoors) to be below background.  CIEH and IOA (who presumably know about these things) recognise this in their recommendations and to impose such a spec would make it impossible for many to heat their homes.  Many oil boiler flues and some gas flues would not meet the requirement to be 'well below background' (yet dont cause a problem), and there are many other disturbances which are above background but not audible indoors (for example, in my area, birds).  

Its also incompatible with your suggestion above.

 

Posted by: @elton

Also that tonality needs to be accounted for

I could agree with that so long as the accounting is simple so it doesnt require an expensive expert to make the decision.  Bear in mind a heat pump is just a replacement for a gas boiler so needs ultimately to be as simple to install. 

Personally I think it could easily be made simple, the manufacturers could be required to do a test which defines a tonality penalty (or none).  Would probably need EU agreement to have sufficient clout, but that's just the sort of thing the EU would do.  Perhaps our government could try to persuade them.

 

Posted by: @elton

Interesting as Persephone and I are both suffering form the AExxxRXY Samsung models. From looking at product literature and the graphs within it, and from listening to it outside my bet is that the Samsungs (which I have come to thin are a bit are cheap'N'nasty) would be whacked quite hard if a tonlaity measure came in (as it should).

Thats interesting and why I could agree that a simple tonality measure could reasonably come in.

This post was modified 2 weeks ago 4 times by JamesPa

   
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(@jamespa)
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Posted by: @elton

Looks like the PD consultation is out, including some HP elements:

Changes to various permitted development rights: consultation - GOV.UK (www.gov.uk)

Thanks for flagging this, I was wondering when it might appear and was worried I had missed it.

I had a preliminary look, its sadly the normal Government consultation style - ie with loaded questions 'do you agree' rather than' what is your view on'.  So I think we can tell from the consultation what the plan is!

The art of writing consultation in a way which elicits a balanced response appears to have gone by the wayside, whether this is because the people who write them dont understand the concept of loaded questions, or whether its intentional, I don't know. 

 

This post was modified 2 weeks ago by JamesPa

   
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(@elton)
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On the 42db(A) figure, this document from 2012 outlines where it came from:

- see bottom of page 9. In essence, it has no basis in acoustic research & is merely a compromise position.

Fast forward to 2023 & the Welsh Government Phase 2 report on PD Executive Summary (page 5) https://www.gov.wales/sites/default/files/publications/2024-01/ashp-noise-and-permitted-development-rights-in-wales-phase-2-report.pdf - it lists some potential ideas for changes and then comes in at the end with a critical statement that prevents any weakening of regulations as... further work is needed to figure out what the level causing nuisance is.

Quote the summary ends on: " • Further work is required to determine if the current permitted noise target is adequate to deal with protection of quality of life, cumulative impacts of multiple units, tonality, directionality, intermittency and variation in noise generated over the seasons and at different heat loads; also to better understand and improve the public perception of noise from ASHPs through guidance and education."

So the level of nuisance has not yet been understood or established. The government/MCS can do away with arbitrary rules like 1m boundary and size, but their hands are tied in terms of the db(A) limit in that they cannot weaken it in any way from present (including flattening the steps) with any legitimacy. No policy maker can, in good faith, weaken limits until that is bottomed. It is too risky an approach and is indefensible as wouldn't be evidence-based policy making.

I would be very suprised if we see any weakening of limits - the evidence is not fully present yet to support the current level, let alone a new one (in fact what is there indicates potential issues and the need for [and benefit to rollout of] tightening regs).


   
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(@elton)
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Sorry James, I'm a bit rubbish at quoting so excuse the format.

The long and the short is that the heat pump should always be WELL below background noise levels at all times, not on a par or close. 

Reply:

I fundamentally disagree

In many areas background is sufficiently low that it cant be heard inside.  At this point there is absolutely no need for heat pumps (or any other equipment that is used principally when people are indoors) to be below background.  CIEH and IOA (who presumably know about these things) recognise this in their recommendations and to impose such a spec would make it impossible for many to heat their homes.  Many oil boiler flues and some gas flues would not meet the requirement to be 'well below background' (yet dont cause a problem), and there are many other disturbances which are above background but not audible indoors (for example, in my area, birds).  

Its also incompatible with your suggestion above.

 

I don't think this should be applied to boiler flues or oil boilers - these should be treated as traditional noise nuisances if noise becomes an issue. I do not agree there is comparability between the sounds. I think heat pumps should be subject to specific, distinct rules reflecting the research and evidence around the difference in the nature of the noise and its capacity to cause nuisance. And then you can also have vibration which as far as heating goes is pretty unique to heat pumps. Yes many forms of heating can be a nuisance, but on heat pump noise, [random but they say it well] Guernsey Council's planning advice note puts it well:

"The dominant frequencies within the noise are typically low frequencies (i.e. 50 – 200 Hertz (Hz)) which travel further and can potentially be heard as an annoying hum within buildings, particularly through the night."

I maintain heat pumps should be required to operate at levels beneath the background noise unless they are far enough from neighbouring properties not to cause issues. Could be that if tonality was factored in properly more equivalence to could be claimed between the noise levels - but it isn't.

 

 

 

 

This post was modified 2 weeks ago by Elton

   
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Toodles
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@elton Sorry, late on parade on this topic but that won’t stop me from putting in my 0.9pence worth! A special category for heat pumps is probably a good idea; there are a few special features about ASHP’s in particular that aren’t met so often with gas or oil burner boilers.

The tendency to run ‘24/7’ means that there is noise during times when other noises may die down and many people might be trying to sleep. As to any attempt to accept a level of sound or noise that is ‘no louder’ than ambient level - this could be a slippery slope; after all, any additional ‘noise’ however low level is additive - even if at levels regarded as ‘insignificant’ they are still adding to the overall blanket of noise pollution.

Cost is likely to be a significant factor that negates lowering noise levels from any device if pressure to do so is not strong enough. Perhaps research into using close field monitoring of the noise emanating from a heat pump so that antiphase sound might be produced and blended with the original to create noise reduction away from the pump creating a lower environmental impact should be invested in? Anyone know how to access defence-budget type amounts of money!!!??? Regards, Toodles.

Toodles, 76 years young and hoping to see 100 and make some ROI on my renewable energy investment!


   
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(@jamespa)
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I take it we all agree that our homes must be heated.  The fundamental problem is that there is no penalty free way to do so.

Burning wood is roughly carbon neutral, pretty quiet, but the particulate contamination kills people.

Burning oil or gas can be a bit noisy, but the climate change it causes will result in mass migration, hunger, political instability and likely war.

ASHPs are a bit more noisy than burning fossil fuels, much more climate friendly and ultimately climate neutral.

Resistance electric heating is far to expensive and requires infrastructure we are unable to build in a realistic time.

 

There is absolutely no logic in discriminating in favour of older technology on the basis that it is 'traditional'. Noise is noise, nuisance is nuisance and death is death no matter what the technology.  So we have to make choices between options all of which have a downside.

A heat pump installed so that it does not cause nuisance to others, albeit that it might make noise above background, is a reasonable choice given the options actually available.  The current planning rules are designed to achieve that.  Of course some installations will go wrong, just as gas boilers occasionally kill people from CO poisoning and gas explosions, and some people complain about their neighbours oil boiler flues.  We don't live in a perfect world and we need all to get over it.

It's sometimes worth imagining that technology was invented in the opposite order and asking, if it had been, would the 'traditional' technology stand a chance.  Phones with wires tied to a wall that you can only use at home?, Cars with thousands of parts that rely on explosions to propel them, emit noxious fumes, have a poor acceleration and which you can't fill up at home?  Heating that requires a special network of pipes across the country pumping an explosive gas into your home, which also kill you throwing CO poisoning and crash the global climate.  I don't think any these would stand much of a chance if it weren't for the familiarity bias that comes with them being the earlier technology!

This post was modified 2 weeks ago 7 times by JamesPa

   
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(@derek-m)
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@toodles

I still think that issuing ear plugs to all affected parties would be the cheaper option. 😋 

Joking apart, why do humans react to noise? It is probably part of our defense mechanism from cave man days. So if a heat pump is installed nearby, it is the 'new kid on the block' and we therefore become aware of its presence. Over time, when we discover that the heat pump did not creep round and attack us during the night, will its noise become accepted as part of our surroundings and filtered out?


   
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Toodles
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@derek-m Could the sound/noise of a heat pump be compared to a babbling brook, a roaring stream at flood levels, bird song, an ocean roar, a gale force wind? All natural sounds - some possibly detrimental to our safety. We probably know that the heat pump is unlikely to attack us or even sh*t on our garden but, it may drone away and keep us awake. Some like the sound of rain whilst they relax / sleep; even a high constant wind comforts some as long as they are not exposed to it. No, I don’t have a clue as to the answer! Regards, Toodles.

Toodles, 76 years young and hoping to see 100 and make some ROI on my renewable energy investment!


   
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(@jamespa)
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Posted by: @toodles

Some like the sound of rain whilst they relax / sleep; even a high constant wind comforts some as long as they are not exposed to it. 

Both keep me awake and should be outlawed.  And while we are at it let's revoke the second law of thermodynamics.

As I observed above, there is no perfect solution to domestic heating, but we need domestic heating.  Thus we have to make choices Discriminating in favour of 'traditional' technologies on the grounds of familiarity bias makes no sense.


   
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