Posted by: @jamespa

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Can I cross-post your proposal (with credit or without as you prefer) to buildhub.  There are some reactionaries on there who seem to criticise everything (including MCS) but refuse to be positive about any suggestion for change.  Actually your package seems a good one and it would be interesting to get their reactions.  Only if you consent of course!

hi james - if you're referring to my list, then yes. By putting it on here I'm effectively making it public and declaring those to be my opinions / thoughts / proposals "if I ran things", so no issues with you referring to / cross-posting it.

Posted by: @chickenbig

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The Boiler Upgrade Scheme gatekeeping is understandable, but has resulted in poor uptake and some poor quality installations by chancers who know how to use something like easy-MCS. The idea of getting a gas-safe person to verify the de-installation is novel, provided the BUS grant scheme checks building control for a subsequent re-installation of a gas boiler.

what's easy-MCS, I'm not familiar with that?

Posted by: @chickenbig

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At the risk of being pedantic, the zero rated VAT on energy saving measures (link) does not mandate the use of MCS. I am considering putting materials and subcontracting (heat pump and IWI and suspended floor insulation) through my own VAT registered limited company, although for a 2k saving all the paperwork may turn out to be a bit of a chore. But for me the principle is important!

I did read those Vat guidelines when I was working out what to do. I considered putting my heat pump purchase through my ltd company as well, and then selling it to myself personally... but it just looked like too much hassle to have to register another line of business, figure out what I might have to do for it to be valid not to charge myself VAT,  get my accountants to sort the right vat rate and any changes it'd mean to the rest of my business (I'm on flat rate at the mo), does my insurance cover it (no).... etc. anyway, not everyone has their own ltd!

to explain a little more, my thoughts on having a gas-safe person involved were around who is suitable for the job and for the fraud prevention:

• they are obviously the person to do the actual decomm work
• able to validate that the boiler is in use, and has been so for (time T) whatever T is deemed to be reasonable. Not a scrapped boiler that was re-installed last week.
• if they fraudulently verify , the sanction would be they'd lose their Gas-Safe, which is their livelihood.
• they'd get paid a suitable fee for the admin aspect of it if that was all they were doing.
• they might be the same person as the aforementioned "any local heating contractor" doing the HP install so potentially bundle it all in.
• as you say a BC check say 12 months later for another gas install would be sensible.

for me the key bit that is not obvious to me is who are  the umbrella organisation providing training and support to make sure these installs are done "well" - whatever "well" is deemed to be? I don't know who that is or how it'd be run. we all know that from this forum, installed by an MCS company does not always equal well installed (of course sometimes it does, but we need better than that for this to work), and MCS has no teeth in terms of getting installs remediated from "bad" to "good". So there needs to be another solution to that. Are there setups that already work this way in other industries, does anyone know?

Posted by: @jamespa

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Permitted development rules modified so that the noise condition set out in MCS-020 applies but not the conditions which require the installation and design to be done by an MCS registered contractor to qualify for PD

I can't see where the permitted development rules insist on using an MCS registered contractor. The legislation (link) G1 states

Development is not permitted by Class G unless the air source heat pump complies with the MCS Planning Standards or equivalent standards.

which at the planning portal (link) is clarified to mean

Development is permitted only if the air source heat pump installation complies with the Microgeneration Certification Scheme Planning Standards (MCS 020) or equivalent standards.

Are you saying that the MCS-020 can only be followed by an MCS Contractor?

"for me the key bit that is not obvious to me is who are  the umbrella organisation providing training and support to make sure these installs are done "well" - whatever "well" is deemed to be? I don't know who that is or how it'd be run. we all know that from this forum, installed by an MCS company does not (always) equal well installed, and MCS has no teeth in terms of getting installs remediated from "bad" to "good". So there needs to be another solution to that. Are there setups that already work this way in other industries, does anyone know?"

As you say this is the key bit but also the one which risks (guarantees?) reproducing the problems with MCS, because it creates an elite monopoly or pseudo-monopoly.  To me the only thing in the list which should depend on this is the grant, nothing else. And we should be working towards eliminating the need for the grant.  Only then can the market develop freely, true competition be introduced and the plumber on every street corner get engaged.  The gas boiler market seems to function quite well with only essential safety regulation, the HP market has to seek the same.

I don't honestly know of a comparable situation which works well.  My experience of both plumbing and electricals, both of which are regulated by sector bodies, is that there are individuals in both who use the 'sector rules' as a means to try to bambozzle the customer into unnecessary work.  Once rules become as rigid as MCS and attempt to do a 'good' job not just a safe job, this becomes even easier.  Fortunately there is enough competition in the general plumbing and electrical market that the customer can go elsewhere.

My gut feel is that relying on local plumbers who value their reputation to do a good job, with minimal or no regulation beyond that necessary for safety, is the way forward.  I grant, however, that this is the most difficult area which is largely why I favour finding ways to eliminate the need for the grant as soon as is practically possible.

Sorry thats not really an answer, just some thoughts.

Posted by: @iancalderbank

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what's easy-MCS

See https://www.easy-mcs.com

The easy way to achieve MCS certification

One hopes easy and good are correlated!

@chickenbig As you say the PD rules say that 'Development is not permitted by Class G unless the air source heat pump complies with the MCS Planning Standards or equivalent standards.'

So we need to look to the definition of 'The MCS Planning Standards' to find out what that means.

'MCS Planning Standards are defined in MCS-020 as follows

"3.1 The MCS Planning Standard for air source heat pumps is as follows:

a) The air source heat pump product shall be certified in accordance with MCS 007 

b) The air source heat pump shall be installed by an MCS contractor in accordance with MIS3005

c) The installation shall be carried out in compliance with the calculation procedure contained in Table 2.  MCS Contractors must complete the 'results/notes' column in Table 2 for each step of the calculation procedure to show how it has been followed."

(c), which is the noise criterion, is the one that is rightly part of planning law, but the second part requires the assessment is completed by an MCS contractor

(b) requires the installation to be done by an MCS contractor, and MIS 3005 requires that an MCS installer must install to a design done by am MCS contractor.

So yes, I am saying that the condition set out in the PD rules can only be met if both installation and design is done by an MCS contractor.

The worrying thing is that its MCS that wrote this in, because they wrote the definition of 'The MCS Planning Standards'

@jamespa the way I read the whole PD thing was that if I install in such a way that complies with the noise, space, distance etc , I'm good. So I installed.

Posted by: @jamespa

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As you say this is the key bit but also the one which risks (guarantees?) reproducing the problems with MCS, because it creates an elite monopoly or pseudo-monopoly.  To me the only thing in the list which should depend on this is the grant, nothing else. And we should be working towards eliminating the need for the grant.  Only then can the market develop freely, true competition be introduced and the plumber on every street corner get engaged.  The gas boiler market seems to function quite well with only essential safety regulation, the HP market has to seek the same.

the difference is that with a gas boiler, the biggest issue is the safety risk. Done wrong, the house blows up and people die. but with the safety bit done right (and obviously properly specified/installed/working components), its pretty much impossible for the house not to be warm. whereas with HP, there's no comparable safety issue (hence why us DIY'ers can get stuck in), but it is very much possible for the house not to be warm or cost a fortune to run.

I'd have much more been likely to contract with the local plumber to do this for me if there'd been a way for them to backed by some of the veteran heat pump installers who live on this forum and other similar places (and get a BUS and not pay VAT).

So my point is doesn't have to be legally enforced - just there as a warranty assurance that it's going to be done right, that most joe publics would be happy to pay something extra for. however I suspect there'd probably be something of a People's Popular Front of Judea thing as different orgs would set themselves up as "design + warranty" providers, disagreeing about the methods 🙁

Posted by: @iancalderbank

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the way I read the whole PD thing was that if I install in such a way that complies with the noise, space, distance etc , I'm good. So I installed.

yes and I think many others would too (I have considered it and my LPA have, off the record, suggested I could probably get away with it). 

But your reading is, IMHO, self-evidently wrong, and we should not be forced to take this risk.  Furthermore plumbers, not MCS registered, might be put off from being associated with an unlawful installation. 

[userid="4643" data-postid="18914"]

the difference is that with a gas boiler, the biggest issue is the safety risk.

Quite, so less regulation not more is required!

Posted by: @iancalderbank

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So my point is doesn't have to be legally enforced - just there as a warranty assurance that it's going to be done right, that most joe publics would be happy to pay something extra for. however I suspect there'd probably be something of a People's Popular Front of Judea thing as different orgs would set themselves up as "design + warranty" providers, disagreeing about the methods

I think a warranty based approach would potentially be good, rather than a standards body.  Of course the risk is that the insurer then becomes the standards body!  The key here might be to find a way to write the rules that it is bundled automatically with whatever public liability/product indemnity insurance plumbers have, so its absorbed into their general insurance rather than being heat pump specific.[quote data-

Posted by: @jamespa

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So yes, I am saying that the condition set out in the PD rules can only be met if both installation and design is done by an MCS contractor.

*sigh* So the MCS Planning Standards also governs the installation; at the very least this is a (deliberately, or just became that way though various edits) misnamed standard. The installation aspect seems more like something in building control's sphere.

Posted by: @jamespa

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yes and I think many others would too (I have considered it and my LPA have, off the record, suggested I could probably get away with it). 

I'm not sure I like this informal permission model, not when a complaint could result in my source of heat being taken away!

Posted by: @chickenbig

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Posted by: @jamespa

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So yes, I am saying that the condition set out in the PD rules can only be met if both installation and design is done by an MCS contractor.

*sigh* So the MCS Planning Standards also governs the installation; at the very least this is a (deliberately, or just became that way though various edits) misnamed standard. The installation aspect seems more like something in building control's sphere.

Posted by: @jamespa

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yes and I think many others would too (I have considered it and my LPA have, off the record, suggested I could probably get away with it). 

I'm not sure I like this informal permission model, not when a complaint could result in my source of heat being taken away!

 

Quite so.  I suspect it might have been deliberate on the part of MCS (a private monopoly) when they wrote the definition of 'the MCS Planning Standards'.  Whether or not it was the government's intent I don't know, quite plausibly not.  My strong suspicion is that this part of PD was intended to be about noise and noise only, as MCS020 essentially deals with noise.  The installation does not fit planning rules at all, as you say this is part of building regs (if its needed) not part of planning.  

I agree an informal permission model is wholly unsatisfactory and also potentially has downstream issues on sale of house.  It needs to change.

Posted by: @jamespa

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@bontwoody 

 

1. I have yet to find a manufacturer that quotes SCOP at 65C.  What I did was create a model based on published cop at various flow temps and outdoor temperatures, weather compensation, and the annual distribution of outdoor temperatures (in the South East).  I don't necessarily trust the absolute figures, but the degradation (provided you run WC) between running at 45 and running at 65 whilst large, is no so large that the latter should be rules out. 

Bear in mind also that, in talking SCOP, we are dealing with the reciprocal of what really matters (ie energy consumption).  This gives a distorted impression.  The difference between a SCOP of 1 and a SCOP of 3 really matters, its a tripling of a high energy use.  But the difference between a SCOP of 3 and a SCOP of 5 doesn't matter anything like as much, its only a 40% increase on a rather small energy use (and only 13% of the consumption at a SCOP of 1).  

2. Yes, but that's a separate problem.  We know we MUST go electric so those responsible for this need to solve it.  Reducing the SCOP of the deployed solution from say 4 to 3 isn't likely to be the dominant factor (see above), its the switch from gas to electricity.  A proposed alternative to heat pumps is hydrogen, that takes 4* the electricity of a heat pump with a SCOP of 3.

I think the problem is largely one of distribution during peaks, not so much generation.  This may ease somewhat as batteries and electric cars smooth out the load.  But either way its a totally separate problem which must be solved else we are toast.

3. With the current state of technology I think you may well be right.   As heat pumps get more efficient at higher temps (they are no where near the limits of the physics) this will likely change.  We have to start somewhere.

Whilst I agree that the present systems need vast improvement to encourage uptake of heat pumps, your idea of HT heat pumps I feel will have even bigger problems when people become aware of the running costs.

Installing better insulation and larger heat emitters may discourage some, but once done they will reap the benefits for years to come.

Your assessment of SCOP in your spreadsheet is far from real world situations. Below are some details of SCOP's that can be expected. The password for the file is midea2020