JamesPa

The current condition says used not capable. So nothing in the current condition inhibits installing, under PD, ASHPs which are capable of cooling provided that they are not used for cooling. There is a very good reason for retaining the existing wording: A HP used solely for heating is only used when its cold, and most people (in particular the neighbours) are inside with windows closed. So the MCS-020 fixed sound constraint (sound pressure <= -37dBA at the assessment points), which is readily calculated by anyone, is also justifiable even if the background noise is lower than this value, because -37dBA will be inaudible inside. As soon as you permit cooling then you have to assume that the unit will be used when windows are open and people outside. At this point background level needs to be considered if the HP is not to cause nuisance, in which case you introduce the need for a house-specific assessment, requiring a sound consultant and additional expense which burdens the installation of HPs for heating unnecessarily. Seems like a good idea (although its arguably implicit in proposal (3).) Correct, nowt, hence the need to relax the rules as set out in proposals 1-4 Yes but... It does not permit the customer to separate design and installation, the customer must contract through a single MCS contractor (who may subcontract to another MCS contractor). So I cant, for example, go to a Heat Geek to do a more intelligent design than MCS mandates, and then go to my local plumber to implement it, following the general practice in the building industry whereby architects and builders are separately contracted by the customer. The closed shop is maintained in the 'split' MCS rules. The above proposals break the MCS stranglehold. At that point it really doesn't matter what MCS does with training, however 'bloody silly' it is. They will then have to respond to competition which, today, doesn't exist.

I think you have taken that out of context. I made this comment in response to a post which was challenging the assertion that it would be possible to calculate heating load and thus size of ashp needed from annual energy usage, and that the result would almost certainly be much more accurate than the current method. The challenger was on oil, quoted his annual oil consumption, and asserted that it was not possible to calculate ashp size from this. In responding to the post I said you could, and then remarked that, as oil ch is a minority in this country, it's not the priority in the grand scheme of things. I was not saying it doesn't matter, it does. Sorry if that confused.

Unlikely to be running 'flat out' in summer because the OAT is much higher so neither the fan wont have to try anything like as hard, and anyway its for a couple of hours only. The current rule is a good 'balance so far as I can see, anything which involves determination of ambient is just another barrier. Installation of a noisy flue from a gas or oil boiler is unconditionally PD.

I think the problem with this is that it muddies the water on the noise constraint. A HP used solely for heating is only used when its cold, and most people (in particular the neighbours) are inside with windows closed. So the MCS-020 fixed sound constraint (sound pressure <= -37dBA at the assessment points), which is readily calculated by anyone, is also justifiable even if the background noise is lower than this value, because -37dBA will be inaudible inside. As soon as you permit cooling then you have to assume that the unit will be used when windows are open and people outside. At this point background level needs to be considered if the HP is not to cause nuisance, in which case you introduce the need for a house-specific assessment, requiring a sound consultant and additional expense which burdens the installation of HPs for heating unnecessarily.

There seems to be little material dissent that the above package of measures would be a good set to open up the market in the way that is necessary to achieve the volume needed. Before we 'bank' these however and move on, Id just like to ask a couple of questions Is there anything else in the Permitted development constraints that needs to change. Currently they read (summarised) No more than 1 ASHP - which we are proposing should be changed to 2 - see above The development must comply with MCS planning standards or applicable standards - which we are proposing should be changed - see above and then: a. the volume of the air source heat pump’s outdoor compressor unit (including any housing) must not exceed 0.6 cubic metres; b. the air source heat pump must not be be installed within 1 metre of the boundary c. the air source heat pump must not be installed on a pitched roof; d. the air source heat pump must not be installed on a flat roof where it would be within 1 metre of the external edge of that roof; e. the air source heat pump would be installed on a site designated as a scheduled monument; f. the air source heat pump would be installed on a building or on land within the curtilage of the dwellinghouse or the block of flats if the dwellinghouse or the block of flats is a listed building; g. in the case of land within a conservation area or which is a World Heritage Site the air source heat pump must not be installed on a wall or a roof which fronts a highway or be installed so that it is nearer to any highway which bounds the curtilage than the part of the dwellinghouse or block of flats which is nearest to that highway h. in the case of land, other than land within a conservation area or which is a World Heritage Site, the air source heat pump must not be installed on a wall of a dwellinghouse or block of flats if that wall fronts a highway the air source heat pump would be installed on any part of that wall which is above the level of the ground floor storey. i. the air source heat pump must be used solely for heating purposes; j.the air source heat pump must, so far as practicable, be sited so as to minimise its effect on the external appearance of the building and the amenity of the area; To me the ones which may need modifying are (a) should this be per unit if there are 2 units, or just bigger? (b) is this necessary at all given the sound constraint? (d) I presume this is a H&S requirement, but it rather depends on which way it is facing. Is this constraint really needed? I think (i) can stay, as it says 'used'. So an ASHP which is capable of being used for heating and cooling but which in fact is used only for heating is PD. Obviously this is nigh on unenforceable, but it seems to me that the existing wording is not materially detrimental to the cause of mass roll out for heating. Also, part of 3 'Support reduced to £1K if A2A installed as a part-replacement (conditions, and whether a later full replacement attracts a grant, to be defined' and 4. - No Vat on HP at purchase - would appear to apply to aircon used for cooling alone. Is there a way to prevent this potential abuse? Comments please.

I fear that getting a grant for self install with no professional body involved may be a step too far, if only because there is nobody who loses their livelihood by defrauding it and the entire industry will object. The vat concession seems to me achievable, because it's auditiable, subsidies to DIY installs probably not. Politics is the art if the possible!

Without a doubt. But @markocosic tells us that the industry hates MCS. The current government is fundamentally anti regulation and pro free market. Furthermore we were told that MCS was invented to convince the EU we had a qualification scheme, and the current government is also desperate to find any benefit from 'Brexit freedoms.' So if this is all true then there is lots in our favour. Who can we influence and how?

You can tell you are 'lakelandfolk'!

I believe you are correct Agree with the second point, so any concession would be on the hp and controller only. Its still worth perhaps 600-1000 though. Probably true, although it's possibly hassle which deters one man bands (who are exactly the sort of people we don't want to deter because some can be very good, very intelligent and think out of the box). Perhaps we need opinions from some of them. Also VAT relief on sales helps the DiY market. However I do grant that this us the least important of the measures and, if it were contentious/problematic the first to drop.

I think its fair to say that a consensus has emerged on this thread (with a few exceptions of course) that, if we are to achieve the mass roll out of heat pumps that is necessary to achieve our climate change goals, changes must be made in the regulatory regime, in the installation industry and in the ‘toolbox’ with which the installation industry works. The essential background is that today we install about 1.6M gas boilers each year of which 1.4M are retrofits. Each gas boiler installed is an opportunity lost. In 2022 we installed about 60,000 heat pumps. The UK is 20th on the eurpoean league table of heat pumps per person. (https://www.theecoexperts.co.uk/heat-pumps/top-countries). To achieve mass roll out it seems also to be generally agreed that the market needs to be opened up beyond the special purpose fly-by-night companies that have grown up to harvest the grant, don’t do a particularly good job, don’t have a roadmap to mass adoption and, through MCS, are stifling innovation and cost-effective system engineering. Furthermore they are structured for, and probably quite happy with, low volume-high price. Arguably this means opening it up to local plumbers and electricians, who today are excluded from the market, but certainly it means opening it up. Some other work force changes may be needed as well, discussed above. So in this post Im going to try to summarise the regulatory changes that it has been suggested are needed, and invite constructive comments. Engineering/workforce changes will be summarised separately The following was suggested by @markocosic · Kill the MCS stranglehold. That eliminates the fly-by-night grant chasers AND a good chunk of non value add tasks. You keep the requirements (e.g. the technical requirements with regards noise for permitted development) but make it the job of planners to enforce planning conditions (e.g. please prove it's adequately quiet, where here are the requirements lifted from the old MCS standards, and if you meet them them it's deemed fine, but you don't need to partake in the rest of the MCS charade) · Relax a few planning conditions too. They're asking for units to be too small. It should be permissible to have both a heat pump and an air conditioner. There shouldn't be stupid restrictions on siting R290 propane units near to doorways whilst it's still ok to keep two 15 kg propane cylinders inside your house. · Take a chill pill. AC in cars is ubiquitous. Let people do AC in houses more easily. Don't mandate that in order to receive grant funding the heat pump must deliver heat AND hot water. Chop the available grant to £1k and apply the condition that it's a packaged/tested solution with a sCOP of 5 or above. It's pish easy to install A2A units in this ball park. They work. People will rave about them. In a related forum, the following package of liberalisation measures was proposed, aimed also largely at killing the MCS stranglehold · No Vat on HP at purchase - regardless who/where/how. It really got on my wick that they announced that and then there's the "oh yeah you only get zero vat as part of an MCS install...grr..." · BUS if Boiler swapped for HP - for all . regardless of by who or how. Boiler removal part to be by a GasSafe engineer who signs off that its was previously in service and this audited against premises recent gas bills and boiler servicing bills to prevent fraud on the BUS. · Additional grant support above and beyond BUS for low-income people (means tested) to genuinely get the install price down to same as gas for them. · Grant support for electricity price for HP use to be same as gas to get the run cost equal or better. Requiring separate input metering prior to any structural changes in the market like moving the green levy (if ever...) · any qualified plumbing and heating contractor to do the work · an umbrella organisation providing support and advice to those heating contractors , with their decision making as to what system design and HP type to use. and providing a warranty (And access to swat team of Seasoned Veterans to troubleshoot) if there are performance issues. Pulling these together I offer up the following combined strawman: 1. Permitted Development rules in relation to air source heat pumps amended to remove all reference to MCS. The noise condition only in MCS-020 to be incorporated into the PD rules (without reference to the spreadsheet being completed by an MCS engineer) This will address the problem that, as things stand today, only systems designed and installed by an MCS contractor are Permitted Development and, as such, import into planning rules engineering considerations which are well outside the scope of planning. 2. Permitted Development rules in relation to air source heat pumps amended to allow 2(?) ASHPs provided that the combined noise meets the noise condition (and the other PD rules are met in relation to both) This will allow a combination of A2A and A2W heat pumps, or other two pump installation, without material negative effect on the built environment 3. Grant support under the BUS or similar to be available wherever a HP is installed to replace a gas boiler (used for domestic heating and the primary source of same) by a contractor accredited under NICIEC, NAPIT, GasSafe (list of organisations to be expanded), without regard to MCS or other complex design rules. Boiler removal part to be by a GasSafe engineer who signs off that its was previously in service and that he has audited against premises gas bills (to prevent fraud on the BUS). Support reduced to £1K if A2A installed as a part-replacement (conditions, and whether a later full replacement attracts a grant, to be defined) This will open up the market further and allow, for example, a separately contracted consultant to design the system to the person who physically installs it, currently forbidden under the MCS rules (much like the architect-builder relationship) 4. No Vat on HP at purchase - regardless who/where/how This will remove the discrimination against plumbers who fall below the VAT threshold (who currently cannot reclaim the VAT on the purchase) and against self-installers As I say above this alone wont be enough, we also need technical and workforce changes. I will try to summarise the suggestions for these (where they have gained some traction) in a separate post. Comments/suggestions for improvements please, preferably constructive (this thread went very negative for a while then became more constructive. Please lets keep it more constructive.

Sounds like the argument the Brexit brigade are using to justify the mess they have made, so fair game apparently.

Agreed. As you say in an earlier post supply market needs to expand and if necessary be tweaked by govt intervention. It has to become in someone's interest. And when plumbers replace a gas boiler they don't 'own the problems with the existing system'.

All of us. Unless these are done we wont fix our heating systems so they dont contribute to climate change. So we have to make it work!

Fairly easy, that figure tells us the total heat input, about 16MWh. The amount of energy needed to heat a house with a given loss in a particular location is well established. Your bills can be checked and you can be asked some simple questions about how you heat the house. From this a whole house estimate of load can be calculated, certainly to an accuracy MUCH better than the theoretical calculations appear to produce (see graph upthread). Really this is about the easiest part of the process. If the current calculations gave an accurate answer we might not be having this discussion, but they are way out, so we are. Finally oil really doesn't matter that much in the grand scheme of things, a tiny proportion of the heating in the country, so if we just did this for gas installations in the first instance it would suffice. No need to rely on what the customer tells you, the gas supplier has the data.

Not necessarily. Builders aren't liable for design mistakes by architects or structural engineers, they are only liable if they fail to follow the instructions. A reputable builder will always reserve the right to question an architect or structural engineer, a reputable plumber can do the same. This problem is soluble if it needs to be solved!

Agreed with the first sentence. Second less so, oil bills/gas bills/smart meter readings can be produced and analysed easily and will give a much more accurate indication than the current theoretical calculations.

Partly agreed (albeit off-topic). Batteries may eventually have some load-management value, albeit by the time the installed base of batteries has grown to the point it can make any significant contribution, the load management function will hopefully be performed by electric cars. For what its worth the solar installers around where I live currently pretty much refuse to fit solar panels without also fitting batteries. One was even brazen enough, when challenged, to admit that this was because the margins on batteries were higher. Another MCS closed shop stitch up!

Yes definitely. But only part of the solution. The other part of the problem is the heating system re-engineering, and in particular the (current) overestimating of the demand and the unnecessary replacement of much perfectly good kit. Until this is also fixed prices cant come down to the 4-5K target needed to achieve the volume. So, as @markocosic implies/states, we need to address this also. That requires a different mindset to the current 'rip it all out and start again' mindset and also is more skilled at the design stage (but ultimately much less difficult and cheaper at the implementation stage. I think this is the crux of the technical (as opposed to regulatory) problem, and its different from house to house, albeit there are similarities which can be exploited many of which have been discussed above. Its getting close to the point where a summary of this thread, and in particular the common ground, is needed!

Quite possibly true. However, with all due consideration to those who live in either super-insulated or otherwise low-load houses, these don't matter much in the grand scheme of things. We can tolerate a small percentage of low thermal load houses continuing to burn fossil fuels for the next 20 years if thats what they want to do, because the contribution to greenhouse gas emissions is small.

I was trying to be generous to/understanding of the designers!

I sort of agree and sort of disagree. Why? several reasons 1. I don't think it is fair to 'write off' all our 50 year old plumbers and electricians as you appear to do. There are plenty of 50 year olds who are still keen to learn new skills and to work hard. They also know some of the 'tricks of the trade' which a years practical experience wont necessarily teach them. So IMHO excluding the more mature part of the existing workforce is a mistake (and unlawful!) 2. I don't think enough younger people will go into plumbing and electricals fast enough to meet our needs. Its (sadly) a cultural mismatch for much of the UK which has (again sadly) developed an anti-engineering, anti maths, anti- 'practical work' mindset. 3. I cant see a real-world mechanism to generate the opportunities for these younger people fast enough without massive government intervention. With the current government that just isn't going to happen. Another government might make a different choice, but that depends on the voters! Perhaps the 'how' (to grow an adequately skilled workforce quickly) is a separate debate. We both (and others on this forum) agree we need an adequately skilled workforce, which is a good start in itself. My gut feel is that we need a combo of the ideas you have promoted and ideas which use the existing workforce. I also think there might be mileage in attracting people from other fields of engineering, maybe even retired people!. Design of a CH system retrofit is a system engineering task. Of course it needs some practical plumbing experience so you know what is easy and what is hard, but its fundamentally putting together reasonably well specified components using a combination of analysis, engineering judgement and experience to create a cost effective solution to a problem. I would reckon that many of those on this forum with an engineering background, and who have also done some plumbing even if its only DiY, could do it with probably a months training or less. Come to think of it that's exactly what they are doing but are frustrated that the industry and regulation conspire not to deliver what they want. Why not, I say. Back to - my gut feel is that we need a combo of the ideas you have promoted and ideas which use the existing workforce. BTW I do agree with

Not at all. There are multiple reasons why estimated load is likely to exceed actual load. These include unaccounted for fabric upgrades and over estimation of ventilation loss as well as 'margins' added to ensure that the system is big enough to cover uncertainties. I wouldn't necessarily characterise this as bad design, just design uncertainties which, inevitably, lead to margins being added in to cover them. I grant that some is bad design and some is doubtless usage patterns, but Im far from convinced its mostly bad design. My own estimates for my house come out at 11kW, using MCS assumptions and the best estimates I have of the fabric improvements (which I put in, but don't necessarily have the specs for). The measured load is 7.5kW. I don't think that difference is 'bad' design, its a design uncertainty.

If my experience, ad that of many on here is anything to go by, you wont get an MCS contractor (with the exception of Octopus if they will do yours) to quote less than about 10-15K after BUS, possibly up to 20K after BUS. The structural problem in the installation industry is that it is populated largely by fly-by-night companies set up to exploit the BUS grant, who arent interested in jobs costing less than about £15-£20K. So they quote for a whole load of work which often isn't needed, at rates which are extortionate. Because demand exceeds supply they get away with it. Local plumbers and electricians, whose bread and butter work is smaller jobs, are excluded by regulation. Your options appear to be get Octopus to do it if you can forgo the grant and use local plumbers and electricians, but bear in mind that Permitted development rights require MCS (bizarrely) pay the price demanded do it yourself There is a wildly raging discussion about this structural problem here, probably best read the first page then skip to about page 8, where some analysis of the underlying causes starts to emerge and some possible solutions also.

Not really, a factor of 2 or more oversizing/undersizing means that completely the wrong unit is chosen. Oversizing in particular leads to excess cost, the unit itself is more expensive, it wont modulate down so you need to fit a buffer, because you have fitted a buffer (doubtless badly) you get poor performance, it wont modulate down to the 6kW you can get through the existing 22mm pipes to the DGW cylinder, so you have to swap those out. Lots of very bad knock on effects.

1) Attract higher calibre, numerate / literate folks into the industry by paying good money and eliminating the bovine excrement. (having to compete with fly-by-nights; having to waste time chasing/qualifying leads and completing non value add tasks) You don't actually want this job to be a low paid job just right now. It should be very possible/common to make six figures aged 25 to get the people you need fully bought in. Drop the rates later once they're hooked. In this respect it's a good idea to let te folks willing to pay £10k pay £10k right now. 2) Kill the MCS stranglehold. That eliminates the fly-by-night grant chasers AND a good chunk of non value add tasks. You keep the requirements (e.g. the technical requirements with regards noise for permitted development) but make it the job of planners to enforce planning conditions (e.g. please prove it's adequately quiet, where here are the requirements lifted from the old MCS standards, and if you meet them them it's deemed fine, but you don't need to partake in the rest of the MCS charade) Relax a few planning conditions too. They're asking for units to be too small. It should be permissible to have both a heat pump and an air conditioner. There shouldn't be stupid restrictions on siting R290 propane units near to doorways whilst it's still ok to keep two 15 kg propane cylinders inside your house. Also 3) Look at communal ground arrays / hybrid arrays (substation gets a low temp air source heat pump on top that tops up a ground loop which nearby houses rent access to for £X per year and chuck a shoebox water:water heat pump in the kitchen to drawn from and feed the existing heating system; laying your LV cable reinforcement and FTTP at the same time as you lay the ground loop) 4) Quit subsidising new natural gas connections and subsidising marginal gas supply costs by moving the carbon taxes from electricity onto gas and moving the welfare taxes from electricity to central government and by requiring price transparency on the bills. (distribution and metering cost more than the electricity; historically) 5) Make use of / abuse advertising standards privileges / editorial accuracy requirements to kill the hydrogen nonsense; to kill the hit job articles; etc. 6) Take a chill pill. AC in cars is ubiquitous. Let people do AC in houses more easily. Don't mandate that in order to receive grant funding the heat pump must deliver heat AND hot water. Chop the available grant to £1k and apply the condition that it's a packaged/tested solution with a sCOP of 5 or above. It's pish easy to install A2A units in this ball park. They work. People will rave about them. So now we are beginning to get somewhere. The only one of these I would question is the first, not because I don't think that good plumbers should be well paid, nor because I don't think we should attract higher paid more talented people to the industry, but because I cant see that trying to recruit a whole load of people who currently know nothing about plumbing and electrics will yield enough in a short enough time to hit the target (it may be a longer term strategy though). I am more than ever convinced we have to use the existing workforce, local plumbers and electricians. They currently deliver 1.6M boilers a year, when they could be delivering 1.6M heat pumps. So the solution here needs a bit more thought and is, I suspect, a combination of training simplification, eg using some of the ideas @johnmo has posted some sort of 'system consultant/system architect role/function which works out the difficult things in cases which need it (and are paid as @markocosic suggests. We do this in the building industry (builders are separate from architects and structural engineers, and are separately contracted by the customer), why not in heating too? Is there any reason not to do it this way, rather than expecting everyone 'on the job' to be ace heating designers? And even if there is a reason, is the alternative Im suggesting good enough that its a preferable/practical way to achieve the volume we need?