Rethinking the mindset for mass retrofit - a provocative idea

[JamesPa]

40 minutes ago, JohnMo said:

That would be nice, I would make a £2k profit. Or at least get what I am doing free of charge.

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!

[JamesPa]

17 hours ago, JamesPa said:

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.

 

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.

 

[SteamyTea]

@JamesPa

 

Can get a conclusion down to about 300 words, then send it off to BBC Radio 4's You and Yours.

Nearly every week they are talking about HPs, most of it is accurate, but often misguided.

Pointing out that there are planning restrictions may spur some action.

 

I wonder how a car is allowed to be parked outside the front of a house with our planning laws.

[DougMLancs]

Personally I would also amend i) to remove the need for it used solely for heating purposes where the system forms the primary heating system for a property. I believe most A2A units are capable of cooling which means they have to go through planning at the moment. This caught my brother out when he ripped out ancient storage heaters and went for A2A. He ticked all the other PD conditions but had to apply for retrospective PP. I don’t think they’ll believe you if you promise not to switch on the cooling in summer 😉 I take your point @jamespa but if we’re trying to overhaul the regs we may as well improve the wording.

Edited April 29, 2023 by DougMLancs

[JamesPa]

7 minutes ago, DougMLancs said:

Personally I would also amend i) to remove the need for it used solely for heating purposes where the system forms the primary heating system for a property. I believe most A2A units are capable of cooling which means they have to go through planning at the moment. This caught my brother out when he ripped out ancient storage heaters and went for A2A. He ticked all the other PD conditions but had to apply for retrospective PP. I don’t think they’ll believe you if you promise not to switch on the cooling in summer 😉

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.

[JohnMo]

Just to counter the above what about the hour or two heating the cylinder when the ASHP could be running flat out even in the summer.

[JamesPa]

2 minutes ago, JohnMo said:

Just to counter the above what about the hour or two heating the cylinder when the ASHP could be running flat out even in the summer.

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.

[Dillsue]

23 hours ago, JamesPa said:

Finally oil really doesn't matter that much in the grand scheme of things, a tiny proportion of the heating in the country

I think this view is the crux of the problem that we face as most people dont think they are the cause of the climate change problem, as they're only a tiny proportion of the emmissions in the world.

 

First thing we need to address is that we're all responsible and no body is exempt

[SimonD]

3 hours ago, JamesPa said:

. the air source heat pump must be used solely for heating purposes;

 

Why? Many A2W pumps also provide cooling which would inihibit product availability/installation.

 

I would suggest that the change is from the existing BUS regulations (Part 3, Regulation 9) stating a heat pumps is eligible if  it is "for the purpose of both space heating and hot water heating, using liquid as a medium for delivering that heat" and "it is capable of meeting the full space heating and hot water heating demands of that property"

 

to something that permits heatpumps other than those using a wet medium and that it doesn't not have to satisfy the requirements of both heating and hot water, but a minimum of heating purposes, leaving some flexibility for the use of immersion powered by various means as a potential for hw.

 

Additionally, the BUS regulations (Schedule 4) permit certification schemes other than MCS it's just that nobody seems to have set up an alternative yet. Therefore within the regulations it would be possible to set up an alternative simply taking advantage of the free market. The HHIC tried to do this about 8 years ago and not sure what came of it - probably nowt.

 

The additional comment is that MCS does currently permit the seperation of design and installation as it now has 2 different qualifications and if you're qualified just for installation, you must have a relationship with a designer and provide evidence of the design. Because the focus has recently been to train installers (e.g. discounted training funded by government through OFTEC) several companies are starting to offer design only services for a fee. This is attractive to installers as it also reduces risk and liability on the part of the installers.

 

In terms of other specifics, there definitely needs to be a revision of training requirements as last year they introduced a further requirement that trainees had to have held plumbing/heating qualifications for at least 2 years to attend - bloody silly when you're already allowed to play with gas and oil which I'd argue are a little more dangerous.

[JamesPa]

1 minute ago, Dillsue said:

I think this view is the crux of the problem that we face as most people dont think they are the cause of the climate change problem, as they're only a tiny proportion of the emmissions in the world.

 

First thing we need to address is that we're all responsible and no body is exempt

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.

 

 

[JamesPa]

28 minutes ago, SimonD said:

Why? Many A2W pumps also provide cooling which would inihibit product availability/installation.

 

 

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.

 

28 minutes ago, SimonD said:

to something that permits heatpumps other than those using a wet medium and that it doesn't not have to satisfy the requirements of both heating and hot water, but a minimum of heating purposes, leaving some flexibility for the use of immersion powered by various means as a potential for hw.

 

Seems like a good idea (although its arguably implicit in proposal (3).)

 

28 minutes ago, SimonD said:

Additionally, the BUS regulations (Schedule 4) permit certification schemes other than MCS it's just that nobody seems to have set up an alternative yet. Therefore within the regulations it would be possible to set up an alternative simply taking advantage of the free market. The HHIC tried to do this about 8 years ago and not sure what came of it - probably nowt.

 

Correct, nowt, hence the need to relax the rules as set out in proposals 1-4

 

28 minutes ago, SimonD said:

The additional comment is that MCS does currently permit the seperation of design and installation as it now has 2 different qualifications and if you're qualified just for installation, you must have a relationship with a designer and provide evidence of the design. Because the focus has recently been to train installers (e.g. discounted training funded by government through OFTEC) several companies are starting to offer design only services for a fee. This is attractive to installers as it also reduces risk and liability on the part of the installers.

 

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.

 

28 minutes ago, SimonD said:

In terms of other specifics, there definitely needs to be a revision of training requirements as last year they introduced a further requirement that trainees had to have held plumbing/heating qualifications for at least 2 years to attend - bloody silly when you're already allowed to play with gas and oil which I'd argue are a little more dangerous.

 

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.

 

 

Edited April 29, 2023 by JamesPa

[markocosic]

3 hours ago, JamesPa said:

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

 

Nope.

 

Most run the compressors flat out for DHW production and the compressors on a good unit are very much louder than the fans I'm afraid.

 

Windows are likely to be closed and blinds pulled whilst cooling if PV powered. Nighttime cooking is the swine for those without cooling as their windows will be open for night cooling.

 

[SimonD]

1 hour ago, JamesPa said:

So nothing in the current condition inhibits installing, under PD, ASHPs which are capable of cooling provided that they are not used for cooling. 

 

The wording I was refering to is in the BUS regulations rather than PD - there's a need to be a clear distinction here between the two as well as joined up requirements

 

1 hour ago, JamesPa said:

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.

 

Where is it stated that this must be the case? In the BUS regulations, which appears to be the relevant regs here for the grant, it simply says that an installation must meet the required scheme standards, which from a design perspective mean designed by someone competent to do this job according to MCS or equivalent body and then installed to those standards. Nothing I've read so far prevents a customer from engaging their own designer and installer. Maybe I've missed something spurious in the MCS rules.

 

1 hour ago, JamesPa said:

The above proposals break the MCS stranglehold.

 

And if you read the regs, the MCS doesn't have a regulatory stranglehold, just a free market one - so to break the strangehold, you can just set up an equivalent body!

 

5 hours ago, JamesPa said:

other complex design rules

 

With respect to this, and being someone who has completed the low-temperature heating system design course, the design rules are not particularly complex. Onerous perhaps....

 

I am of the view that the last thing we want to do is relax the design requirements of new heating systems, simply because good heating system design makes sense from both environmental and economic perspectives. I also think that the last thing we want to be doing is chucking in heat pumps as if that's what's going to save us. You only need to look at UK and European policy on Diesel engines and numerous other ones to understand how that goes.

 

My humble view is that we need to actually take the time and make the investment to do it properly, With my professional background, I've been involved in enough global change initiatives within multinational companies where they've forged ahead with what seems like a good idea in a state of panic because they thought they didn't have the time to do it properly.

 

Rather than proposing a relaxation of standards, I would propose a scheme whereby the customer is provided with a design voucher and told they can choose their own designer and that design cost is covered by the government as part of the grant scheme.

 

Not only would this enable a better non-risk assessment of heating system suitability but also a huge amount of data to be gathered to shape both policy and practise going forwards. Including to shape resource planning.

 

As has already been raised, the complexity does however lie in the retrofit of the heating system and dealing with the historical real world crap of UK central heating systems - look in enough houses and it is something the behold. Some of the ideas and suggestion here that it simply requires a couple of pipes and might just take a plumber and electrician 1 day to fit really do not demonstrate an understanding of working with heating systems in this market.

 

For me it simply has to go back to the reality of good training and development, as well as promoting a cultural shift in how we view 'manual' labour. The reality is that the number of qualified heating engineers is reducing year on year. The reality is also that government policy over the last 25 years or so has kicked this can down the road and it has come back to bite us. For sufficient training to become independent and efficient in this space, you really do need a good 2/3years of onsite experience, even more if, like me, you live and do this work on lots of old victorian and georgian properties.

 

I'm sorry if this doesn't match the idea of getting a fast roll-out, but the whole thing touches upon a lot of complexities that, like it or not, do take time to resolve.

[JamesPa]

1 hour ago, SimonD said:

Nothing I've read so far prevents a customer from engaging their own designer and installer. Maybe I've missed something spurious in the MCS rules.

MCS rules, MIS 3005-I paragraph 1.4 (and doubtless a similar paragraph in MIS 3005-D), to be precise

 

1 hour ago, SimonD said:

The wording I was refering to is in the BUS regulations rather than PD - there's a need to be a clear distinction here between the two as well as joined up requirements

I cant find anything in the BUS regulations which says that the installed HP must be incapable of cooling, which regulation is this please?  If they do say that then I agree it needs to change.

 

1 hour ago, SimonD said:

And if you read the regs, the MCS doesn't have a regulatory stranglehold, just a free market one - so to break the strangehold, you can just set up an equivalent body!

but nobody has, and the current regulations completely exclude the only workforce we have that is capable of scaling up to the volume we need and interested in the size of job this needs to become in order to reach mass roll out (I mean local plumbers and electricians).  Currently the market is dominated by special purpose fly by night companies set up to harvest the grant who have no interest in anything other than the cream of the jobs and have the luxury of choosing.  For local plumbers 5K retrofits is their bread and butter.  See also all the reasons others have given above why the MCS stranglehold.

 

1 hour ago, SimonD said:

My humble view is that we need to actually take the time and make the investment to do it properly,

Agreed, but define 'properly'.  Currently most retrofit installations involve throwing out lots of perfectly usable equipment, often unnecessarily, to fit an oversized heatpump.  That accounts for a significant part of the cost and disruption (the rest is just excess margin).  There is insufficient competition in the industry for anyone to take on the lesser jobs.  There is no earthly way mass roll out is going to be achieved at 15K a pop, because retrofit of replacement gas boilers costs 4-5K a pop.  The job needs to be stripped back to what's strictly necessary, but currently nobody has the incentive to do this.  See discussion earlier in the thread.

 

1 hour ago, SimonD said:

Rather than proposing a relaxation of standards, I would propose a scheme whereby the customer is provided with a design voucher and told they can choose their own designer and that design cost is covered by the government as part of the grant scheme

This would only work if regulation is also relaxed so that the customer can then compete the actual installation and it does not have to be done 'to MCS standards' (which require all sort of things that aren't necessary, create a closed shop and stifle innmovation). Current regulation prohibits this and the changes above would fix this up.   

 

The objective is not to reduce standards rather to make the regulation fit for purpose and allow more innovation in the marketplace.

 

I do think there is value in separating design and build though, just as architects and builders are separate.  But this cannot happen until the market is freed.  Note also my comment that 'we also need technical and workforce changes'.  This could well be part of these and indeed several have discussed it above (albeit that there are arguments both ways)

 

1 hour ago, SimonD said:

For me it simply has to go back to the reality of good training and development, as well as promoting a cultural shift in how we view 'manual' labour. The reality is that the number of qualified heating engineers is reducing year on year. The reality is also that government policy over the last 25 years or so has kicked this can down the road and it has come back to bite us. For sufficient training to become independent and efficient in this space, you really do need a good 2/3years of onsite experience, even more if, like me, you live and do this work on lots of old victorian and georgian properties.

Yes and no.  I return to the fact that we have local plumbers and electricians who today do 1.4 gas boiler retrofits each year but are excluded from the market.  So we need to enable them to become included (and sufficiently trained), hence the proposed regulatory changes.  

 

Note that I say above:

 

7 hours ago, JamesPa said:

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.

 

1 hour ago, SimonD said:

I'm sorry if this doesn't match the idea of getting a fast roll-out, but the whole thing touches upon a lot of complexities that, like it or not, do take time to resolve.

 

Unfortunately climate change wont wait for us.  1.4M gas boilers retrofitted per year is 1.4M lost opportunities for the next 20 years.  

Edited April 29, 2023 by JamesPa

[DanDee]

1 hour ago, markocosic said:

 

Nope.

 

Most run the compressors flat out for DHW production and the compressors on a good unit are very much louder than the fans I'm afraid.

 

Windows are likely to be closed and blinds pulled whilst cooling if PV powered. Nighttime cooking is the swine for those without cooling as their windows will be open for night cooling.

 

Most actually don't run flat out at all. If you have a look at those shared on https://heatpumpmonitor.org/ you can see that even now at 10-15 Celsius they don't run flat out. Even less in the summer due to higher air temperature the compressor uses less energy/workload to achieve the same output. Just check these things before saying it that it's that plain simple. 

Edited April 29, 2023 by DanDee

[JamesPa]

3 minutes ago, DanDee said:

Most actually don't run flat out at all. If you have a look at those shared on https://heatpumpmonitor.org/ you can see that even now at 10-15 Celsius they don't run flat out. Even less in the summer as the higher air temperature requires less energy from the compressor to achieve the same output. Just check these things before saying it that it's that plain simple. 

Interesting (and in a different context important) though this debate is none of it is an argument against retaining the current wording that ASHPs installed under PD must be used for heating only, for which there is a sound argument set out above.  Unless of course you are advocating that no installation of ASHPs should be allowed under PD, which so far nobody has done on this forum.

 

A reminder of what we are looking at in order to 'bank' some progress in the discussion so far:

 

7 hours ago, JamesPa said:

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).  Rules of BUS to be modified to permit this.

 

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.

 

 

7 hours ago, JamesPa said:

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.

 

 

[DanDee]

1 minute ago, JamesPa said:

 Unless of course you are advocating that no installation of ASHPs should be allowed under PD, which so far nobody has done on this forum.

 

 

 

I was only addressing the non fact that they run flat out in the summer on DHW duty cycle.

[JamesPa]

1 minute ago, DanDee said:

 

I was only addressing the non fact that they run flat out in the summer on DHW duty cycle.

Agreed, and I was only pointing out that whoever is right it doesn't affect the basic thust of the thread, to avoid (hopefully) getting distracted.

[DanDee]

5 minutes ago, JamesPa said:

Agreed, and I was only pointing out that whoever is right it doesn't affect the basic thust of the thread, to avoid (hopefully) getting distracted.

To participate in the conversation. There will be cases when a HP AW/AA will impact the neighbors in the summer, and there will be cases when not. It's all about space and location.

 

This is a HP that was moved and encased in metal, from next to the house wall initial location, opposite a neighbor's brick wall that was reverberating the noise, affecting both parties, more the owner due to the location outside his home office.

 

There can be solutions, although not for every case.

 

Photos from a dutch forum.

 

[JamesPa]

13 minutes ago, DanDee said:

Photos from a dutch forum.

 

You dont happen to know what the Dutch rules are on location etc.  Do you need permission each time a heat pump is installed or can they be installed (in some circumstances) without permission (as they can here, but the circumstances are very limited).

[DanDee]

23 minutes ago, JamesPa said:

You dont happen to know what the Dutch rules are on location etc.  Do you need permission each time a heat pump is installed or can they be installed (in some circumstances) without permission (as they can here, but the circumstances are very limited).

Not clear cut info, it refers only to noise. Generally permitted but with limitations, I don't know about enforceability. 

 

 

Noise requirements for heat pumps and air conditioners are being tightened

News item | 23-03-2021 | 11:13

As of April 1, 2021, new noise requirements will be imposed on (newly placed) installations for heat or cold generation installed outside. This concerns heat pumps and air conditioners that are used in homes and residential buildings. These installations may not cause more than 40 dB noise to the neighbours. With this national noise standard, neighbors are better protected against noise from heat pumps and the development of quieter heat pumps is promoted.

The heat pump market shows continued strong growth in numbers and in heat production. This noise requirement will help the heat pump in its further advance, and also accelerate the development of new quieter heat pumps. Sales are expected to continue to grow in the near future.

The determination method for the new noise requirements has been laid down in the 2012 Building Decree Regulation (Government Gazette 2020, 62676), which will enter into force at the same time. This determination method is a noise measurement on location. However, on the basis of acoustic calculations, it can be made plausible in advance that the noise requirement will be met. The Ministry of the Interior and Kingdom Relations has commissioned a calculation tool (ODS file) and an associated manual for these calculations. The noise requirements do not apply to the heat pump itself (from the factory), but to an installation placed near a home. The heat pump itself generally does not meet the 40 dB requirement. This means that the installation must be placed at a sufficient distance from the neighbors or must be shielded so that the 40dB is not exceeded.

 

The National Government. For the Netherlands

 

This is just for laughs

Edited April 29, 2023 by DanDee

[JamesPa]

38 minutes ago, DanDee said:

As of April 1, 2021, new noise requirements will be imposed on (newly placed) installations for heat or cold generation installed outside. This concerns heat pumps and air conditioners that are used in homes and residential buildings. These installations may not cause more than 40 dB noise to the neighbours. With this national noise standard, neighbors are better protected against noise from heat pumps and the development of quieter heat pumps is promoted.

Assuming that this NL, thats 3dB more (less stringent) than the UK PD standard.  Also the UK figure applies to heating only, for cooling (which is never PD in the UK) LPAs often apply a  standard which is more stringent still - 10dB below ambient, which can mean that ~30dB is required in quieter neighbourhoods.

 

I doubt the installation you have illustrated complies with even the weaker Dutch standard!

 

 

Edited April 29, 2023 by JamesPa

[markocosic]

4 hours ago, DanDee said:

on https://heatpumpmonitor.org/ you can see...

 

...that they run flat out or, at least run hard, when producing DHW.

 

Compressors leak internally. Hitting higher temperatures for DHW needs high pressures. High pressures leak too much internally if you run the compressor slowly. So you run it hard to avoid operating in the inefficient part of the compressor envelope.

 

Perhaps dialling back a notch if the tank can't take that amount of power without the flow temp rising too much; but running hard nevertheless.

 

They'll be at minimum output cycling for space heating.

[SimonD]

5 hours ago, JamesPa said:

MCS rules, MIS 3005-I paragraph 1.4 (and doubtless a similar paragraph in MIS 3005-D), to be precise

 

This paragraph says that there must be a single point of contract with the customer, therefore, if an installer is not qualified for design then the designer must be subcontracted. Likewise, if the designer contracts directly with the customer, then an installer would be subcontracted. Overall responsibility lies with the direct contracting party.

 

Now, this does not prevent the customer from using preferred suppliers providing there is a single contract, which makes sense because if you have two contracts - one for design and one for installation, then if there are any problems you give rise to lots of potential buck passing - whose problem is it, the designer or installer bla bla. From a practical perspective, this makes a lot of sense, IMHO.

 

So it is possible for a customer to select a high quality designer, who you would assume would e happy to select a high quality installer, rather than the customer having to rely on some random unknown local installer.

 

5 hours ago, JamesPa said:

but nobody has, and the current regulations completely exclude the only workforce we have that is capable of scaling up to the volume we need and interested in the size of job this needs to become in order to reach mass roll out (I mean local plumbers and electricians).  Currently the market is dominated by special purpose fly by night companies set up to harvest the grant who have no interest in anything other than the cream of the jobs and have the luxury of choosing.  For local plumbers 5K retrofits is their bread and butter.  See also all the reasons others have given above why the MCS stranglehold.

 

No, the current regulations do not completely exclude the only workforce capable of scaling up to the required volume. And given that this workforce are very much in short supply (I know because I'm one of them) and reducing day by day, it's a very tall ask. In fact one of my mates, in his 60s has just got the design and installation tickets which only took a few days training and some exams. In recent research by Gas Safe, however, the conclusion showed that only 32% of registered engineers intended training on heatpumps.

 

I'm seem to be repeating myself that the issue is structural, requiring a change in culture, training and policy.

 

The MCS does have many problems - it's expensive and the standards reads like a corporate process and beaurocracy manual. It also seems to be a bit stuffy. Its existence creates a good number of hoops that installers and designers have to jump through, but then if the industry wants to professionalise itself, then hoops have got to be jumped through - what does it take to become a recognised and register professional in other areas the building sector? E.g. a structural engineer or architect?

 

5 hours ago, JamesPa said:

Currently most retrofit installations involve throwing out lots of perfectly usable equipment, often unnecessarily, to fit an oversized heatpump.

 

What is your evidence for this statement and how do you judge what is perfectly usable equipment? I can tell you that one of the primary reasons stuff is stripped out is because of the risk of problems over the short term that result in significant cost and resource demand both for the customer and the installer, not because of greed.

 

In the last 2 months I've had call backs and headaches due to customers demanding components are kept because they seemed to think they were fine. One of them was a magnaclean that had originally been installed poorly so that, like so many of them out there, the composite thread was stripped starting a leak as soon as the filter was touched - result: order a replacement and because the model has now changed, re-pipe the installation. The next was a heat only boiler installation where the customer insisted on a heat only boiler as the existing pump was relatively new as was the motorised valve and other bits in the heating system. The pipework was so bad that on installation it took 3 days to clear airlocks and once it was running it lasted just 4 months before I get called back due to a no flow error on the boiler - I should have torn all the old crap out and fitted a system boiler which was what I originally specced as this would have avoided all these problems. Problems that impacted my customer, my reputation and they ultimately have a significant carbon cost too.

 

It's a very difficult balance deciding what to keep and not to when you want to leave a system that works well and reliably for a customer.

 

5 hours ago, JamesPa said:

but are excluded from the market

 

They're not excluded from the market, they just need to go and get the relevant training and pay the money to get the right tickets. Why they aren't doing so is more the question. Almost all of them need to be trained as low temperature heating systems require a fundamental change of mentality and this is not a technical question. But also it's very difficult to install a heatpump as a one man band due to size and weight of a heatpump. For example, a Vaillant aroTherm 5kW heatpump has a net weight of 85-90kg. This is not something you can carry and lift into place on your own so you need at least one more person. Costs then escalate.

 

5 hours ago, JamesPa said:

the changes above would fix this up.

 

The changes you've suggested would do nothing for improving standards and innovation, nor would they improve supply of resource which needs to be trained and experienced. The industry badly needs new blood that has a desire to maintain a decent career, whether as a business or as an employee. This is where the focus needs to be rather than some tinkering with PD, for example.

 

5 hours ago, JamesPa said:

hence the proposed regulatory changes.  

 

All the current competent person schemes could set up alternative schemes to the MCS as it stands. No regulatory changes are required. The question is: why don't they already?

 

5 hours ago, JamesPa said:

Unfortunately climate change wont wait for us.

 

Which is exactly why we have to ensure we think for the long term and don't implement short term solutions that from a life-cycle perspective demand more resources than necessary - such as energy generation, network infrastructure and natural resources.

 

5 hours ago, JamesPa said:

Currently the market is dominated by special purpose fly by night companies set up to harvest the grant who have no interest in anything other than the cream of the jobs and have the luxury of choosing. 

 

Unfortunately, it's on this kind of statement that I lose respect for the entire premise of the thread. There are plenty installers and designers out there who have their customer's best interests at heart. And the costs, while unpalatable are not always down to people making excess profits, but reflective of the demands of the job and costs of running a business. This is often poorly understood, even by competent DIYers and self builders on this forum. If I now go back to a quote I received a few years ago for the installation of a 7kW heatpump with unvented cylinder, knowing what I do now, I know what work has to go into designing, installing, commissioning and tuning the system. I don't think it was unreasonable any more!

 

The reality is that if a customer wants to forget the BUS grant, then there don't seem to be any preventions to installing the system themselves, or having a non MCS installer doing the job. The risk, however, would be with product warranty.

 

[sharpener]

24 minutes ago, SimonD said:

Likewise, if the designer contracts directly with the customer, then an installer would be subcontracted.

 

I don't think this is a likely scenario. Having employed architects and structural engineers (@JamesPa's analogy) and also having run my own technical consulting business I think I can say that it is unlikely that the designers would want to be prime contractors to cover the installation work. There are just too many extraneous factors that could go wrong even with a known and trusted installation partner. Even if things went OK the inevitable contract variations (consumer add-ons, emergent work) would then have to be renegotiated via the design house which they would not want to get involved with. Also the professional indemnity insurance would not be likely to cover the extra exposure.