Rethinking the mindset for mass retrofit - a provocative idea

[Radian]

1 hour ago, markocosic said:

And visual amenity

Like the sea of brightly colored wheelie bins you see on terraced rows.

[gregh]

14 minutes ago, Radian said:

Like the sea of brightly colored wheelie bins you see on terraced rows.

Preserved just as it was in Victorian times. It's a shame the planners can't apply their logic to more widely. Who wouldn't want to bring back child labour, toilets in the garden, and living to the ripe old age of 45!

[MikeSharp01]

40 minutes ago, Radian said:

Like the sea of brightly colored wheelie bins you see on terraced rows.

They are an abomination that is for sure.

[Rob99]

2 hours ago, markocosic said:

It's been proposed and attempted but is not viable on battery power.

On the contrary, Loxone have had proportional radiator actuator valves running on batteries for several years.

[Dillsue]

2 hours ago, ProDave said:

Anyone could do the water plumbing of a gas CH system then the gas safe engineer comes along connects the gas, signs it off and everyone is happy.

 

A bit like mu UVC The G3 plumber just made the final water connection checked it all and signed it.

If that is the building regs compliance doc that is being signed off then no problem others having done some or all of the wet install. If its the gas safe cert then it should just be the fitter thats worked on the gas elements, AFAIK

[markocosic]

9 hours ago, Rob99 said:

On the contrary, Loxone have had proportional radiator actuator valves running on batteries for several years.

 

Not of the sort required.

 

They rely on the mechanical valves for full flow system balancing (the thing that heat pumps require/Mike wanted to automate)

 

The actuator head has control over room temperature but doesn't regulate the max flow rate.

 

(i.e. you still need the lockshield or presettable trv body to be setup before the temperature controlling head is added)

[sharpener]

On 23/04/2023 at 19:39, JamesPa said:

except that the legislation doesn't say 'MCS Noise Standards, it says 'MCS Planning Standards or other equivalent standards'.  And the 'MCS Planning Standards', defined by MCS, require MCS installation and design, so an equivalent would (presumably) need to have similar constraints.  If it were that easy, why has nobody done it.  

 

Bad drafting of the regs, I grant, but fact nonetheless

 

This is the nub of it. Planning departments use the word "Planning" to cover different things (environment, noise) from MCS (system design, hp sizing). Not easy to fix now the confusion has arisen.

 

In principle I think it should be possible to argue that the latter aspects are of no concern to the planners and so PD should apply provided the relevant parts of the MCS standards i.e. wrt noise and external appearance (if any) are met, and enforcement action against someone who met them whilst not being an MCS-certificated installer did not achieve any planning control objective and was therefore not in the public interest.

 

But local planners are capricious and might require one to apply for retrospective p/p as a remedy. And then impose conditions which as you have found make no sense or defy the laws of physics - but they can be seen to have done their job and it is you that are non-compliant.

 

Neighbour has a cellar with a window onto our property. MCS definition of "habitable room" does not mention cellars, just says (from memory) any "room" other than kitchen, toilet or bathroom. What about descriptive terms like library, study, studio, scullery, pantry, lobby, attic at least some of which would usually be regarded as "rooms", do we have to consider them or not? Or hall(way), corridor or landing - which are not normally thought of as "rooms" yet might be affected by noise? Or box room, store room, shower room, wet room, boot room, gun room, darkroom - which are "rooms" by their very nomenclature but not at all likely to be affected?

 

IIRC there is someone on this forum who is a noise consultant, I wonder if he will tell us what the case law is on these definitions, they cannot be unique to ASHPs.

[RichardL]

FWIW I went full planning for a second ASHP external unit - a second unit falls outside PD.

The planners on a full planning application were interested in model numbers, but mostly noise and location of the noise relative to road/neighbours.

The model numbers bit was interesting - planning doesn't usually go that level of detail - I guess they wanted the opportunity to double check sound levels advertised?

My point being - IF sound is all that concerned them on full planning you'd have thought permitted development could potentially restrict itself to the same criteria:
   a. is it visible from the road/neighbours
   b. is it over (pick a number) 65dB

   => If no for both then PD

All this MCS stuff seems overkill

(sorry if I missed the point above)

[sharpener]

1 hour ago, RichardL said:

FWIW I went full planning for a second ASHP external unit - a second unit falls outside PD.

The planners on a full planning application were interested in model numbers, but mostly noise and location of the noise relative to road/neighbours.
 

Did you get it in the end?

[RichardL]

8 hours ago, sharpener said:

Did you get it in the end?

Yes - no issues - no complaints from the various mandatory commenters - ward politicians, aonb, etc etc. It didn't even make it to a planning meeting - decided offline.

Just took 3-4 weeks.

[S2D2]

37 minutes ago, RichardL said:

Yes - no issues - no complaints from the various mandatory commenters - ward politicians, aonb, etc etc. It didn't even make it to a planning meeting - decided offline.

Just took 3-4 weeks.

How much did it cost for planning if you don't mind me asking? If I install an A2W it will also be a second outdoor unit.

 

As others have said, for PD I considered following the MCS requirements that were relevant to planning (noise, visibility from street) to be all that's required. System performance is not within their enforcement remit. Someone could test that with a certificate of PD if they wanted a watertight guarantee.

 

I remember some concern about the wording including MCS Contractor, here is the definition from their standard:

 

 

I.e. distinctly different from a certified MCS Contractor?

[RichardL]

@S2D2  £230 for householder planning, half that for a certificate if you are sure you are inside PD and just want confirmation, my lot are cheeky now and also want ~£100 just for a conversation with a planning officer for informal advice.

Randomly in this part of the world you have to add to wildlife environments - hence the bird box requirement.

The certificate approach usually doesn't need plans.
TBH MCS wasn't mentioned either when I checked for the original PD unit, nor when this full application went through - is it a regional thing?


Text  of my application, this was accompanied by full elevation/site plan/location plan etc.
Passed in Feb this year.
 

Context
---------
Continue projects to move the property away from Oil fired heating/hot water to sustainable options.
The plan is to migrate to a combination of solar/battery and air source heat pump technologies.

This proposal will complete the move of space heating away from Oil.
 

Current situation
-------------------
The property is currently heated with a combination of Oil boiler and one external air source heat pump unit.

The air source heat pump was installed under permitted development terms, heating the timber frame half of the house & was successful in terms of functionality and costs over the winter months.

The existing heat pump install was discussed informally with the planning dept. 1/2/21 and your colleague .... advised "...it is most likely that your proposals would be considered PD." - I proceeded on that basis with reference to the PD constraints he shared.

I would like to expand the system.
 

Proposed changes
----------------------
1. Abide by Planning Policy Wales (PPW) 11 to enhance local wildlife and install a bird box 2-4m high on the north/east side of the Pear tree as indicated on the site block plan.

2. Install two external inverter/condenser units and discrete external trunking to supply heat to remaining rooms: The dining room, boot room and upstairs bedrooms.
 

One additional unit sited at the back of the property.

Mitsu.....
Dimensions: w x h x d: 950mm x 330mm x 796mm
Max noise level 51 dBA

SCOP: 4:6-4:65
To heat: Boot room and upstairs bedrooms.
Visibility: Front not visible from the ... road. Back not visible from the ... road.
 

One additional unit sited near to the existing one next to the Lounge/Office area at the front of the property.

Mitsu.....
Dimensions: w x h x d: 800mm x 285mm x 550mm
Max noise level 46 dBA

SCOP: 3.74-4.2
To heat: Dining room.
Visibility: Front not visible from passing traffic on ... road, units some visibility if standing at the front gate. Back not visible from the ... road.

Edited April 25, 2023 by RichardL

[RichardL]

@S2D2
For full context - this is the response - granted a bit old now from 2021 - re the original unit permitted development -  there is the MCS standards statement - I guess it was implicit that I was using equivalent standards - I used terms like qualified installer/qualified electrician etc.

I guess this does depend on local govt. development principles etc - may be different where you live - I could refer to the gov.wales document in my original PD conversation.

Apologies I've had to remove some links which identify exactly where I am - 
 

Good morning Richard,

The follow Welsh Government link provides additional detail on what is deemed Permitted Development for ASHPs: 

https://gov.wales/planning-permission-heat-pumps

Installation of one air source heat pump used solely for heating purposes is normally permitted, provided that it complies with the MCS Planning Standards (or equivalent standards) and subject to the following conditions:

·         - no more than one air source heat pump can be installed on (or within the curtilage of) your property

·         - the volume of the air source heat pump's outdoor compressor unit (including any housing) must not exceed one cubic metre

·         - no part of the air source heat pump can be installed within three metres of the boundary of your property

·         - if in the case of the installation of an air source heat pump, a stand alone wind turbine is installed within the curtilage of the dwellinghouse

·         - the air source heat pump can not  be installed on a pitched roof

·         - if installed on a flat roof, the air source heat pump must not be sited within one metre of the external edge of that roof

·         - the air source heat pump cannot be installed on a wall or roof which fronts a highway.

An air source heat pumps must be sited to have a minimal effect on the external appearance of your property and the wider amenity of the area. For more details on restrictions applying to the installation of air source heat pumps, you should contact your local planning authority.
 

From looking at the above it is most likely that your proposals would be considered PD.

...'s Renewable Energy Supplementary Planning Guidance also provides additional guidance (on 68/80): <link removed>

 

Heat Pumps are PD if they are under 45KW, but my understanding is that most domestic heat pumps fall well within this limit.

For proposals that are deemed permitted development you can apply for a Lawful Development Certificate (a.k.a. Certificate of Lawful Use – application form attached). This would be the only means by which to obtain a legally binding decision that the works qualify as permitted development.

 

This can be obtained in the interest of any future property sale/conveyancing undertaken that would query the works.

[S2D2]

Thanks @RichardL, very helpful. £330 to planning that could have been spent on renewables, that's half the cost of my A2A install...

[SteamyTea]

This 'visible from road' which is really just saying not at the front of most houses.

Does it not rather clash with the noise conditions.

Most people's rear gardens are quite than the front ones, because they are shielded from traffic by 100 tonnes of solid mass.

It is not unusual for my road to hit 90 dB (one if my neighbours cars is 80 dB when it is ticking over, and 10 metres away). The rear of my house is generally much quieter at night, though when upstairs one can hear the road more as there is a bend and a rise.

If I could put an ASHP at the front of my house, the one installation would be much simpler, make no difference to noise levels and be mostly hidden by some pampas grass. 

 

Really there needs to be a better way to enforce noise problems if they arise, not try to make one technology a special case.

[RichardL]

Yeah - I was emphasising visibility because I'm in an AONB, luckily not a conservation area, so assumed a lot of emphasis of the decision would be on whether the units be seen - by neighbours or general public...

The '... road' in my application were originally explicit road names.
 

[RichardL]

17 minutes ago, S2D2 said:

Thanks @RichardL, very helpful. £330 to planning that could have been spent on renewables, that's half the cost of my A2A install...

Plus - If you have to employ someone to do drawings - double/trebble that number (guess).
I spent a few weekends drawing up my own plans.

TBH I'm interested in the process, documentation, bring a bit of school graphic communication skillets the fore with plans/elevations etc - if you weren't then it would be expensive in time and £ to hire someone to do it.

Edited April 25, 2023 by RichardL

[S2D2]

9 minutes ago, RichardL said:

Plus - If you have to employ someone to do drawings - double/trebble that number (guess).
I spent a few weekends drawing up my own plans.

TBH I'm interested in the process, documentation etc - if you weren't then it would be expensive in time and £ to hire someone to do it.

PD needs expanding to two units imo, enough for a full A2A multisplit install or a phased move from Gas -> A2A offsetting gas -> A2A + A2W.

 

All the current fees do is incentivise scrapping a perfectly good A2A unit to get the A2W under PD and spending that money on the A2W install.

[ProDave]

In Scotland the PD planning rules for ASHP's are different, it has to be something like 100 metres from a neighbours boundary to be PD which few would be able to achieve.

 

I was originally planning a GSPH (which are PD) but changed my mind in time to get it added on to the planning application for the house and it was not questioned.

[JohnMo]

18 minutes ago, ProDave said:

In Scotland the PD planning rules for ASHP's are different, it has to be something like 100 metres from a neighbours boundary to be PD which few would be able to achieve

 

Just double checked and from I can see that 100m condition only applies to free-standing micro wind turbine (MWT), as no such conditions apply to an ASHP.

 

The wording of the condition is "Limitations 6.18

For MWT, the limitations are that:

■ the installation of a MWT must be not

less than 100 metres from the curtilage of another dwelling.

 

[ProDave]

1 minute ago, JohnMo said:

 

Just double checked and from I can see that 100m condition only applies to free-standing micro wind turbine (MWT), as no such conditions apply to an ASHP.

 

The wording of the condition is "Limitations 6.18

For MWT, the limitations are that:

■ the installation of a MWT must be not

less than 100 metres from the curtilage of another dwelling.

 

Interesting.  When I was going through planning for the house and discussing finer details with the planning officer, it was her that said an ASHP is not PD unless you can meet the 100 metre rule and told me to add it to the planning application.  Of course one does not question that a planning officer has got it wrong so I dod not check.

[JohnMo]

The guidance was updated in 2021, so it may have changed 

guidance-householder-permitted-development-rights-updated-2021.pdf

[SimonD]

On 22/04/2023 at 19:47, JamesPa said:

I'm being deliberately provocative here to stimulate out of the box thinking, please bear with the explanation and numbers, but then feel free to critique. 

 

My view is that if we're going to be properly provocative with this question, we need to consider aspests that underpin the front end tech, which is unfortunately how the problem is typically viewed.

 

The first thing that needs to be considered is the reality that whilst a heatpump may be more efficient, it also requires significantly more natural resources to make and distribute. A single heat pump installation can require up to 120kg more steel and 40kg more copper, not to mention the other requirements for various components. Shifting all boiler installs over to heatpumps would put a huge demand on mining, processing etc. of raw materials. Currently, copper mining is in decline with an insufficient number of mines going through the planning phase to come online. There is both known and unknown environmental cost to this kind of proposal. There is also an economic one as raw materials are likely to become more expensive as opposed the the incorrectly assumed reduction in price due to volume.

 

The second is geopolitics. Chine currently controls the majority and with some materials enjoys the exclusive control of material processing for many of the materials required for heatpumps. We lost the ball on this one a couple of decades ago.

 

For me, heatpumps are a distraction to what really needs to happen, which is a fundamental change to how we consume both natural materials and energy.

 

The low hanging fruit of making homes more energy efficient has already been mentioned, as has behaviour change, awareness and education. The next step has to be a monumental shift in the systems in power - political, manufacturing, distribution etc. - as they've shown themselves to be incompetent in moving this forwards. In some ways, they've even gone backwards.

[SteamyTea]

23 minutes ago, SimonD said:

A single heat pump installation can require up to 120kg more steel and 40kg more copper, not to mention the other requirements for various components

Oh, the famous ''Up To".

 

Copper has an embodies CO_2e content of between 2 and 4 kg/kg.

Mineral Wool is around 1.2

Polyurethane around 4

Polystyrene around 3

 

So pick your insulation carefully as I suspect there is a greater tonnage of insulation in a typical UK house than there is a mass of heat pumps.

[JohnMo]

1 hour ago, SimonD said:

single heat pump installation can require up to 120kg more steel and 40kg more copper

@SteamyTea beat me to it, l got diverted to dog walking.

 

Why? Can require, doesn't mean it does.

 

I'm in the process of installing a heat pump, so far a couple of lengths of 28mm copper tube, a few fittings and a 3 way valve. Heat pump weight wet is 71kg, copper and steel are 100% recyclable, so at end of life can be turned into something else.