Gas boiler lobby obstructing heatpumps

[JohnMo]

If you read the press more people would be wanting rid of them due to the high running cost, fly tipping on your front garden would be more of an issue, than low life's taking them from you.

[Beelbeebub]

50 minutes ago, JohnMo said:

If you read the press more people would be wanting rid of them due to the high running cost, fly tipping on your front garden would be more of an issue, than low life's taking them from you.

Certain portions of the press!

 

 

[HughF]

A really interesting discussion, good work everyone 👍

[JamesPa]

Returning to the question of retaining existing dhw cylinders discussed upthread, para 5.6.7 of mis 3005-d might wipe that idea out.  It's ambiguous, but one reading says that, if the primaries to the retained cylinder aren't already insulated, then insulation needs to be fitted to the primaries.  This might involve accessing pipes under solid flooring that can't be lifted easily like carpet/floorboards can, together with all associated works on skirting and fittings, in some cases (including my own) adding thousands to the cost.

 

I have taken this up with the MCS helpdesk.  Their initial reaction was to confirm that this unreasonable interpretation was the correct one, but on further questioning admitted that they weren't actually sure and had escalated it to the technical team.  I am awaiting further feedback which I will post here.  If they confirm the unreasonable explanation then that's another nail in the coffin for a reasonably affordable ashp retrofit.  Let's hope they see sense!

 

Has anyone else queried this in the past?

[sharpener]

3 hours ago, Mike said:

Yes - they're more easily stolen:

https://www.homebuilding.co.uk/news/how-to-protect-your-heat-pump-from-theft

 

 

Fitting their fancy tracker will not help much, the toerags will quickly learn to recognise them, remove them and leave them on site behind a bush.

 

A spair pair in one of the interconnection cables could however easily be linked to a wired or wireless burglar alarm and it will then alert the entire neighbourhood at the time if the wires are disconnected or cut.

 

Better still one core in each of two cables. And/or linked to microswitches on the covers and inside the mains isolator.

[JohnMo]

57 minutes ago, JamesPa said:

retained cylinder aren't already insulated, then insulation needs to be fitted to the primaries. 

But as per relevant legislation and guidance - so as per BR.... If so I believe it's just the first metre to insulate of piping connected to the cylinder. I am sure someone will correct this if I am wrong.

[JamesPa]

1 hour ago, JohnMo said:

But as per relevant legislation and guidance - so as per BR.... If so I believe it's just the first metre to insulate of piping connected to the cylinder. I am sure someone will correct this if I am wrong.

Here is the quote from Part L  I have italicised what I believe is the relevant text.

 

4.24 In a new system, all of the following new pipework should be insulated.

a. Primary circulation pipes for heating circuits where they pass outside the heated living space, including where pipework passes into voids.

b. All primary circulation pipes for domestic hot water.

c. All pipes that are connected to hot water storage vessels, for at least 1m from the point at which they connect to the vessel.

d. All secondary circulation pipework.

 

I don't honestly think MCS have a scooby about how to write rules.  You need to think about all the use cases, wrinkles, ways around etc.  Its really difficult!   You also need to scrutinise any text you refer to and potentially update yours if that text changes.

 

That's why building regulations are drafted the way they are (short rules then illustrative guidance) and why people who write legislation are paid a lot.

Edited July 25, 2023 by JamesPa

[sharpener]

41 minutes ago, JamesPa said:

4.24 In a new system, all of the following new pipework should be insulated.

a. Primary circulation pipes for heating circuits where they pass outside the heated living space, including where pipework passes into voids.

b. All primary circulation pipes for domestic hot water.

c. All pipes that are connected to hot water storage vessels, for at least 1m from the point at which they connect to the vessel.

 

So "primary circulation" (rule b) seems to trump the "1 metre" bit (rule c).

 

All qualified by "In a new system". Does an old hw system incorporated into a new HP system become "new" or not @JamesPa ?

 

Personally I don't care about pipes that are within the thermal envelope, especially where they pass through the airing cupboard.

 

 

Edited July 25, 2023 by sharpener

[JamesPa]

 

14 minutes ago, sharpener said:

All qualified by "In a new system". Does an old hw system incorporated into a new HP system become "new" or not @JamesPa ?

 

 

In short, yes according to MCS (not according to building regulations):

 

From MIS 3005-I

 

From MCS Helpdesk

 

"Firstly, yes we can confirm ‘new’ installations means new installations in existing or new buildings.

 

The reason for the clause regarding upgrading the insulation on existing cylinders is to ensure heat loss is minimised via existing pipework and existing primary feeds to promote higher efficiency of heat pump systems. Due to the unknown condition of the existing insulation, we cannot assume that the insulation is adequate enough to meet the same standards as new installations. If we relied on the existing insulation, we pose the risk of poorly performing systems.

 

The difference between the first and second sentences is whether the existing insulation was factory fitted to Section 12 of BS 1566-1:2002 + A1:2011, rather than installed by the installer on-site and not compliant with the above standard. The reason the quality of the existing insulation can be satisfied by this sentence is that compliance with this standard provides enough evidence of higher quality insulation, in comparison to on-site installation.

 

If the insulation was not factory fitted to Section 12 of BS 1566-1:2022+A1:2011, we require the insulation to be upgraded to BS 5615:1985.

 

However, we appreciate your concerns on how this may cause major disruption with the need to lift flooring, but essentially, we cannot risk reducing system performance based on a lack of/poor existing insulation. I have fed your comments/concerns back to our technical working for comment as we are always looking to improve our standards in anyway we can. "

 

This says,at least in my reading, that the primaries must be upgraded.   I have called them, talked them through why this is utter madness, and have been told that the emails 'have been passed to the technical team'.  I think I am due a further response but, as it stands installers who do not replace the cylinder would be right to insist on upgrading insulation on primaries if it doesn't meet the latest standards, even if that means

 

• lifting and replacing 30sq m of Amtico (just a random example - not what I have, but perfectly plausible)
• removing and replacing skirting (and making good),
• removing and replacing fixed furniture (eg sanitary fittings) and
• relocating primaries in notched joists elesewhere so they can pass through using drilled holes (I cant see how you can insulate piped which are bang up against the floorboards).

 

all to insulate 5m of pipe.

 

14 minutes ago, sharpener said:

So "primary circulation" (rule b) seems to trump the "1 metre" bit (rule c).

 

 

Rule c applies to any other connected pipework (eg the feed to the taps!)

 

 

 

Edited July 25, 2023 by JamesPa

[HughF]

10 minutes ago, JamesPa said:

 

 

 

From MIS 3005-I

 

From MCS Helpdesk

 

"Firstly, yes we can confirm ‘new’ installations means new installations in existing or new buildings.

 

The reason for the clause regarding upgrading the insulation on existing cylinders is to ensure heat loss is minimised via existing pipework and existing primary feeds to promote higher efficiency of heat pump systems. Due to the unknown condition of the existing insulation, we cannot assume that the insulation is adequate enough to meet the same standards as new installations. If we relied on the existing insulation, we pose the risk of poorly performing systems.

 

The difference between the first and second sentences is whether the existing insulation was factory fitted to Section 12 of BS 1566-1:2002 + A1:2011, rather than installed by the installer on-site and not compliant with the above standard. The reason the quality of the existing insulation can be satisfied by this sentence is that compliance with this standard provides enough evidence of higher quality insulation, in comparison to on-site installation.

 

If the insulation was not factory fitted to Section 12 of BS 1566-1:2022+A1:2011, we require the insulation to be upgraded to BS 5615:1985.

 

However, we appreciate your concerns on how this may cause major disruption with the need to lift flooring, but essentially, we cannot risk reducing system performance based on a lack of/poor existing insulation. I have fed your comments/concerns back to our technical working for comment as we are always looking to improve our standards in anyway we can. "

 

This says that the primaries must be upgraded.   I have called them, talked them through why this is utter madness, and have been told that the emails 'have been passed to the technical team'.  I think I am due a further response but, as it stands installers who do not replace the cylinder would be right to insist on upgrading insulation on primaries if it doesn't meet the latest standards, even if that means lifting and replacing 30sq m of Amtico, removing and replacing skirting (and making good) and removing and replacing fixed furniture (eg sanitary fittings).

 

 

 

Rule c applies to any other connected pipework (eg the feed to the taps!

 

 

 

pre-insulated MLCP chucked in the floor void or rendered into the wall - job done 🤣

[JamesPa]

10 minutes ago, HughF said:

pre-insulated MLCP chucked in the floor void or rendered into the wall - job done 🤣

In a retrofit under flooring which cannot easily be lifted (amtico, solid wood etc) - absolutely no.  Several £1000s of additional cost to insulate a few m of pipe.  

Edited July 25, 2023 by JamesPa

[HughF]

4 minutes ago, JamesPa said:

In a retrofit under flooring which cannot easily be lifted (amtico, solid wood etc) - absolutely no.  Several 1000s of additional cost to insulate a few m of pipe.  

I'd just ignore the MCS rubbish, I expect that's what most people will end up doing. I feel their time is numbered anyway...

[JamesPa]

7 minutes ago, HughF said:

I'd just ignore the MCS rubbish, I expect that's what most people will end up doing. I feel their time is numbered anyway...

Its easy to say that but.. installation under permitted development rights requires MCS, and seeking express consent may lead to unachievable noise constraints (currently it does in my case albeit that I'm still fighting my LPA)

 

So not legally possible!

 

Doubtless some installers will ignore the stupider excesses of MCS, but many hide behind them.  The goal, remember, is 1.4M heat pumps retrofitted per year in the UK which we aren't going to get anywhere close to if installers are forced to do things, or can hide behind things, which are objective madness!

 

Is their time numbered- they seem to be the darlings of Government.  They are still involved in Solar Panels even though that's now an entirely mature technology.

 

 

 

 

 

Edited July 25, 2023 by JamesPa

[sharpener]

20 minutes ago, HughF said:

pre-insulated MLCP chucked in the floor void or rendered into the wall - job done 🤣

 

Only if it runs parallel to the first floor floor joists.

 

My experience with plumbers is they do not know, do not understand and do not comply with the quite strict rules about holes and notching.

 

I kept back a £500 retention until they produced a structural engineer's letter confirming that what they had done in contravention to the rules was acceptable, which never happened (they sent a span table for non-load-bearing ceiling joists which I rejected as irrelevant). Some of the £500 went on doubling the affected joists which I did myself.

 

The prime contractor was a loft conversion firm, and when a neighbour saw their site board outside he told me he had won a court case against them for £50k damages so I had got off lightly. Later they went bust - for a second time. I did not feel very guilty.

 

 

Edited July 25, 2023 by sharpener

[DougMLancs]

1 hour ago, JamesPa said:

Its easy to say that but.. installation under permitted development rights requires MCS, and seeking express consent may lead to unachievable noise constraints (currently it does in my case albeit that I'm still fighting my LPA)

 

So not legally possible!

 

Doubtless some installers will ignore the stupider excesses of MCS, but many hide behind them.  The goal, remember, is 1.4M heat pumps retrofitted per year in the UK which we aren't going to get anywhere close to if installers are forced to do things, or can hide behind things, which are objective madness!

 

Is their time numbered- they seem to be the darlings of Government.  They are still involved in Solar Panels even though that's now an entirely mature technology.

 

 

 

 

 

Codrina Cretu at NESTA UK is currently wanting situations where planning is holding back the heat pump rollout for a report they’re putting together to advocate changing the rules. I think she’d be very interested to hear what you’ve gone through. You can find her on Twitter or contact NESTA 

[JamesPa]

1 hour ago, DougMLancs said:

Codrina Cretu at NESTA UK is currently wanting situations where planning is holding back the heat pump rollout for a report they’re putting together to advocate changing the rules. I think she’d be very interested to hear what you’ve gone through. You can find her on Twitter or contact NESTA 

Thanks.  I have emailed NESTA

[HughF]

Unless you have nosy neighbours, just fit the thing and go to retrospective if anyone finds out/complains… which they won’t, unless you make a total nuisance of yourself 🤣

 

better to ask for forgiveness than permission…

 

my neighbour fitted his pellet boiler and then got retrospective, and he then fitted his ashp himself without planning or mcs. After the stink of his pellet boiler, no-one cared when he installed his ashp.

Edited July 26, 2023 by HughF

[JohnMo]

9 hours ago, HughF said:

Unless you have nosy neighbours, just fit the thing and go to retrospective if anyone finds out/complains… which they won’t, unless you make a total nuisance of yourself 🤣

 

better to ask for forgiveness than permission…

 

my neighbour fitted his pellet boiler and then got retrospective, and he then fitted his ashp himself without planning or mcs. After the stink of his pellet boiler, no-one cared when he installed his ashp.

Exactly - my thoughts also.

[JamesPa]

6 minutes ago, JohnMo said:

Exactly - my thoughts also.

I agree on a practical level. 

 

But its wrong in principle that people must expose themselves to the risk of being required by law to remove their source of heating because the industry and the government have made it impossible.  It's not that way for gas boilers, oil boilers or pellet burners.

[JohnMo]

1 minute ago, JamesPa said:

risk of being required by law to remove their source of heating

Love to see anyone win that case in court, man tries to save planet, court instructs him to remove your heating, and install oil or gas boiler which by then are banned.

[JamesPa]

Just now, JohnMo said:

Love to see anyone win that case in court, man tries to save planet, court instructs him to remove your heating, and install oil or gas boiler which by then are banned.

I'm also a inclined to agree with that, a point I have made to my planning department. 

 

But who wants the hassle, easier just to slap in a new gas boiler from the get go, which is also cheaper.  I can be bothered to fight the system which appears determined to ensure people do the wrong thing, most can't or won't.

[JamesPa]

On 25/07/2023 at 17:28, JamesPa said:

 

 

In short, yes according to MCS (not according to building regulations):

 

From MIS 3005-I

 

From MCS Helpdesk

 

"Firstly, yes we can confirm ‘new’ installations means new installations in existing or new buildings.

 

The reason for the clause regarding upgrading the insulation on existing cylinders is to ensure heat loss is minimised via existing pipework and existing primary feeds to promote higher efficiency of heat pump systems. Due to the unknown condition of the existing insulation, we cannot assume that the insulation is adequate enough to meet the same standards as new installations. If we relied on the existing insulation, we pose the risk of poorly performing systems.

 

The difference between the first and second sentences is whether the existing insulation was factory fitted to Section 12 of BS 1566-1:2002 + A1:2011, rather than installed by the installer on-site and not compliant with the above standard. The reason the quality of the existing insulation can be satisfied by this sentence is that compliance with this standard provides enough evidence of higher quality insulation, in comparison to on-site installation.

 

If the insulation was not factory fitted to Section 12 of BS 1566-1:2022+A1:2011, we require the insulation to be upgraded to BS 5615:1985.

 

However, we appreciate your concerns on how this may cause major disruption with the need to lift flooring, but essentially, we cannot risk reducing system performance based on a lack of/poor existing insulation. I have fed your comments/concerns back to our technical working for comment as we are always looking to improve our standards in anyway we can. "

 

This says,at least in my reading, that the primaries must be upgraded.   I have called them, talked them through why this is utter madness, and have been told that the emails 'have been passed to the technical team'.  I think I am due a further response but, as it stands installers who do not replace the cylinder would be right to insist on upgrading insulation on primaries if it doesn't meet the latest standards, even if that means

 

• lifting and replacing 30sq m of Amtico (just a random example - not what I have, but perfectly plausible)
• removing and replacing skirting (and making good),
• removing and replacing fixed furniture (eg sanitary fittings) and
• relocating primaries in notched joists elesewhere so they can pass through using drilled holes (I cant see how you can insulate piped which are bang up against the floorboards).

 

all to insulate 5m of pipe.

 

 

Rule c applies to any other connected pipework (eg the feed to the taps!)

 

 

 

Update on the above, for once good news.  MCS now accept that, where it is not reasonable to upgrade existing pipework to a retained DHW cylinder, and where Building regulations do not require it to be ungraded, MCS wont insist that they be upgraded.

 

Here is the email I received from MCS today:

 

"Thank you for your patience whilst I awaited a reply from our working group. As our working group is made up of volunteers, this is why it took some time to get a reply.

 

Firstly, thank you for highlighting the ambiguity of the clause around using existing cylinders . As part of 5.6.7 clause a), we mandate that the cylinder and pipes in an existing system are to comply with relevant legislation. Below is a screenshot of the relevant requirements under building regulations around the insulation of pipework:

 

[screenshot of regulations 4.24 and 4.25 in building regulation part L]

 

MCS mandate that the above building regulations are adhered to when using an existing system as the clause states that the insulation shall be upgraded to at least the equivalent of what’s stipulated in 4.24 in the building regulation requirements above. However, 4.24 above uses the word ‘should’ in which MCS use this term as “prescribes and requirement or procedure that is intended to be complied with unless reasonable justification can be given”. Therefore, if it is unreasonable to insulate all pipework (in this instance due to the significant disruption of lifting flooring), then that would be accepted under building regulations and therefore also by MCS. Reasonable attempts should be made to insulate all pipework, however, if this is not the case, then it would be expected that the contractor properly assesses the effects of this on the system performance and efficiency and advise the customer accordingly. 

As a response to this query, MCS will make the necessary changes to clause 5.6.7 a) with MIS 3005 D in the next rewrite to allow for clearer understanding. "

 

Thank you again for raising this

 

 

Edited August 1, 2023 by JamesPa

[JohnMo]

That all sounds reasonable.

[sharpener]

6 hours ago, JamesPa said:

As a response to this query, MCS will make the necessary changes to clause 5.6.7 a) with MIS 3005 D in the next rewrite to allow for clearer understanding. "

 

Well done for persisting @JamesPa, another small step in the right direction.

[JamesPa]

2 hours ago, sharpener said:

 

Well done for persisting @JamesPa, another small step in the right direction.

Now we need the manufacturers of HT heat pumps on board.  Daikin for example specify a min coil area of 1.1sq m both for their HT and LT models which makes zero sense.  I have yet to check others.  MCS requires installers to conform with any cylinder requirements specified by hp manufacturers.