The Future of MCS...

Worcester

Worcester

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Mentor
Spent the other day with one of our Heat Pump suppliers, their technical guy sits on the MCS steering group for Heatpumps.

The following points came out:

1) MCS is distancing from Decc and becoming a charitable organisation.

2) MCS is pushing that only MCS certified organisations will be allowed to install renewable energy solutions to be building regs compliant under a CPS.

Not sure whether this is a good or a bad thing....

With the potential demise of the RHI and FiT not to far away, there would be no reason for the existence of MCS..

Why couldn't or shouldn't the existing competent person scheme providers be able to certify organisations / people to be able to install the relevant technologies directly without all the bureaucratic input of MCS & RECC

The next Solar PV standard is being developed by outside of MCS, and there are other guides e.g the safety first one, the Heat Pump associations could take on the HP standards and BPEC / HETAS the biomass elements...

So does the continued existence of MCS beyond FiT and RHI have value?
What are your thoughts?
Jobs for the boys or an important standards body that adds value and improved security / quality / comfort (it'll work...) for the consumer?
 
Interesting topic. I think MCS may end up having a role similar to FENSA. Namely, issuing certificates to demonstrate compliance with building regs. I heard that DECC was expected to cull 90% of its workforce. Seats on the MCS steering committee surely await? Sadly, such technocrats rarely have experience of life in the real world outside Whitehall and certainly wouldn't have a clue how to operate a crimp tool or wire up an isolator.

I would prefer a slow demise rather than a sudden "rug-pulling" as we've seen in the past. The current degression mechanism seems to be working reasonably well with predictable bubbles of intensive work followed by relative inactivity. If we keep seeing 3.5% reductions, it will take a fair while to reach the point where FiT is worthless, especially if the export tariff rises annually. However, a 28% hyper-degression could be pretty painful to swallow.

OFGEM (or someone ) will still be needed to administer the MCS database as lots of people are on 20 or 25 year FiT contracts.

We haven't seen many hefty rises in utility costs recently but these will surely come. Many of the causes are outside our control but the effect may be to drive people towards renewables.
 
I can't see the 'only MCS for Bldg Regs compliance' ever being workable or generally acceptable.

Even now, with Part P, there is a process that allows a DIYer to do their own work.

It would require a pretty big re-think and re-write of the entire Building Regs regime, where currently doing certain things in certain ways are just given as examples of how the Bldg Regs may be complied with.

There's plenty of other useful jobs that the folks at MCS could be redeployed doing, such as ... er... er... nope, can't think of anything.
 
That was my comment to them, ie the current CPS schemes should be able to cope with it, definitely seemed to be a case of trying to justify their continued existence.
 
MCS should be like Gas Safe. The scheme is being overhauled to make it effective. With falls in equipment costs and reduction in FITs, PV could become attractive to the DIY brigade, so God help us.

If I was an insurance company, I would only cover your premises if the renewable technology had been installed by a MCS registered business working to what will be more robust standards of assessment.

If MCS had worked from day one as intended, there wouldn't even be this discussion. I am optimistic that the changes happening will mean it provides the levels of consumer protection, and customer assurance that were originally intended. It has a clear role due to the multidisiplinary nature of renewables installation - most are not a single trade.

The reason for it becoming a charity is to give it a legal entity which it currently does not have. It will actually be a company limited by guarantee, a common structure found in the third sector.

I am not sure whether it is DECC or Ofgem who are doing the distancing. Ofgem have consulted on MCS equivalence. Part of it may be the Government drive to remove 'red tape' regardless of the consequences for consumers.
 
I'm struggling to see exactly how MCS and the services that it currently provides would qualify as a charity.

To compare with Gas Safe, for example, while Gas Safe is a charity it contracts with Capita to provide the Gas Safe Register, which is a separate entity and not a charity. Capita presumably make a profit from this operation.

MCS, run by Gemserv, provide the equivalent of the Gas Safe Register at the moment AFAICS, and nothing more.

So a new charitable umbrella body would be needed to appoint Gemserv, or whoever, to run a register in a similar manner to this and to provide new and additional "benefits" to the general public by way of "charitable purposes" in the same vein as Gas Safe, whose listed purposes are:

The objects are to promote and support gas safety in order to advance health and save lives
by providing education in relation to gas safety and by promoting any purpose that is
charitable according to the laws of England and Wales and which furthers gas safety as
determined by the Trustees.
 
This is happening and interviews for the Trustees have already taken place. Its Memorandum and Articles of Association will set out its charitable purpose in the same way that Gas Safe does. I haven't seen these but assume they will be about promotion of the industry and consumer protection.

Within the structure of the new organisation there will be a trading company that delivers all non charitable activities and then remits any surplus to the charity as a donation. This is the standard structure under which the vast majority of charities, voluntary organisations, and other third sector bodies operate non charitable activities allowing them to meet the requirements of Charities Law in a way that is also tax efficient. Effectively it is seen as a form of fund raising.

Whether Gemserve remains contracted to run services and provide a secretariat is not something I have any information about.
 
I don't want to have a go at Gas Safe as I think they do a good job.

But on looking at their accounts I see that 100% of their annual income is from a 'donation' from Capita. Capita also provides 2 trustees on their board. Part of the expenditure of the charity is then a grant awarded to Capita to provide "educational services".

I can't really see how that set up can be construed as a "charity" in any real sense even though it presumably meets all the required definitions of the Charity Commission.
 
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Crossed posts with you Ted. As long as MCS or Gas Safe is a not for profit organisation with 'Mem and Arts' that meet the requirements of the Charites Act, this is the best kind of structure for these organisations, and is recognised in law as such.

HMRC are also satisfied with this, and would soon jump on anyone who abused it. It will mean MCS using any surpluses in the charity to further its charitable aims. This could be through funding research etc.

There are also regular audits by the Charities Commission to ensure compliance.
 
As I say, these set ups obviously meet the required charity guidelines or they wouldn't be allowed to continue.

But to my thinking all this is not 'charity' in the real sense of the word, where the government has a hand in setting up a quasi-monopoly situation that is then handed over to a charity to run, where a proportion of the income from a subsidiary, normal commercial endeavour is handed to the charity to pay for its administration.

Try reading through some of the gas legislation or guidance while replacing the word "gas" with "renewable electricity" and you will begin to see the size of the job of setting up MCS as a parallel organisation to Gas Safe.

http://www.legislation.gov.uk/uksi/1998/2451/made
http://www.hse.gov.uk/pubns/priced/l56.pdf

The 'back-end' legislation that Gas Safe sits on just doesn't exist for renewables. Maybe it should, but it is hard to see how MCS could be supported independently without it. Some of it does exist for "electricity" but, unless MCS are going to be in competition with NICEIC or NAPIT, then I can't see how that would work.
 
The current MCS structure is a bad joke. Hopefully they'll sort this out with the new revision, but frankly I'm sick of the entire thing and wish we could move into the above 50kWp market entirely so we could sack them off.

They're about to cede all industry accountability for the technical guidance for solar PV to IET without consultation as well.

Oh yeah, in case anyone wasn't aware, MCS are in the process of scrapping the current guide and moving across to the IET guide when it's implemented, something that wasn't made clear at the point when IET did their very brief consultation.

AFAIK there's been no impact assessment done on this change, in breach of the MCS change guidance, but none of that seems to really apply if certain key people determine that this is the way it should be.

So get ready for being forced to bond all your array frames to the MET on every job even isolating transformer inverters despite no evidence being presents about why this is needed, and if it is needed then what this means for the half a million + installations already carried out without being bonded.
 
solarsavings said:
One thing is certain.......................jobs for the boys.
Click to expand...

The position of Trustee is unpaid. All they will receive are expenses for travel and subsistence. (and I am not talking about an attendance allowance like the House of Lords).

There may be some new paid positions, but these are likely to be very part time.

It should be remembered that everyone who contributes to any of the working groups and other committees currently does so voluntarily, not even receiving travel expenses. The commitment of time and resources made by many to develop and implement product and installation standard has been huge. We would be stuffed without them. At best working group members may receive expenses in future in return for this commitment, hardly jobs for the boys.

I appear to be one of those odd people who support the aims and objectives of the scheme, believing the industry would be in a far worse position without it
 
Having dug through the rather vague and non-transparent Gas Safe set up a little more.

The HSE have accredited Capita Gas Registration and Ancillary Services Limited as the only gas engineer registration body. Others can apply to UKAS and HSE to perform an equivalent function but none have done so.

Capita Gas Registration and Ancillary Services Limited (a subsidiary of Capita plc) has a contract with Gas Safe Charity, the T&Cs of which do not seem to be public, other than it allows 2 employees of Capita to sit on the board of trustees of Gas Safe Charity.

The gas industry technical specs are produced by IGEM - the Institution of Gas Engineers and Managers - which is also a registered charity. Turnover approx £1.5 million.

Gas Safe Charity has an annual income of approx £250K, which is 90% contributed by a donation from Capita Gas Registration and Ancillary Services Limited and 10% from investment income.

Capita Gas Registration and Ancillary Services Limited has a turnover of just under £20 million.

So if this model is to be followed then:

- Gemserv will be appointed to act as the 'MCS register' for installers and products and issue certs as now, approved by UKAS and accredited by the HSE

- a new 'MCS' body will be created as a charity to support education in renewables and will be funded by a donation from Gemserv

- the IET will be responsible for producing all 'MCS' technical specs


Gemserv's 3 year contract with DECC to operate MCS runs out this October.
 
I'm looking at the whole renewables industry, not just PV, I agree that an oversight body would be a good thing, I'm strongly NOT convinced it should be MCS or any of the admin team that it has had in the past. I see little benefit that their existence has so far passed on to consumers.

The PV guides were there before (DTi) and will be after (IET), the standards for the other technologies are also there. (CIBSE Heating, Building Regs for combustion devices, etc....)

I can see the need for a body that indexes the standards, though not a need for a regulatory body, that surely is what the CPS schemes are about.

Note also that more than 10% of PAS2030 registered installers have been struck off!! (One in ten Green Deal companies 'struck off' for breaking the rules - Telegraph )

Other sources tell me that MCS has lost nearly 30% of it's membership through non-renewals. (Solar ONLY PV Installers is down to 1700, total number of all installers is 3500)

@The Solar King, sorry, I struggle to justify the continued existence of MCS.
 
TedM said:
- the IET will be responsible for producing all 'MCS' technical specs
Gemserv's 3 year contract with DECC to operate MCS runs out this October.
Click to expand...

Thanks TedM

The first part - as per my post crossed in the ether, it's more that just PV, so I guess others will also be involved.

The second, that's going to cause a nice mess, unless they issue a 6 month extension to get us to end of March 2016 :)
 
For most contributors to this site MCS may not be relevant because they work to required standards, understand the need for training and constantly strive to improve their operations. Sadly this is not true for many others in the industry. Correctly operated the Scheme should provide the necessary safeguards for consumers.

As far as standards are concerned, there is a great deal of interchangability on authorship of PV including new IET guide. Main mover behind both has been Martin Cotterall. Griff Thomas has also been involved in both. This is true of other standards. MCs has been the only route to providing comprehensive coverage of all aspects of installation. For this reason there will be a new non electrical PV guide.

Biggest problem with MCS in the past has not been the installation standards or product standards, but the silly paperwork systems surrounding the programme. The other issue has been the accreditation bodies implementing the scheme. They are the ones for whom this has been a dripping roast and in many ways have done much to discredit the programme through their actions. Perpetuating stuff that gives them the excuse to make money from checking non essential clerical procedures is nonsense.

Historically complaints about the scheme on this site have been about poor implementation and businesses not following basic standards in installation, then nothing being done about it.

Hopefully addressing these issues within a new structure will make the scheme relevant. It may seem ironic that other markets that don't have the equivalent of MCS see it as a major benefit.

As the saying goes you never miss your mother til she's dead and buried in the grave.
 
it'd be fine if MCS were some sort of gold standard, but it isn't.

At best it attempts to enforce mediocrity at least in the PV world.

Bad design, underperforming systems... no worries, we've got a get out clause to cover all those eventualities, as long as you've done an MCS shading assessment from the window below the roof, and most importantly you've got loads of stickers all over the place then everyone's happy. Except the customer.
 
Worcester said:
Spent the other day with one of our Heat Pump suppliers, their technical guy sits on the MCS steering group for Heatpumps.

The following points came out:

1) MCS is distancing from Decc and becoming a charitable organisation.

2) MCS is pushing that only MCS certified organisations will be allowed to install renewable energy solutions to be building regs compliant under a CPS.

Not sure whether this is a good or a bad thing....

With the potential demise of the RHI and FiT not to far away, there would be no reason for the existence of MCS..

Why couldn't or shouldn't the existing competent person scheme providers be able to certify organisations / people to be able to install the relevant technologies directly without all the bureaucratic input of MCS & RECC

The next Solar PV standard is being developed by outside of MCS, and there are other guides e.g the safety first one, the Heat Pump associations could take on the HP standards and BPEC / HETAS the biomass elements...

So does the continued existence of MCS beyond FiT and RHI have value?
What are your thoughts?
Jobs for the boys or an important standards body that adds value and improved security / quality / comfort (it'll work...) for the consumer?
Click to expand...

Looks like its started As previously announced the Microgeneration CertificationScheme (MCS) is in the process of establishing the MicrogenerationCertification Scheme Charitable Foundation (MCS CF). We are delighted toannounce that we have now appointed six Trustees to serve on the inauguralboard of the Charity.
 
So definitely about managing the money and processes so they can be 'seen' to operate as a charity, and not about the technology or market sector (industry).. Also though not stated, you can guarantee a certain level of personal contact/influence with politicians.

Does not bode well for the development of the industry. More regulation and rules to come.

This should be simplified not complicated, don;t see that happening tho with this move :(

HOWEVER, if they do achieve the 'regulatory' status as per gassafe for renewables, it MIGHT close out some of the cowboys..
 
can't help thinking that this should have been set up as more of a union / members organisation where we actually get to vote for our representatives.

but now, it's just another quango.
 
Gavin A said:
can't help thinking that this should have been set up as more of a union / members organisation where we actually get to vote for our representatives.

but now, it's just another quango.
Click to expand...

There is still that opportunity as the Legislation doesn't give MCS exclusivity - YET ... there can be another body set up

Perhaps the 3,556 MCS certified companies should each donate £100 to set it up :)

How many do you think would go along with it ...

They make shed loads more money out of the certificate registration fees than they do the membership..
 
There was nothing to stop anyone applying to be a trustee. Thought about it myself but decide I couldn't commit the time. If you didn't apply quit moaning about who was appointed. There are certain qualities, attributes and experience that are required for the role of trustee. What makes you think those appointed will be unable to successfully fulfil the required role?
 
Equally, there was adequate opportunity to become involved in discussion about the future framework of MCS. All you had to do was become involved. Please do not complain about those who bothered and committed their time if you didn't. You can't have it both ways. What evidence is there that a different structure would be more successful in delivering he required outcomes?
 
The Solar King said:
Equally, there was adequate opportunity to become involved in discussion about the future framework of MCS. All you had to do was become involved. Please do not complain about those who bothered and committed their time if you didn't. You can't have it both ways. What evidence is there that a different structure would be more successful in delivering he required outcomes?
Click to expand...

Depends upon how you define the outcomes, the gov'ts requirements are simple, however atm with three bodies involved - the CPS / Certification Bodies, MCS and RECC, yet NONE of them actually champion the consumer when it goes wrong... and name any publicity about anyone being struck off, or the phoenix companies, fold one, start another...

We are still seeing a debacle of over selling, I have one quote on my desk from a company showing me £70,000 in fuel savings over the next 20 years if I swap from Oil to a pellet boiler - My current oil bill is less than £1500 per year... and yet some people will be suckered in... I don't see that these changes will address the fundamental failings of the MCS scheme.

Strip it down, simplify it, use pre-published standards by other technical authorities, charge an appropriate fee for a certificate - it costs less than £3 to send in my building regs notices, and for other work, that includes insurance on my warranty..
 
The Solar King said:
There was nothing to stop anyone applying to be a trustee. Thought about it myself but decide I couldn't commit the time. If you didn't apply quit moaning about who was appointed. There are certain qualities, attributes and experience that are required for the role of trustee. What makes you think those appointed will be unable to successfully fulfil the required role?
Click to expand...

We are well aware of your very high opinion of.................................yourself and your dickie bow wearing pals.
 
The Solar King said:
There was nothing to stop anyone applying to be a trustee. Thought about it myself but decide I couldn't commit the time. If you didn't apply quit moaning about who was appointed. There are certain qualities, attributes and experience that are required for the role of trustee. What makes you think those appointed will be unable to successfully fulfil the required role?
Click to expand...
Here's the requirements from the advert

About the applicantWe are looking for individuals to steer and guide the charity through its initial establishment and implementation following successful registration. We are therefore looking specifically for individuals with skills and expertise in the following areas:

  • Strategy establishment and organisational development
  • Charity compliance and efficient operations
  • Operating at senior committee or board level
  • Grant giving
  • Consumer and environmental protection
Click to expand...
nothing in there at all about wanting anyone on the boards who knows anything even vaguely about renewable energy, so yes we could have applied, but as we'd mostly not have met that spec we'd not have got the role.

I'm not saying they shouldn't have had people on the board to cover the roles listed, but they definitely should also have people on the board to cover the roles relating to the actual remit of the charity, and the reason they don't is because they set it up that way, not because none of us applied.
 
This ties in with my experience; when I spoke to the IET (when they were drafting the standard) they were asking about MCS and why it should continue to exist beyond FIT. Many years ago Gryff Thomas talked me into joining MCS as it would be necessary as a CPS.
 
OK, So how many of us saw this and realised it's implications:

MCS Consultations: Certification Body Requirements Document

Microgeneration Certification Scheme - MCS Consultations: Certification Body Requirements Document

Despite their archivng it's difficult to find, also responses had to be in by 4th December.

So what?
Here's the crunch - MCS are proposing to massively up the number of inspection so that you could easily end up with multiple inspections per year - some of the larger installers would end up having one a fortnight!!!

The consultation included two direct questions applicable to microgeneration installers. The first concerns a new method of calculating the number of site inspections an installation business would be required to undergo (Q1). The second relates to a proposed cap on the number of site visits that would be required for larger organisations (Q4).

The new calculation method MCS are proposing could see surveillance visits rise from one a year, up to 20 a year, depending on the number of installations you carry out.

The consultation does not take into consideration the additional time and costs that would be incurred by the installers when determining the impact of the changes – which may be significant.

Nicely hidden whilst we're all busy, the document doesn't even appear on their 'archived consultations page, I can't find any links to it at all, so here's one:
http://www.microgenerationcertifica...ultation_and_Impact_Assessment_v1_0_FINAL.pdf
and the responce document (too late :( )
http://aemapi.spsend.com/Clicks?Lin...5e&Blast=880d1ebf-3a64-4192-b828-6a042aa38b11

If you're into renewable heat also check this out urgently : https://www.ofgem.gov.uk/sites/defa...ce_consultation_stage_2_v1_0_dec_2015_web.pdf
( Stage 2 consultation on MCS equivalence for the Domestic Renewable Heat Incentive Scheme )
 
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On top of all that, MCS have just gone out to tender for a compliance audit inspection service - they're proposing to spot check a significant number of installations themselves, key note - the owner of the system has to give approval for the inspection and they can decline.

Net effect, those owners not happy will agree (rightly so), however the inspection sample with therfore be heavily skewed to those with non compliances / poor workmanship, which will them trigger even more inspections based on the new proposals above... So penalising the good guys how are just trying to do their best.
 
I didn't see that, will check my emails to see if I got sent anything about it.

Not opposed to the principle of the visits, but am opposed to the costs being born by the companies. At over 100 installs those companies will have put in £3500 or so to MCS in fees, which MCS is making a big profit on, so MCS should front the costs from the existing fees.
 
If the inspectors want to come and actually scrutinise my installs then I'd be happy with 6 inspections a year. If I'm going to have the headache/charade of sorting my QMS document out every time then I'm going to be very annoyed indeed.

The industry could be improved many times over with a little bit of common sense. They should speak to a cross section of customers/visit a cross section of installs off their own back (none of this installer choosing nonsense) and poor installs/customer service should be struck off the list.

Our company has been going a long time now while many companies with impeccable QMSs have folded. Really, why is it anyone else's business how I run mine?
 
SolarCity said:
"Average cost per kW 2014 – seehttps://www.gov.uk/government/statistics/solar-pv-cost-data £2,101.00"

£2,100?![/QUOTE)

I wish! We are looking at a max price of £5000.00 for a 4kW system to make it work for the customer. Smaller systems will be more per kW as only equipment costs reduce. This figure may be true in SE England or true on a historic basis. Just as well it formed the basis of DECCs calculations.
Click to expand...
 

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Worcester

Worcester

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