DECC and MCS

[Ted]

Erich Scherer from DECC was the speaker at the conference on the Renewable Heat Incentive (RHI) that I attended yesterday. Part of the Q&A session covered MCS and his response was to the effect that DECC are required by the EU Renewables Directive to ensure that such a scheme is put in place and that the UK government, therefore, have no choice in the matter. This was news to me so I decided to look it up.

Here is the relevant part of the EU Directive (as far as I can see):

Article 14 - Information and training

3. Member States shall ensure that certification schemes or equivalent qualification schemes become or are available by 31 December 2012 for installers of small-scale biomass boilers and stoves, solar photovoltaic and solar thermal systems, shallow geothermal systems and heat pumps. Those schemes may take into account existing schemes and structures as appropriate, and shall be based on the criteria laid down in Annex IV. Each Member
State shall recognise certification awarded by other Member States in accordance with those criteria.

Annex IV then provides the details of certification requirements for installers.


There are a few important points worth noting here:

1. No mention whatsoever that the certification scheme has to cover products - only installers.

2. No mention of hydro or wind turbines.

3. No mention that FITs or RHI payments can only be linked to certified installations.

4. Solar Keymark is specifically mentioned in Annex IV 6.d - I wonder if this is why it was 'bolted-on' to the MCS eligibility criteria.


I shall be taking these points up with Erich Scherer of DECC directly.


Ref: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:EN:PDF

[djh]

Are other national certification schemes already in operation and are they more sensible?

I think article 14 doesn't deal with products because article 13 does! -

"Member States shall ensure that any national rules ... are proportionate and necessary."

"administrative procedures are streamlined and expedited at the appropriate administrative level;"

"rules governing authorisation, certification and licensing are objective, transparent, proportionate, do not discriminate between applicants"

and more relevant to RHI than FIT:

"In the case of heat pumps, Member States shall promote those that fulfil the minimum requirements of eco-labelling established in Commission Decision 2007/742/EC of 9 November 2007 establishing the ecological criteria for the award of the Community eco-label to electrically driven, gas driven or gas absorption heat pumps"

"In the case of solar thermal energy, Member States shall promote certified equipment and systems based on European standards where these exist, including eco-labels, energy labels and other technical reference systems established by the European standardisation bodies."

[Ted]

"promote certified equipment and systems based on European standards where these exist"

Well, MCS is quite specifically not a European standard. And nowhere does it say that standards have to be created if they don't already exist.

[wookey]

Classic tactic: 'The EU made us do it, we had no choice'. You will usually find that we enthusiastically promoted whatever 'it' is by way of the council of ministers. It provides convenient denyability.

As ever Ted gets to the nub of things. Well done for fishing out the relevant docs.

I noticed there was a DECC stand at ecobuild. I wanted to go and bend someone's ear about the MCS/DIY situation but everyone was busy so I missed the opportunity and of course there was so much to see I didn't get back. Not sure there would be anything but unempowered serfs on the stand though, so it may not have made much difference. More stiff letters are needed though. Get on it if you haven't written, or responded to RHI consultation.