50 kw mcs limit

[noah]

Not asked directly as far as I know: does anyone know the mcs`s rationale for the 50 kw limit on  accreditation? It`s obviously illogical to require more  vigilance on 49kw than 51kw. Seems to be a pointless and arbitrary position, as the FIT rate is the same for 49 or 51.
I know that they are trying to up it which makes sense from their point of view.

[noah]

Before anyone else points it out the obvious answer is that projects 50kw and above could be expected to have a longer gestation and they don`t wish to discriminate against those already underway. However, they could have easily given an extra year or two or at least explained the position. Leaving it open is just senseless.

[A.L.]

Hello Noah,

Its the 'microgeneration certification scheme' - designed to protect the domestic market. People installing 50kw+ are deemed to be capable of looking after themselves.

[Ted]

The definition of 'microgeneration' comes from Section 82 of the Energy Act 2004 which, in part, says:

( 8 ) That capacity is–

(a) in relation to the generation of electricity, 50 kilowatts;

(b) in relation to the production of heat, 45 kilowatts thermal.

http://www.legislation.gov.uk/ukpga/2004/20/section/82

So MCS take their limits from this currently.

The question then becomes why did parliament take those figures and not any others?

This actually goes back to the implementation of ROCs and buyback schemes where 'small' generators were seen to need some alternative to the administrative hurdles that 'large' generators had to comply with, and that allowed 'amalgamation' of small generators figures. AFAIK 50kW was chosen for this limit on a fairly arbitrary basis. This is from the RIA for the Climate Change and Sustainable Energy Act 2006:

Sectors and groups affected
Small generators. These are generators who are defined as having a declared net capacity of 50kW and under.

Benefits
The changes which allow agents to act on behalf of generators should reduce administrative burdens on small and micro-generators, and provide them with the option of an easier route to obtaining the benefits of ROC eligibility. The additional change of allowing agents to amalgamate output will bring additional benefit to small generators whose output is very low or who would not normally be in a position to claim any or many ROCs. The proposals also have the potential to reduce administrative burdens on Ofgem over time. It is not intended that it will be a requirement for small generators to use an agent so where they wish to act for themselves they will still be able to do this.

The removal of sale and buyback agreements would also remove an administrative burden. There is also evidence that small generators find it difficult to obtain these agreements. Almost all respondents to the RO Review statutory consultation agreed that the sale and buyback requirement should be removed for small generators and all respondents who commented on the proposals in relation to agents supported the proposed change.

I believe that the argument that anyone installing a system under 50kW needs 'protection' and that people installing more than 50kW must be capable of looking after themselves is post facto.

[noah]

Thanks Ted
Arbitrary and post facto seem to be a good summary n'est-ce pas?
On that basis it would make slightly more sense if the break mirrored the tariff at 10 or 15kw.

[renewablejohn]

Hello Noah,

Its the 'microgeneration certification scheme' - designed to protect the domestic market. People installing 50kw+ are deemed to be capable of looking after themselves.

I am quite capable of looking after myself at 25kw never mind 50kw.

Historically on wind turbines anything less than 50kw was deemed small anything above being large. Now large starts at 500kw upto 5MW which is not a justification for raising MCS from 50kw to 500kw.

[Ted]

Checking back to earlier likely sources proved barren. The Energy White Paper of 2003 mentions 'micro-generation' and 'small' but without defining it. All the supporting papers barely mention small renewables. Micro-CHP featured extensively in discussions and was seen as the next big thing.

It is depressing to see how little distance we have managed to advance over the past 8 years or so.

http://webarchive.nationalarchives.gov.uk/tna/+/http://www.dti.gov.uk/files/file10719.pdf
http://webarchive.nationalarchives.gov.uk/+/http://www.berr.gov.uk/energy/whitepaper/2003/supporting-analysis/page21345.html

There is EU Directive 2004/8/EC which defines:

(m) ‘micro-cogeneration unit’ shall mean a cogeneration unit with a maximum capacity below 50 kWe;

but this Directive only refers to cogeneration and not electricity generation in general.

[Ted]

A bit more digging through Hansard shows that the definition changed sometime between the Energy Bill being debated in the House of Lords at the end of March 2004 (when '50 kW' was nowhere to be seen) and a government amendment introduced in the Commons in July 2004. I'll post the details later.

I shall try to find out more precisely what happened in the intervening period, when the Bill was being discussed in committee.

[renewablejohn]

There is EU Directive 2004/8/EC which defines:

(m) ‘micro-cogeneration unit’ shall mean a cogeneration unit with a maximum capacity below 50 kWe;

but this Directive only refers to cogeneration and not electricity generation in general.

Ted

I would not be surprised if this is the needle in the haystack. Its the typical one line which our wonderful statute writers pick up and use totally out of context.

[noah]

Ted, as usual, can be relied on to dig indefatigably. It will be intriguing to see if there is any logical basis for the 50kw cut off - or indeed any cut off. As far as I know, anything over 50va is considered potentially dangerous (not sure of this: I think there is a lower limit of electrical safety-a digital watch is unlikely to be dangerous even when worn in the bath).
Of course if you are a committee made up from industry whose commercial  interests would be well served by increasing subsidy to renewables a 50kw limit makes a lot of sense. It would stop 99.9% of DIY`ers who might be tempted to do the job themselves, perhaps even buying direct fron China (horrors!) but still enable the bigger installers to continue without any extra bureaucratic hassle.
But that sounds like a conspiracy, so it can`t be true.

In the  Lords debate (23/3/04) there is mention of `small generating stations- 50kw or less` when discussing aggregation for ROCs. 

[Ted]

Here is some of the detail I mentioned earlier.

1. Original wording in the Energy Bill 2004 - from House of Lords debate - 12th Feb 2004

   "new and renewable energy sources" mean sources of production of energy from or by means of—
         1. (a) wind power,
         2. (b) solar power,
         3. (c) ground source heat.
         4. (d) micro combined heat and power systems,
         5. (e) fuel cells, and
         6. (f) other low or zero carbon sources.
    "microgeneration" means generation of energy by means of equipment installed in single units of residential accommodation or office accommodation."

   http://hansard.millbanksystems.com/grand_committee_report/2004/feb/12/energy-bill-hl#S5LV0656P0_20040212_GCR_99
   
2. On 29th March 2004, in continued HoL debate, Lord Ezra moved amendment 195B which included a slightly revised definition:

   "new and renewable energy sources" means sources of production of energy from or by means of—

      1. (a) wind power,
      2. (b) solar power,
      3. (c) ground source heat,
      4. (d) micro combined heat and power systems,
      5. (e) micro hydro power, and
      6. (f) other low or zero carbon sources;
   "microgeneration" means generation of energy by means of equipment installed in, or for use by, a single unit or a small number of units of residential accommodation or office accommodation."

   Amendment 195B to the Bill was passed 106 to 87.
  
   http://hansard.millbanksystems.com/lords/2004/mar/29/energy-bill-hl-1#S5LV0659P0_20040329_HOL_343
  
3. On 13th July 2004, in the Commons, Stephen Timms (then Energy Minister) tabled Clause 4 which included the new definition:

(6) For the purposes of this section "microgeneration" means the use for the generation of electricity or the production of heat of any plant—
   1. (a) which in generating electricity or (as the case may be) producing heat. relies wholly or mainly on a source of energy or a technology mentioned in subsection (7); and
   2. (b) the capacity of which to generate electricity or (as the case may be) to produce heat does not exceed the capacity mentioned in subsection ( 8 ).

(7) Those sources of energy and technologies are—
   1. (a) biomass;
   2. (b) biofuels;
   3. (c) fuel cells;
   4. (d) photovoltaics;
   5. (e) water (including waves and tides);
   6. (f) wind:
   7. (g) solar power;
   8. (h) geothermal sources;
   9. (i) combined heat and power systems;
  10. (j) other sources of energy and technologies for the generation of electricity or the production of heat, the use of which would. in the opinion of the Secretary of State, cut emissions of greenhouse gases in Great Britain.

( 8 ) That capacity is—
   1. (a) in relation to the generation of electricity, 50 kilowatts;
   2. (b) in relation to the production of heat, 45 kilowatts thermal.

 
http://hansard.millbanksystems.com/commons/2004/jul/13/microgeneration#S6CV0423P1_20040713_HOC_202
  
Richard Page (Con, SW Herts) commented:

The definition of "micro-generation" in clause 129 applied to the generation of energy by means of equipment installed in or for use by a single unit or a small number of units of office or residential accommodation. To judge by the comments already made today, it seems that such a provision is basically welcomed and encouraged. The new definition in new clause 4 relies on the definition of specific sources or technologies of a set capacity, as set out in subsections (7) and ( 8 ).

Such an approach is much wider, and it might apply, or come to apply, to units of office or residential accommodation that are well above the size envisaged in the original clause. Is that a deliberate or accidental move? The Government have changed so much of the Bill that it would not surprise me if they wanted to make further changes. Either way, is the consequence that might flow from that approach desirable?

He received no reply.

Michael Weir (SNP, Angus) said:

I have already said that I support Government new clause 4, though I am slightly disappointed that its terms have been watered down. We debated an earlier draft in Committee, and I prefer the original wording.

The amended Clause 4 was added to the Bill.

Select Committee B
I've been through all the published debate from the Select Committee B, that sat in discussion of the Bill between 20th May 2004 and 22nd June 2004, and there is little mention of microgeneration. Microgeneration strategy was discussed on the afternoon of 17th June but the definition was not part of this.

http://www.publications.parliament.uk/pa/cm200304/cmstand/b/st040617/pm/40617s01.htm (hit the 'Continue' button at the bottom of the page to get to the next page)

As a side issue I noticed that the notions of net-metering and dynamic demand management were both discussed by the committee and both ideas thrown out.

[noah]

Silly aside: looking at some commons written answers at

http://www.theyworkforyou.com/wrans/?id=2010-02-01d.312473.h&s=%22microgeneration+certification%22+segment%3A20669956#g312473.q0

there is a link for chairman of MCS, Gideon Richards, which some wag has re-directed to the wiki page of John Holmes, porn star.

[knighty]

slightly off topic but slightly on topic too....

I recently heard that you have to be over 50kw to register for ROCs now....

I'd assumed I wouldn't be able to receive anything (fits or ROCs) for my CHP system.....

I'm building it anyway, and it *could* theoretically run at 50kw if I wanted it too.... so all I would need is permission from the DNO and I would be able to register it as 50kw and receive ROCs ?   (3phase connection, I'd probably have to pay for upgrades for 50kw, but it could be worth it?)


EDIT: on the application forms it does have separate boxes for the max power you can produce, and the max power you will export, I wonder if there's a gap there where it could be 50kw max production, but 10kw max export? - long shot but worth a try maybe!

[Ted]

CHP is only covered by FiTs for specific pilot systems up to 2kW. Everything else will be covered by ROCs assuming your fuel is acceptable. I think jotec here has registered.

[Ted]

This might be something of a red-herring, but who knows.

In 1943 (yes, really) the Hydro-Electric Development (Scotland) Bill was being debated in the House of Lords. There was a proposal that any private hydro system over 50 kilowatts should only be allowed with the express permission of the 'Electricity Commissioners'.

http://hansard.millbanksystems.com/commons/1943/jul/27/clause-22-control-of-new-private#S5CV0391P0_19430727_HOC_474

So anything up to 50kW was considered to be of a size that any private individual or company could install without the need for permission. Again the question is - why that size?

It seems that their Lordships considered that 50kW was a sufficient sized hydro turbine to power a house.

Lord Brocket says:

That brings me to Clause 22 where I see that an ordinary individual or a private company can put up a hydroelectric scheme of a rating up to 50 kilowatts. I am not an expert on electricity, but I am told that 50 kilowatts would supply a fair-sized house and perhaps the garage and steading.

http://hansard.millbanksystems.com/lords/1943/jun/09/hydro-electric-development-scotland-bill#column_980

Now 'a house' here clearly doesn't mean what we think of as a house. It is likely to be, given the context, a laird's house with a number of villager's houses included. Given the appliances available at the time 50kW would power a heck of a lot of light bulbs.

In any case this particular 50kW limit stood (through several later Acts that updated other parts) until changed under Section 4 of the Energy Act of 1983, when it was increased to 1MW, by which time other planning and environmental controls would restrict what individuals could do.

http://www.legislation.gov.uk/ukpga/1983/25/pdfs/ukpga_19830025_en.pdf

Unfortunately copies of the original and updated Acts haven't made it on to the internet.

Since 1943 "50 kW" has been used as a threshold for any number of different things, especially under ROCs as I originally mentioned, but this is the earliest reference I can find.