To my mind this MCS clause is unjust and anti-comeptitive. I wonder if there is some way to launch a legal challenge? The StBC PV system would makre a good test case..
Well you could try or just save your money. There is no way that the FITs system will start without some sort of accreditation. MCS exists therefore it is, to paraphrase Descart.
The following is from the Consultation Doc...
Small generators
3.63 For microgenerators and others where systems exist we intend to make
maximum use of third-party certification to minimise the administrative and
compliance burden. The Microgeneration Certification Scheme (MCS) is an
independent certification scheme accredited by the United Kingdom Accreditation
Service (UKAS), which assesses installer companies and products against robust
standards. It enables the provision of accurate forecasts of energy outputs to
generators as well as a level of consumer protection which meets the Office of
Fair Trading requirements. In addition, MCS gives assurances about the likely
quality, durability and performance of installations.
3.64 MCS, which is industry-led, is capable of providing independent assurance and
legitimacy to small-scale onsite energy installations. As such, it is the basis for
eligibility for grants under the Low Carbon Buildings Programme and CERT.
3.65 Given the establishment of the MCS as the only formalised industry standard in
the UK based on European and international standards, and that it has been used
as the basis of existing Government support programmes, it would be beneficial
to continue to use it for installations up to the capacity limit to which it applies
(currently 50kW). Therefore, we propose that the MCS or an equivalent scheme29
has a role to play in the accreditation and registration of installations where that
scheme applies.
and ...
Consumer protection
3.76 If FITs are to lead to greater participation in electricity generation by households,
communities and other non-expert generators, the systems, as well as being
simple, need to deliver confidence to generators that their rights in the market will
be protected and they will not be subject to exploitation.
3.77 We propose that the interests of generators – especially households – will be
protected by a range of arrangements. These include systems that are specific to
FITs and energy markets, as well as general competition and consumer
legislation.
3.78 In the case of installation, we propose using the MCS to provide consumers with
assurance about the quality of the product they are buying – that it will generate a
certain amount under certain conditions and be operational for a certain length of
time.
and ....
Auditing, assurance and enforcement
3.124 The organisations involved in the delivery and administration of FITs (the licensed
electricity suppliers, Ofgem, Elexon and, through the MCS, Gemserv) have
existing governance, audit and assurance procedures in place, some of which will
be suitable for use on FITs.
3.125 Therefore, as a general principle, where existing procedures exist, such as those
used for the RO, we will look to use these audit and assurance procedures.
We will work with the relevant organisations to ensure that the powers and
procedures in place provide the assurance we need to help achieve the following:
• Only eligible and accredited installations claim FITs;
• FITs installations only receive the tariff for which they are eligible;
• Information provided by generators is accurate and there are suitable checks in
place to prevent fraud; and
• Information provided by suppliers as part of the levelisation process is accurate
and timely.
3.126 The procedures in place to achieve these objectives are to include automated
checks, and ad hoc and scheduled audits and assessments.
Sorry about the formatting but it is copied from a PDF doc.
Simon
