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Author Topic: Correspondence re anti-competition aspects of the MCS/FITs tie-up.  (Read 91750 times)
Ivan
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« on: December 17, 2009, 03:21:40 PM »

This may be a little confusing, as we're picking up this correspondence in the middle. Stephen Tasker has written to Paul Rochdale of the DECC about the anti-competition nature of the MCS which is linked to FITs. The cost of approving equipment is astronomically high, and as far as we know no manufacturer (possibly with one exception) has registered a product. The testing process takes 12months, and of course, the DECC still have not announced their decision, so we still don't know if their proposals will be implemented. Any manufacturer wishing to be listed for MCS will need to carry out 12months testing, which means that manufacturers either gamble hundreds of thousands of pounds, or they wait until things are set in stone, in which case they spend hundreds of thousands of pounds and will have products registered in 1-2years time.....leaving customers unable to buy a turbine suitable for FITs.

The labour government in the UK clearly has no intention of promoting renewables in the UK. This unnecessary, unaffordable beaurocracy simply pours hard-earned money into quango coffers, pushing up the cost of renewables to a level where even with the FITs it will no longer be cost-effective. Clearly, they don't take their carbon emission reduction targets seriously.




Dear Paul

Thank you for your letter which I will make public on an open forum and invite comment from the industry

You will of course be welcome to join the Forum and reply

To reply to your specific comments

1)  We did provide clarification on a number of issues but unfortunately you do not appear to have taken some of these points on board.   

Will you please issue the minutes of the meeting at DECC
It is disappointing that these were not issued promptly for sign off
My position is that several things were said at the meeting which you actually find uncomfortable
I also note that at the end of the meeting you were threatening about "my saying things untrue"
In fact I have not said anything untrue - if I had you would have had a legal team on me

2) You have suggested that the majority of the UK small wind industry supports your views. However, this is not what we believe to be the case.

What efforts have you made to verify your view?
In our meeting I suggested that you engage a professional independent market research company to survey the market - you declined to do this

3) I note over the last few days that some stakeholders within the industry have emailed as part of what you call your MCS survey with a variety of concerns about feed-in-tariffs and MCS

To the best of my knowledge I have e mailed every stakeholder - a total of 1586 contacts on my database
If I have missed any stakeholder of who you are aware please forward my e mails and ask them to respond to me
I have referred to every response including 2 positive responses for installer accreditation
However, you point does reinforce my suggestion that the survey should have been done by an independent market research company commissioned by DECC

4) Your statements within the Survey were hardly unbiased and has lead to misleading information being sent to those you have surveyed, which is very unfortunate

Please reply stating clearly what I have said which is misleading and I will issue a correction

5) Your claim that BWEA has hardly any members from the small wind turbine industry  conflicts with what BWEA reports. The BWEA's small wind membership includes over 80 companies and is apparently growing every month. We understand that BWEA small wind group is the largest small wind trade association in Europe.

The BWEA has - by their own e mail

BWEA's small wind membership has grown from 30 companies in 2007 to over 80 companies in 2009 and includes the following (13) small wind manufacturers: Proven Energy (UK), Ampair (UK), Eclectic (UK), Marlec (UK), Evance/Iskra (UK), Renewable Devices (UK), Northern Power Systems (USA), Fortis (NL), SeaB (UK), Vertical Wind Energy (UK), Quietrevolution (UK), Nheolis (FR), Gendrive (UK);
Hence 13 small wind manufacturers of which 3 are overseas companies

There are more than 50 small wind manufacturers in the UK
The German Small Wind Association has more than 60 members
Can you please advise what initiatives you have taken to check the accuracy of BWEA information bearing in mind that the BWEA is a private commercial organisation

6) To suggest that we open the small wind market to manufactured products without proper verification that these products have at least met the standards set out in MCS would be a retrograde step for the small wind market

For you to write this demonstates that you have not understood my position
I repeat - my position is that every wind turbine product sold should be subject to conforming to a minimum safety standard
There is no logical reason for linking safety standards to FIT's
Nor is there any logical reason for allowing the sale of products not to a minimum safety standard

7) Turning to the testing process, you have suggested that predicting performance from the evidence of a single test site to a high degree of accuracy is fundamentally misleading to consumers and that all industry experts agree with that. Again, I do not understand how you can claim all industry experts have agreed that. It would be helpful if you provide evidence that can be considered by the MCS steering group and technical working groups on why you believe there to be a problem with predicting performance at a single site. This can then be discussed and commented on by people with! the relevant expertise. The Power Performance Standard is one that is used and recognised across the wind industry at large and I would therefore question whether all the multi-mega sized machines and their manufacturers are fundamentally wrong

Before a commercial wind farm is established there is always an in depth study of site conditions - which rather destroys your argument

 

Cool I am not in a position to comment specifically on the Gorran School incident but I can assure you that any learning in relation to this incident will be considered by the MCS steering group and technical working group. You, like other stakeholders, will have the opportunity to contribute to development of those standards through the appropriate channels

I am not asking you to comment on this specific incident
The question I am asking is if, in consideration of this, there is a reasonable question as to whether the standard is fit for purpose
If there are reasonable grounds for questioning the standard then do you consider it correct to force manufacturers to commit to an £80,000 test program in advance of a professional review and report on the standards?

9) You should be aware that the MCS Standards are based on and reference international standards, where they exist, which all  IEC member countries have embraced

I am aware of international standards
What I do not understand is why the UK have decided to selectively apply additional standards
I remain of the opnion that this is anti competitive
If additional standards were such a good idea - perhaps justified on safety grounds - then they would be applied to all wind turbines sold - not just those on FIT's

10) . The fact that the UK only has one commercial test site is not because of the MCS standards neither is this an argument for changing the standards.

You do not address my concern that the effective UK monopoly supplier was at least partially involved in setting the standards
Wll you please comment on this

11) You should be aware that MCS does allow (under MCS 011) any individual to undertake testing with the caveat that the testing meets EN 17025 or equivalent

Procedures. This option is being exercised by a number of manufacturers.
You stated that this option is being exercised by a number of manufacturers in our meeting
I subsequently checked this with UKAS who have advised that no UK company have applied for certification to EN 17025 with them which would be required to do this

I have also addressed this to you by seperate e mail - your reply remains pending

Will you please clarify the cost and tmescale for certification to EN 17025
I have been advised this would normally take in excess of 12 months and cost in excess of £1million
If you provide clear evidence that my information is wrong and of the actual timescale and costs I will be pleased to publish this

 

12)  I hope that you will see that there is every opportunity for you and other companies outside of BWEA to get involved in MCS

Again I request that you issue the minutes of our meeting
David Sharman  (Chair of the Technical Committee advising DECC) clearly stated that participation at the higher levels of the Technical Committee was by invitation and was conditional upon joining the BWEA

 

Summary

Please provide full and detailed answers to the questions raised which will also address the points in your annex

Ivan -I hope you will publish all on the forum including Paul's reply

Regards

Stephen
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Ivan
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« Reply #1 on: December 17, 2009, 03:41:56 PM »

Full text of the letter received from the DECC is here:

Dear Stephen,


Thank you for email of 8 December 2009 to Charles Hendry copied to Ed Miliband about the micro wind industry and certification of micro wind turbines. I have been asked to reply as Head of the Microgeneration Policy and Standards.

I note that you have sent a number of emails raising concerns about the small wind industry in the UK and requirements for product testing and certification of micro wind turbines under the Microgeneration Certification Scheme (MCS). We have also recently met to discuss at lengths these issues with representatives from the small wind industry and MCS. We did provide clarification on a number of issues but unfortunately you do not appear to have taken some of these points on board.   

I understand that you question, amongst other things, the MCS micro wind standards, testing and the associated costs, BWEA and the way it represents the industry and the appropriateness of TUV NEL’s test facilities.
I cannot comment specifically on your concerns about BWEA and TUV NEL but I understand that you have written separately to those organisations.  You have suggested that you may start an alternative trade association to BWEA to support small wind companies. As I have made clear, the Government works closely with all the trade associations and stakeholder groups in the microgeneration industry. Should you establish a new trade association, at that time, we will consider how best to work with the new organisation. 
 
You have suggested that the majority of the UK small wind industry supports your views. However, this is not what we believe to be the case. As far as we understand the majority of small wind manufacturers are supportive of MCS and have been actively involved in the development of the standards over the last three years. I note over the last few days that some stakeholders within the industry have emailed as part of what you call your MCS survey with a variety of concerns about feed-in-tariffs and MCS. Your statements within the Survey were hardly unbiased and has lead to misleading information being sent to those you have surveyed, which is very unfortunate.

 
Your claim that BWEA has hardly any members from the small wind turbine industry  conflicts with what BWEA reports. The BWEA's small wind membership includes over 80 companies and is apparently growing every month. We understand that BWEA small wind group is the largest small wind trade association in Europe.

To suggest that we open the small wind market to manufactured products without proper verification that these products have at least met the standards set out in MCS would be a retrograde step for the small wind market. We believe we need robust standards in place that are enforced through accredited test and certification bodies to protect consumers. In reference to MCS small wind standards applying to off grid products I can assure you that this is already the case.

Turning to the testing process, you have suggested that predicting performance from the evidence of a single test site to a high degree of accuracy is fundamentally misleading to consumers and that all industry experts agree with that. Again, I do not understand how you can claim all industry experts have agreed that. It would be helpful if you provide evidence that can be considered by the MCS steering group and technical working groups on why you believe there to be a problem with predicting performance at a single site. This can then be discussed and commented on by people with the relevant expertise. The Power Performance Standard is one that is used and recognised across the wind industry at large and I would therefore question whether all the multi-mega sized machines and their manufacturers are fundamentally wrong.

The UK small wind market is making good progress and I believe we are moving in the right direction. Others markets such as the US and Denmark are working towards similar levels of requirements to MCS. It would not therefore be wise to now dilute the standards and jeopardise the strong position the UK market is securing. We have always made clear that MCS standards will be kept under review and they will evolve over time in line with new innovations, changes to, or the adoption of, new European and international standards and, of course, changes to building regulations in the UK.

I am not in a position to comment specifically on the Gorran School incident but I can assure you that any learning in relation to this incident will be considered by the MCS steering group and technical working group. You, like other stakeholders, will have the opportunity to contribute to development of those standards through the appropriate channels. Contribution, however, should include sound technical arguments and, where possible, an evidential base. This has always been the case and will continue to be so. 

The cost of testing to the MCS wind standard will be challenging for some manufacturers. We are considering what more we can do to reduce these costs and the time it takes to complete testing without weakening the robustness of the MCS small wind standards. You should be aware that the MCS Standards are based on and reference international standards, where they exist, which all IEC member countries have embraced. The fact that the UK only has one commercial test site is not because of the MCS standards neither is this an argument for changing the standards. In fact, given your concerns about consumers’ safety, I would hope that you would support that position. You should be aware that MCS does allow (under MCS 011) any individual to undertake testing with the caveat that the testing meets EN 17025 or equivalent
Procedures. This option is being exercised by a number of manufacturers.

I have set out in Annex A some specific answers to issues you have raised. I hope that you will see that there is every opportunity for you and other companies outside of BWEA to get involved in MCS. I would ask that in future you provide specific questions and concerns about the MCS small wind standard to the MCS email link and these will be considered when the working group next meets in January 2010.


Yours sincerely



Paul Rochester
Head of Microgeneration Policy and Standards





















ANNEX A

1.Need for standard to accept multiple / independent braking systems:
As I understand there is not a small wind product standard in the world that currently requires multiple and independent brake mechanisms to shut turbines down. The current international standard does not make such a requirement, and the vast majority of all small wind systems manufactured today do not possess such engineering features. However, it is the stated intention of the MCS that standards are evolved and improved in the light of enlarged knowledge, new experiences, and any instance where the standards are demonstrated to be deficient. The incorporation of new requirements, for example that all certified product must possess multiple and independent braking mechanisms, is something that the MCS wind working group is always alert to and will consider on an ongoing basis. As international standards develop and change the MCS will look to incorporate their requirements.
  
2.BWEA membership fees providing a barrier to MCS decision making:
In contradiction to your previous suggestions, DECC notes that contribution to, and involvement with, the MCS Wind Working Group (the industry group responsible for agreeing MCS wind standards) is not constrained to BWEA members. Indeed some members of this group are outside BWEA membership but have the potential to contribute to the development of MCS Small wind standards. We have made this clear now on a number of occasions.
 
3.Power performance testing - use of single site/turbine
All UK industry experts support the MCS approach to testing wind turbine performance, which is based on the international wind product standard (IEC61400-12-1:2006) and has been peer reviewed by the international small wind community, as well as the large wind community. Evaluating a single unit is not fundamentally misleading. The turbine is production representative and its provenance is declared and recorded to ensure that this is the case. The approach to performance testing is appropriate, aligned with large wind best practice, and provides a level playing field. This approach also allows consumers to benchmark the claims made by the different companies as to the performance of their turbines.  MCS would welcome the provision of evidence supporting your views on power performance testing.
 
4.MCS accreditation is a barrier to product innovation and improvements in efficiency in a new emerging industry which is both characterised by and dependent upon product innovation for its future success.
MCS006 currently allows stated degrees of flexibility towards product innovation as stated within Section 8 of the BWEA Small Wind Turbine Performance and Safety Standard,which is available for free download from the BWEA site for BWEA and Non-BWEA members . Additionally I believe that there exist avenues to those involved in product testing to contact the Certification Body to consider particular aspects of product innovation and whether changes can be absorbed within the current testing and certification regime. With regard to this point, I would suggest that you speak to a Certification Body to establish what is possible.
 
5.It is completely unacceptable that the rules for MCS accreditation have been defined in such a way as to effectively create a monopoly supplier of test services charging £80,000.
As we have discussed, anyone is able to setup a EN17025 test site. A stated above the testing on that site must meet EN17025 or equivalent procedures. Additionally anyone is able to request that an accredited Certification Body deem a test organisation equivalent to an EN17025 (as is the case with BRE and NaREC). I do not accept the suggestion that MCS has created a "monopoly of test services". The fact we have one EN17025 accredited test organisation in the UK is not because of MCS. I believe that going forward we may see more sites coming on stream.

For your information the MCS annual administration fee is £350 for a single technology.  Products that are already tested via a EN17025 test lab (or other route discussed above) do not need to go through the process again, as the Certification Body will be able to verify the test data, thereby reducing the costs of Certification dramatically.

 
6.MCS does not have the support of the majority of the British small wind turbine industry but rather is the product of a small sub interest group.
MCS has the support of the vast majority of the UK small wind industry as an essential component to building a long term sustainable market in which the consumer is provided with the necessary levels of performance and safety assurance. Hymoto, and any other organisations are more than welcome to express their views to the MCS wind working group. This has been the case throughout the last three and a half years where the overwhelming consensus within the UK small wind industry has been one of support for the development of MCS wind standards to support the UK market.

We have continually stated that we would prefer companies to be represented by their trade association wherever possible to ensure that the views were industry wide, this does not mean only one body can represent the Small Wind Industry and therefore it has been stated at meets that any credible representative body would be welcomed. 

 
7.MCS is anti competitive to both foreign manufacturers and to the majority of British manufacturers.
In order to provide UK consumers with the necessary levels of performance and safety assurance, it is absolutely proper that a robust and adequate suite of standards are made available to the common market for microgeneration products. MCS is open to and accepting of views from any organisation active in the UK microgeneration sector. Indeed, MCS accepts input from numerous UK and foreign manufacturers in the development of product and installer standards across a range of technologies, including small wind. The overwhelming majority of the manufacturers active in the UK small wind sector are supportive of MCS and do not recognise it as an unnecessary barrier to trade.
 
We would suggest from the consumers view, MCS provides a level playing field where all products and their installations, are clearly explained in terms of performance and installed appropriately.  If this is not the case please provide factual evidence of where this has not happened and MCS, UKAS or REAL will investigate and take action as appropriate.


8.MCS standards and compliance to them
 There are potentially two situations which you appear to confuse. 
The first issue is about whether the standards are “fit for purpose” and the Working Group who develop the standards and the MCS Steering Group believe they are; however, if we find that they need amending, as stated above, this will be carried out. 

The second is about compliance and verification and auditing to the standards.  Compliance to the standards is for the companies to achieve; verification and auditing are for the Certification Bodies to carry out.  If there is factual evidence that either of these situations is not being appropriately adhered to, the Certified Company in the first instance, followed by the Certification Bodies and finally UKAS should be contacted to go through their complaints procedure.   
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Rob in Halstock
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« Reply #2 on: December 17, 2009, 05:49:54 PM »

linux

I have also experienced this problem obtaining planning permission for my own non MCS approved Wind Turbine. I had pre-empted the request from Mr Tasker, by writing to my MP the Rt Honerable Oliver Letwin. He took the matter up very quickely and wrote to Ed Millband (Enviroment Secretary) the following day after I sent my letter to Oliver. I am attaching a copy of Oliver's letter bellow. Oliver Letwin is a very big supporter of Wind Power and I am sure any correspondance from other members of the Navitron Forums would be more than welcome if sent. Please write to Oliver at this Email adress: GRAYEJ@parliament.uk


Letter from Oliver Letwin to Ed Milband


Secretary of State
Department for Energy and Climate Change
3 Whitehall Place
London SW1A 2AW


27th November 2009


Dear Ed,

I attach a copy of an e-mail that I have received from my constituent, Mr R M Gale.

I think that the information provided in this e-mail raises very important issues about the certification of micro wind turbines.

As you will see, Mr Gale suggests that the requirement for MCS approval is in effect acting as a non-tariff barrier and is raising the price of small wind installations dramatically.

This is clearly a serious problem which may have a profound effect on the amount of micro wind generation available in the UK following the introduction of feed-in tariffs.

Do let me know what you think might be done to deal with this problem and to enable cheaper machines which actually have acceptable noise characteristics to be imported more easily.

Yours ever,



OLIVER LETWIN


Encl.
« Last Edit: December 17, 2009, 05:54:25 PM by Rob in Halstock » Logged
Ted
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« Reply #3 on: December 17, 2009, 05:53:17 PM »

Interesting.  Can you say what the dates of these letters were, Ivan?

I assume Stephen has been though the BWEA response to the FITs consultation?

Quote
(3) Despite standards being accepted as fit for purpose and sufficiently
robust, the cost of testing wind products to MCS remains prohibitively
high in the context of current market size. BWEA maintains that UK
should mimic US, Irish, Australian, Spanish and other national
Governments in financially supporting small wind testing processes in
the short term, in order to jump start responsible and sustainable
market growth;
(4) The availability of small wind testing facilities (recognised as
acceptable under MCS) has been, and continues to be, limited. Only in
Q3 2009 did a small wind testing laboratory achieve EN17025
accreditation status for the first time;
(5) Testing small wind turbines in line with MCS requirements can take a
long time, potential up to nine months for Class 2 turbines, and even
longer for Class 1 turbines. This results in a significant lead time for
products between entering testing processes and completing
certification.
(6) It is broadly acknowledged that MCS recognised test facilities have
capacity limits for the testing of turbines. The number of turbines that
can be tested at any one time, or over a set period, may limit the
potential of manufacturers to test and certify products within current
FIT scheme timescales.

From http://www.bwea.com/pdf/091014_BWEA_Financial_Incentives_consultation.pdf

Is there sufficient funding to set up a separate EN17025 turbine test facility?
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Ivan
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« Reply #4 on: December 17, 2009, 09:10:20 PM »

Ted,

Sorry, not sure of the dates - all I can say is that they are very recent.

I don't know of any funding available to set up an independent testing facility, but I guess that the BRE would want their cut to accept it (inspection fees, auditing etc) and from experience they are very much less than helpful - we've been waiting since October for a response on some essential questions relating to our application, but they still haven't bothered to reply despite many follow-ups.

I'd more than happily follow up the idea, but I guess it would take 2 years or more to gain acceptance, and by that time, things will have moved on. What Stephen has been told regarding wind turbine testing is contradictory to what we were told (ie we were told that we could test the turbines ourselves, as long as the BRE inspected the testing site/procedures and agreed them). This was conveyed to us in a meeting, but I've not managed to get them to provide it in writing, and the only person in the BRE who can provide me with details of their expectations is not prepared to speak to me. I've given up and filed a complaint....
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« Reply #5 on: December 17, 2009, 10:27:12 PM »

I'm still a little confused.

ISO/IEC 17025 accreditation is simply a special form of ISO 9001  - specialised, that is, for labs and test facilities whereas 9001 is for anyone. It has nothing to do with wind turbines per se. I can't see why BRE would be involved at all. It is up to UKAS to give the award as I understand it.  Maybe BRE are involved in the IEC 61400 testing that BWEA require?

On a separate matter, I wonder how much government money has gone into TUV NEL via the NMS (which is funded by Department for BIS).
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« Reply #6 on: December 17, 2009, 11:06:09 PM »

Ted, Ivan, Re: dates of the correspondence, in the full letter you presented earlier it says: "Thank you for email of 8 December 2009 to Charles Hendry (...) "

Klaus  Cheesy

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« Reply #7 on: December 18, 2009, 09:42:12 AM »

Thanks Klaus, I had missed that.

The point I was thinking of re dates is that this correspondence came after the 15th October consultation cut-off date.
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« Reply #8 on: December 18, 2009, 12:27:37 PM »

I've come in half way through a conversation and am a bit lost.
I am a small designer and am finalising a design that should see 1KW for £200 and 2KW for £300 (DC)
This design will be released under Creative Commons so anyone can build it - including commercial interests
It will also be possible to use the design without planning permission!!
I am also designing a low cost grid connected inverter that should be around £150 plus  £50 per 0.5KW - this may be proprietary.


This should lead to power generation costs of around 3p/KWh  which will require no real financial incentive  for installation  but I don't want to be denied the market due to the blackmail outlined in the above posts.
Can someone enlighten me to the whereabouts of the consultation stuff is held so I can read it at source?
Tom
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« Reply #9 on: December 18, 2009, 01:39:33 PM »

Tom, I'm not clear exactly what you mean by "use the design without planning permission".  If you are the designer then you can do what you want with the copyright to the design itself include putting it in the public domain for free use.

But the erection of a wind turbine, technically in law, still requires planning permission, at least until the current proposals from DCLG are passed into law (for England only, Wales is trailing behind, Scotland I don't know). Some local authority planning departments have issued notices that certain renewables may be installed without the need for formal planning approval, but this varies across the country.

The MCS accreditation requirements for FITs is encapsulated in the DECC FITs consultation documents which can be found here:
http://www.decc.gov.uk/en/content/cms/consultations/elec_financial/elec_financial.aspx

This is the doc: http://www.decc.gov.uk/Media/viewfile.ashx?FilePath=Consultations\Renewable%20Electricity%20Financial%20Incentives\1_20090722165845_e_@@_ConsultationonRenewableElectricityFinancialIncentives2009.pdf&filetype=4

The proposal from DCLG for changes to permitted development to allow MCS accredited wind turbines without planning approval can be found here:
http://www.communities.gov.uk/publications/planningandbuilding/microgenelectriccars

This is the doc: http://www.communities.gov.uk/documents/planningandbuilding/pdf/microgenelectriccars.pdf
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« Reply #10 on: December 18, 2009, 01:46:16 PM »

Hi - Thanks to Navitron for allowing me to bring this subject to the attention of everyone interested on their forum. I am pleased to disclose my identity - Stephen Tasker of Hymoto and I declare an interest as a wind turbine manufacturer
My firm view is that there is a real opportunity for the industry to work together - it is government policy which is threatening to damage our industry and cost thousands of British jobs in this new industry
I have done a lot of work to ensure that the whole industry is aware of just what MCS means
My view
The UK small wind turbine industry is being asked to sign up to tests (the scope of which is not clearly defined and known), at an approximate cost of £80,000 (tests conducted by an effective monopoly supplier of testing services who was at least partially involved in setting the standards), testing to a standard which may not be fit for purpose and may need to be reviewed (UKAS asked to report and investigate) in order that the manufacturer's products may qualitfy for FIT's (not yet ratified)

( manufacturers required to sign up for a very expensive test program in advance of the confidence that FIT's will be ratified.)

If ok with Navitron I will use this Forum to post my correspondence
I have sent correspondence to the industry in general, to The Department of Energy and Climate Change (DECC) . UKAS (approve the certification bodies), Ed Milbank (Energy Minister), Charles Hendry (Shaddow Energy Minister), The Prime Ministers Office and The Micro Generation web site
Much of this correspondence remains unanswered - my view is this is "the club" closing ranks and answering criticism with silence
I will also post communications to the industry from The British Wind Energy Association - I am completely in favour of an open debate
I welcome communication from anyone - whether you agree with me or not - and I will post all reasonable (non legal) comments
Regards
Stephen 07712 841089
stephen@hymoto.co.uk
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« Reply #11 on: December 18, 2009, 01:55:37 PM »

The BWEA (British Wind Energy Association) are issuing a letter encouraging support for MCS

I have written to them offering to co operate - see below

LAST NIGHT
 Subject : Your Letter To The Industry
Date : Thu, 17 Dec 2009 20:32:00 +0000
Linked to : BWEA Alex Murley (Tim Yates)
From : Stephen Tasker <stephen@hymoto.co.uk>
To : BWEA Alex Murley <alex@bwea.com>
Cc : Adam Bruce <Adam.Bruce@mainstreamrp.com>; Adam Bruce <chairman@bwea.com>; Maria McCaffrey <maria@bwea.com>; Matt Partridge <Matt.Partridge@ecotricity.co.uk>; BWEA Chris Tomlinson <C.Tomlinson@bwea.com>; Rochester Paul \(DECC EEC\) <Paul.Rochester@decc.gsi.gov.uk>; Supria Daljit <Daljit.Supria@decc.gsi.gov.uk>; Ed Milband At DEC <ps.ed.miliband@decc.gsi.gov.uk>; Charles Hendry <hendryc@parliament.uk>

 
Dear Alex

I am disappointed that you have not copied me on your communication to the industry - you will agree that I have copied you and your collegues on every e mail I have sent out

However, regardless of this I would like to help you

Would you like me to send your letter to my entire database of small wind companies / installers and interested consumers (total 1586)

Please confirm if you would like me to do this

Also, for the record please advise the number of people on your database that you have sent this out to

Also for the record I note that my interest in MCS is only in relation to MCS accreditation for small wind turbines

I therefore suggest that soliciting the opinion of MCS certified installers and Clear Skies Companies who are not in the wind industry is completely irrelevant as due to the desperately poor communication they are unlikely to be aware of all facts - the typical first response "that can't be correct" - and then subsequent dismay to learn the true facts

Regards

Stephen

 

Good afternoon,

 

Please find attached a copy of a BWEA letter, detailing the support of the UK small wind sector for MCS.

 

Please urgently reply to this email providing the following:

 

(a) Your company's stated support for the letter (via email);

(b) Name, and business title of your company's identified representative (stated support of the CEO/Managing Director is preferable);

 

Please return your stated support as soon as possible. BWEA will be distributing this letter for wider support tomorrow afternoon, and likely to send to DECC early next week.

 

====================

BWEA intends to:

 

(1) Collect written support for co-signing the letter from BWEA members

(2) Collect written support for co-signing the letter from non-BWEA members (e.g. MCS Installers, Clearksies product companies)

(3) Openly send a finalised letter to the Department of Energy and Climate Change (DECC), containing the details (Name, Business title, Organisation) of all support.

(4) Publish a copy of the finalised letter on the BWEA small wind homepage.

====================

Background:

 

In recent weeks, a number of vocal criticisms have been made of the MCS. BWEA views that much of this criticism has been factually inaccurate, unsupported by evidence, and made without the best interest of the UK small wind sector at its centre. The BWEA small systems steering committee has considered the recent, ongoing and increasingly public criticism cannot continue without a public response, and now seeks to re-clarify the sector's overwealming support for MCS as a vehicle through the UK small wind market can grow in a sustainable and ethical fashion, where customer confidence, and industrial reputation, is upheld through the provision of consumer assurance on performance and safety.

 

BWEA invites you to offer your support to the attached letter - I look forward to hearing from you.

====================

 

Do call me if you would like to talk through this further.

 

Best regards,

 

Alex Murley

Head of Small-Systems | BWEA

AND AGAIN TODAY

Dear Alex

Further to my e mail of last night

I am very pleased that the BWEA (British Wind Energy Association) has decided to enter the MCS debate

I am also pleased to confirm that if you really can genuinely demonstrate the support of the majority of the small wind turbine industry (worldwide) for MCS then I will be pleased to back down

The hundreds of e mails which I have received over the last few days suggest a different opinion and I have found that many manufacturers of small wind turbines in the UK were not aware MCS at all

I have also found a significant discrepancy in the understanding of the scope of MCS testing between the information published on the Microgeneration web site and the information minuted at the meeting with DECC (Department of Energy and Climate Change) - attended by Paul Rochester (Minister), Alister MacKinnon (TUV NEL -the effective monopoly supplier of test services to the British Small Wind Turbine Industry) . Gideon Richards (Gemserv - administer MCS) and David Sharman (Chair of the Technical Committee). [I understand you were invited to attend this meeting]

At the meeting it was clearly minuted that the invertors were a part of the MCS testing but the Microgeneration web site states they are excluded

In your letter you state"In recent weeks, a number of vocal criticisms have been made of the MCS. BWEA views that much of this criticism has been factually inaccurate, unsupported by evidence, and made without the best interest of the UK small wind sector at its centre"

I would like to place on record that if any of the information I have distributed is factually incorrect then I will be pleased to issue a correction

I therefore invite you to supply me with a statement advising what is factually incorrect and I will be pleased to issue a correction

In your statement please detail very clearly what was incorrect and please explain in simple terms what the go forward position actually is

Please also detail in your statement why you think it it is a good idea linking a safety standard to FIT's (Feed in Tariff) rather than applying a safety standard to every wind turbine sold in the UK

For the record I remain of the opinion that the UK small wind turbine industry is being asked to sign up to tests (the scope of which is not clearly defined and known), at an approximate cost of £80,000 (tests conducted by an effective monopoly supplier of testing services who was at least partially involved in setting the standards), testing to a standard which may not be fit for purpose and may need to be reviewed (UKAS asked to report and investigate) in order that the manufacturer's products may qualitfy for FIT's (not yet ratified)

So manufacturers required to sign up for a very expensive test program in advance of the confidence that FIT's will be ratified.

As understood the MCS tests place additional requirements to agreed International Standards and therefore will exclude many European manufacturers whilst the high cost of the tests is a barrier to many small companies (both UK and overseas). From my own knowledge I am aware that some of these small companies are doing very innovative work which will increase power production and reduce costs so my opinion remains that by excluding these companies from the market the consumer is disadvantaged and also the government as it will make achieving the renewable energy target more unlikely

In Summary

I repeat my offer to correct any inaccurate information, to issue a clear simple statemement of the correct situation and to publish your alternative view explaining why, considering the facts as stated above, you remain of the opinion that MCS is in the best interests of the British Small wind industry

Regards

Stephen

BUT THE BWEA NEVER REPLY TO ME - BECAUSE "I'm Not A Member Of The Club"
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rhys
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« Reply #12 on: December 18, 2009, 01:57:56 PM »

It's not just Small Wind thats affected, the same applies to PV and it will to solar HW if there is a  FIT for that.
It's not only the requirement for MCS for Manufacturer's but even more outrageously for installers.
Building Control is all that is needed - part P all over again.  Gradually removing the Building Control option, as a way of ensuring quality.
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« Reply #13 on: December 18, 2009, 02:01:12 PM »

Hello and welcome Stephen! I'm really pleased that you've decided to join us on the forum, and I'm sure you'll find a lot of help and support from our members - I'm with you 100% on this, as are many others..... garden
« Last Edit: December 18, 2009, 02:04:29 PM by martin » Logged

Unpaid volunteer administrator and moderator (not employed by Navitron) - Views expressed are my own - curmudgeonly babyboomer! - http://www.farmco.co.uk
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« Reply #14 on: December 18, 2009, 02:16:13 PM »

To everyone who has been following my daily bulletins I can no longer send these out because "they" keep shutting down my e mail account -allegedly because of spam but we have successfully sent more e mails to customers of our bike business before
It would be cynical to suggest that big brother is watching .....and freedom of speach being restricted because I'm making people aware of factually correct information which makes the Government uncomfortable
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