Received an email from Gemserve today, as most of you will with these attachments:
http://www.microgenerationcertification.org/images/MCS Shading 1 FINAL.pdf
http://www.microgenerationcertification.org/images/MCS Shading 2 FINAL.pdf
http://www.microgenerationcertification.org/images/FINAL FAQs for MIS 3002 3.1.pdf
Here is the reply I sent to Gemserve:
"I am sorry that you are persisting in your support of this deeply flawed procedure.
First and foremost, it ignores the very first rule of Safe Working at Height procedures that states
avoid work at height where you can. This takes precedence over any other consideration you may have within the MCS Guidelines. Failure to follow advice given under the Health & Safety at Work Act and the Work at Height Regulations 2005 can lead to very substantial fines. You state in on slide 33 of the first presentation there is no need to go on the roof, this being the case, why are you even promoting a methodology where in many cases this is the assumed course necessary to undertake a shading survey?
This means a different method of assessment will be used in which drawing a sunpath diagram is unnecessary as more accurate results will be obtained without it.
Our preferred method is 3D modelling in PVSol simulation software. Contrary to what is eroniously stated on slide 25 of the second presentation, it is a measurement method in its own right and considerably more accurate than the sunpath method. Having used this correctly, drawing a sunpath is a complete and utter waste of time. It is of no benefit to anyone except those attempting to defend a methodology over which there was no consultation during its development.
In using this method, we use the identical source of irradiance data as that for the MCS method. It should also be noted that there can be considerable variation within the defined regions set out in the MCS method. Accessing the PVGIS-SAF database by postcode gives a far more accurate dataset.
The software can cope with arrays located on different roof faces and at different inclinations. It can deal with the use of optimisers such as Solar Edge. To suggest modelling every single panel or string using the sunpath method is quite frankly laughable. Should we then present the prospective customer with 16 sunpath diagrams?
Those who intelligently use the software also use it to optimise panel position on the roof and also look at other design considerations to provide the customer with the best possible outcome. The software produces output estimations that are far more accurate including the percentage reduction due to shading. Why then waste time drawing a sunpath diagram to duplicate what is already shown?
Another couple of questions: How would you present a sunpath diagram to a prospective customer where you had suggested lopping the top of conifers in the garden and restricting their height to 6m? I note that within the presentations it states only shading objects within 10m of the array need to be considered. So a proposed south facing array on a single story building on the oppositie side of the street from a twenty story office block is OK?
It is a little cheap to have used 3D screen captures from PVSOL in the presentations to demonstrate the MCS which by comparison is clearly so deeply flawed.
Of vital importance the MCS method takes no account of the equipment specified. All it does is take account of panel location on a roof and possible shading objects. In theory if six companies assess a customers property, all propose the same location of panels of a similar size, all output estimates should be the same. How does the customer then differentiate between the six proposals? The only thing left is price. Is Gemserve really wishing to promote a race to the bottom encouraging installers to fit the cheapest and nastiest equipment?
Different combinations of equipment give different outputs. Some equipment is specifically designed to help mitigate the effects of shade. Different panels of the same rating have different outputs. Different inverters have differing efficiencies. None of this is taken into consideration in the MCS output estimation method. This is verging on farce.
By comparison, the draft MIS3001 standard for Solar Thermal will specifically require the specifications of proposed collector panels to be used in the output calculation, not the generic numbers given in SAP.
Some degree of shading is a fact of life. It doesn't mean an installation shouldn't go ahead, but should be fully accounted for, which is what we do in an intelligent and professional manner.
It should be noted that that MCS/ECA document is a guide. As such how can you justify making guidance mandatory? Guidance is about providing a framework of minimum standards which can be exceeded by those working with them should they so wish. It is not about preventing those wishing to exceed them from doing so. Your current approach is hardly professional. In all of the approach to this issue, you are tackling the effects, not the causes of poor installations and dissatisfied customers. Mis-selling is mis-selling, what ever the reason. A new output estimation procedure will not prevent it. MCS should be about promoting and encouraging best practice not forcing the better parts of the industry to dumb down and double up their processes because of problems elsewhere not being dealt with.
I would urge you to immediately drop your insistence on use of the MCS procedure if an organisation can demonstrate to their MCS assessor that they are using a method equal or better (and safer) to it.
I appreciate that two leading members of my own trade body gave a lot of time to compiling the new MCS/ECA guide, most of which is excellent. This however is one aspect that has fallen short. If I can help to take this forward to resolve the issue in a positive manner, I am happy to do so.
I look forward to hearing from you.
Regards"
I will post any response should I get one.