New MCS Certificate

[Worcester]

Ofgem fully understood EXACTLY what was being said, as I put forward the idea of an east / west 2 x 2.5kW system as the example... They declined to give an answer though, and didn't "correct" Gemserv, despite being prompted to comment at least twice...

Also re my comment on cost of system above, I've just registered a new site on the database, and the instructions tell you to put 0.00 in for the price untill they have clarification of what DECC want it for

 

[Gavin A]

My discussions with the head of the MCS unit at gemserv were unambiguous and very concise.

If you install an inverter capped at 16A then the TIC = 3.68kW irrespective of the kWp of the panels.


The SSEG is the inverter (that's what has to be installed to G83 / G59 etc) the panels are purely the power source, in the same way that a pile of coal is for a coal fired power station.

unless you have that in writing it's meaningless.

I have it in writing from the head of the renewables section at Ofgem that they do not accept this is the case, and were instructing Gemserve to that effect.

Cost me about a grand in refunds, and £2.5k in legal fees as well did that dispute before we were forced to give up challenging them.

 

[Gavin A]

Though it's very interesting that you've had that opinion verbally from MCS in that setting. I might go back to Ofgem with that statement and see if they've changed their position again.

 

[BruceB]

I have it in writing from the head of the renewables section at Ofgem that they do not accept this is the case, and were instructing Gemserve to that effect.

Although OFGEM have said that to you, both OFGEM and Gemserve in their formally published guidance to date have been quite careful not to contradict the legislation as I interpret it (ie the same way as Worcester). Gemserve are just a commercial company providing a service and will be quite careful to make sure they do not do anything that will leave them liable downstream. OFGEM I regret are a) covering their arris not wanting to admit a mistake they have made in interpreting the legislation and hoping the issue will go away and b) probably think they are doing the right thing minimising solar pv fit payments after all the initial furore even if that is not what the legislation says nor what they have formally been instructed to do.

 

[matt25]

Also relates to Part A - be careful with your response, not all MCS certification bodies are equal ...

CPS = Competent Persons Scheme.

Thank you, so basically its registered with a CPS when we register the part p cert on the nic website?

 

[Gavin A]

Although OFGEM have said that to you, both OFGEM and Gemserve in their formally published guidance to date have been quite careful not to contradict the legislation as I interpret it (ie the same way as Worcester). Gemserve are just a commercial company providing a service and will be quite careful to make sure they do not do anything that will leave them liable downstream. OFGEM I regret are a) covering their arris not wanting to admit a mistake they have made in interpreting the legislation and hoping the issue will go away and b) probably think they are doing the right thing minimising solar pv fit payments after all the initial furore even if that is not what the legislation says nor what they have formally been instructed to do.

ah, but they have covered themselves in the guidance, as it says something about getting confirmation from Ofgem about it - so unless anyone's got written confirmation from Ofgem that this is allowed in the way they're interpreting it for solar PV, then it's fairly meaningless unfortunately if Ofgem get involved at a later stage.

As I say, unless anyone has this in writing from Ofgem, then anything that may have been discussed verbally counts for precisely nothing in Ofgem's eyes.

 

[Worcester]

These are the LEGAL definitions as published by the Government:

from here: https://www.gov.uk/government/uploa...file/65653/6778-fits-modifications-4-2012.pdf
being the latest legislation

“Total Installed Capacity” means the maximum capacity at which an Eligible Installation could be operated for a sustained period without causing damage to it (assuming the Eligible Lowcarbon Energy Source was available to it without interruption), a declaration of which is submitted as part of the processes of ROO-FIT Accreditation and MCScertified Registration;

“Declared Net Capacity” means the maximum capacity at which the installation can be operated for a sustained period without causing damage to it (assuming the source of power used by it to generate electricity was available to it without interruption) less the amount of electricity that is consumed by the plant;

Solar panles are simply the low energy carbon source.

You need to refer to the inverter manual to establish the "maximum capacity at which an Eligible Installation could be operated for a sustained period without causing damage to it"

Of course there is a bit of a **** up here, as the inveter isn't specified or registered on the MCS certificate, and for some reason or other it is the panels that are .....

With an AD plant, you don't have to get your maize crop or waste veggy mater certified to MCS standards ... Its the device that converts the methane into electrciity that is certified and rated ....

So if you have 3Kwp of MCS certified Solar PV panels hooked up to an SMA 5000-TL your TIC should be 4.6kW
and if you have 5kWp hooked up to a Power-one PVI-3.6 then your TIC will be 3.68kW

I can find no-where in writing that TIC relates to panels - GavinA would you crae to share your written sources / guidance document please?

 

[Gavin A]

worcester - I agree with all of that, and have expensive legal opinion that also agrees with it. Unfortunately, when it came down to it, Ofgem refused to comply with the legislation or their guidance, and instead asserted that DNC, TNC referred to the panels only, and essentially dared us to take them to judicial review to prove them wrong.

if you're going to work on that basis I'd seriously advise you to make sure you always have £10k+ in an account that you're willing to use only to cover the basic costs of judicial review to prove your point, if not then it could come back to haunt you.

I eventually wasn't able to challenge it due to financial constraints, and had to give it up, remove a panel and compensate our customer for the difference as it was cheaper than taking Ofgem to court.

 

[Gavin A]

pm me your email addy, and I'll email you copies of some of the correspondence

 

[jsn999]

I have not completed one since they changed the MCS form.

Can anyone tell me whether the new form includes a section whereby each installation must include building regs from the local council?

Thanks

 

[Worcester]

It asks how you are complying with Building Regs. Irony Part P isn't needed for our typical commercial installtions, as it's covered under the Electricity at Work Act

Seems like the new MCS resgistration process assumes domestic work ...