The Future of MCS...

[Worcester]

Spent the other day with one of our Heat Pump suppliers, their technical guy sits on the MCS steering group for Heatpumps.

The following points came out:

1) MCS is distancing from Decc and becoming a charitable organisation.

2) MCS is pushing that only MCS certified organisations will be allowed to install renewable energy solutions to be building regs compliant under a CPS.

Not sure whether this is a good or a bad thing....

With the potential demise of the RHI and FiT not to far away, there would be no reason for the existence of MCS..

Why couldn't or shouldn't the existing competent person scheme providers be able to certify organisations / people to be able to install the relevant technologies directly without all the bureaucratic input of MCS & RECC

The next Solar PV standard is being developed by outside of MCS, and there are other guides e.g the safety first one, the Heat Pump associations could take on the HP standards and BPEC / HETAS the biomass elements...

So does the continued existence of MCS beyond FiT and RHI have value?
What are your thoughts?
Jobs for the boys or an important standards body that adds value and improved security / quality / comfort (it'll work...) for the consumer?

 

[whinmoor]

Interesting topic. I think MCS may end up having a role similar to FENSA. Namely, issuing certificates to demonstrate compliance with building regs. I heard that DECC was expected to cull 90% of its workforce. Seats on the MCS steering committee surely await? Sadly, such technocrats rarely have experience of life in the real world outside Whitehall and certainly wouldn't have a clue how to operate a crimp tool or wire up an isolator.

I would prefer a slow demise rather than a sudden "rug-pulling" as we've seen in the past. The current degression mechanism seems to be working reasonably well with predictable bubbles of intensive work followed by relative inactivity. If we keep seeing 3.5% reductions, it will take a fair while to reach the point where FiT is worthless, especially if the export tariff rises annually. However, a 28% hyper-degression could be pretty painful to swallow.

OFGEM (or someone ) will still be needed to administer the MCS database as lots of people are on 20 or 25 year FiT contracts.

We haven't seen many hefty rises in utility costs recently but these will surely come. Many of the causes are outside our control but the effect may be to drive people towards renewables.

 

[TedM]

I can't see the 'only MCS for Bldg Regs compliance' ever being workable or generally acceptable.

Even now, with Part P, there is a process that allows a DIYer to do their own work.

It would require a pretty big re-think and re-write of the entire Building Regs regime, where currently doing certain things in certain ways are just given as examples of how the Bldg Regs may be complied with.

There's plenty of other useful jobs that the folks at MCS could be redeployed doing, such as ... er... er... nope, can't think of anything.

 

[Worcester]

That was my comment to them, ie the current CPS schemes should be able to cope with it, definitely seemed to be a case of trying to justify their continued existence.

 

[The Solar King]

MCS should be like Gas Safe. The scheme is being overhauled to make it effective. With falls in equipment costs and reduction in FITs, PV could become attractive to the DIY brigade, so God help us.

If I was an insurance company, I would only cover your premises if the renewable technology had been installed by a MCS registered business working to what will be more robust standards of assessment.

If MCS had worked from day one as intended, there wouldn't even be this discussion. I am optimistic that the changes happening will mean it provides the levels of consumer protection, and customer assurance that were originally intended. It has a clear role due to the multidisiplinary nature of renewables installation - most are not a single trade.

The reason for it becoming a charity is to give it a legal entity which it currently does not have. It will actually be a company limited by guarantee, a common structure found in the third sector.

I am not sure whether it is DECC or Ofgem who are doing the distancing. Ofgem have consulted on MCS equivalence. Part of it may be the Government drive to remove 'red tape' regardless of the consequences for consumers.

 

[TedM]

I'm struggling to see exactly how MCS and the services that it currently provides would qualify as a charity.

To compare with Gas Safe, for example, while Gas Safe is a charity it contracts with Capita to provide the Gas Safe Register, which is a separate entity and not a charity. Capita presumably make a profit from this operation.

MCS, run by Gemserv, provide the equivalent of the Gas Safe Register at the moment AFAICS, and nothing more.

So a new charitable umbrella body would be needed to appoint Gemserv, or whoever, to run a register in a similar manner to this and to provide new and additional "benefits" to the general public by way of "charitable purposes" in the same vein as Gas Safe, whose listed purposes are:

The objects are to promote and support gas safety in order to advance health and save lives
by providing education in relation to gas safety and by promoting any purpose that is
charitable according to the laws of England and Wales and which furthers gas safety as
determined by the Trustees.

 

[The Solar King]

This is happening and interviews for the Trustees have already taken place. Its Memorandum and Articles of Association will set out its charitable purpose in the same way that Gas Safe does. I haven't seen these but assume they will be about promotion of the industry and consumer protection.

Within the structure of the new organisation there will be a trading company that delivers all non charitable activities and then remits any surplus to the charity as a donation. This is the standard structure under which the vast majority of charities, voluntary organisations, and other third sector bodies operate non charitable activities allowing them to meet the requirements of Charities Law in a way that is also tax efficient. Effectively it is seen as a form of fund raising.

Whether Gemserve remains contracted to run services and provide a secretariat is not something I have any information about.

 

[TedM]

I don't want to have a go at Gas Safe as I think they do a good job.

But on looking at their accounts I see that 100% of their annual income is from a 'donation' from Capita. Capita also provides 2 trustees on their board. Part of the expenditure of the charity is then a grant awarded to Capita to provide "educational services".

I can't really see how that set up can be construed as a "charity" in any real sense even though it presumably meets all the required definitions of the Charity Commission.

 

[The Solar King]

Crossed posts with you Ted. As long as MCS or Gas Safe is a not for profit organisation with 'Mem and Arts' that meet the requirements of the Charites Act, this is the best kind of structure for these organisations, and is recognised in law as such.

HMRC are also satisfied with this, and would soon jump on anyone who abused it. It will mean MCS using any surpluses in the charity to further its charitable aims. This could be through funding research etc.

There are also regular audits by the Charities Commission to ensure compliance.

 

[TedM]

As I say, these set ups obviously meet the required charity guidelines or they wouldn't be allowed to continue.

But to my thinking all this is not 'charity' in the real sense of the word, where the government has a hand in setting up a quasi-monopoly situation that is then handed over to a charity to run, where a proportion of the income from a subsidiary, normal commercial endeavour is handed to the charity to pay for its administration.

Try reading through some of the gas legislation or guidance while replacing the word "gas" with "renewable electricity" and you will begin to see the size of the job of setting up MCS as a parallel organisation to Gas Safe.

http://www.legislation.gov.uk/uksi/1998/2451/made
http://www.hse.gov.uk/pubns/priced/l56.pdf

The 'back-end' legislation that Gas Safe sits on just doesn't exist for renewables. Maybe it should, but it is hard to see how MCS could be supported independently without it. Some of it does exist for "electricity" but, unless MCS are going to be in competition with NICEIC or NAPIT, then I can't see how that would work.

 

[Gavin A]

The current MCS structure is a bad joke. Hopefully they'll sort this out with the new revision, but frankly I'm sick of the entire thing and wish we could move into the above 50kWp market entirely so we could sack them off.

They're about to cede all industry accountability for the technical guidance for solar PV to IET without consultation as well.

Oh yeah, in case anyone wasn't aware, MCS are in the process of scrapping the current guide and moving across to the IET guide when it's implemented, something that wasn't made clear at the point when IET did their very brief consultation.

AFAIK there's been no impact assessment done on this change, in breach of the MCS change guidance, but none of that seems to really apply if certain key people determine that this is the way it should be.

So get ready for being forced to bond all your array frames to the MET on every job even isolating transformer inverters despite no evidence being presents about why this is needed, and if it is needed then what this means for the half a million + installations already carried out without being bonded.

 

[solarsavings]

One thing is certain.......................jobs for the boys.

 

[The Solar King]

One thing is certain.......................jobs for the boys.

The position of Trustee is unpaid. All they will receive are expenses for travel and subsistence. (and I am not talking about an attendance allowance like the House of Lords).

There may be some new paid positions, but these are likely to be very part time.

It should be remembered that everyone who contributes to any of the working groups and other committees currently does so voluntarily, not even receiving travel expenses. The commitment of time and resources made by many to develop and implement product and installation standard has been huge. We would be stuffed without them. At best working group members may receive expenses in future in return for this commitment, hardly jobs for the boys.

I appear to be one of those odd people who support the aims and objectives of the scheme, believing the industry would be in a far worse position without it

 

[TedM]

Having dug through the rather vague and non-transparent Gas Safe set up a little more.

The HSE have accredited Capita Gas Registration and Ancillary Services Limited as the only gas engineer registration body. Others can apply to UKAS and HSE to perform an equivalent function but none have done so.

Capita Gas Registration and Ancillary Services Limited (a subsidiary of Capita plc) has a contract with Gas Safe Charity, the T&Cs of which do not seem to be public, other than it allows 2 employees of Capita to sit on the board of trustees of Gas Safe Charity.

The gas industry technical specs are produced by IGEM - the Institution of Gas Engineers and Managers - which is also a registered charity. Turnover approx £1.5 million.

Gas Safe Charity has an annual income of approx £250K, which is 90% contributed by a donation from Capita Gas Registration and Ancillary Services Limited and 10% from investment income.

Capita Gas Registration and Ancillary Services Limited has a turnover of just under £20 million.

So if this model is to be followed then:

- Gemserv will be appointed to act as the 'MCS register' for installers and products and issue certs as now, approved by UKAS and accredited by the HSE

- a new 'MCS' body will be created as a charity to support education in renewables and will be funded by a donation from Gemserv

- the IET will be responsible for producing all 'MCS' technical specs


Gemserv's 3 year contract with DECC to operate MCS runs out this October.

 

[Worcester]

I'm looking at the whole renewables industry, not just PV, I agree that an oversight body would be a good thing, I'm strongly NOT convinced it should be MCS or any of the admin team that it has had in the past. I see little benefit that their existence has so far passed on to consumers.

The PV guides were there before (DTi) and will be after (IET), the standards for the other technologies are also there. (CIBSE Heating, Building Regs for combustion devices, etc....)

I can see the need for a body that indexes the standards, though not a need for a regulatory body, that surely is what the CPS schemes are about.

Note also that more than 10% of PAS2030 registered installers have been struck off!! (One in ten Green Deal companies 'struck off' for breaking the rules - Telegraph )

Other sources tell me that MCS has lost nearly 30% of it's membership through non-renewals. (Solar ONLY PV Installers is down to 1700, total number of all installers is 3500)

@The Solar King, sorry, I struggle to justify the continued existence of MCS.