Heat Energy, DECC RHI, RHPP – UK renewable heating incentive scheme – green energy subsidy news 19 September 2011.

Copy of correspondence to DECC/RHI and MCS [with my comments in brackets]

Dear Sirs,

I would like to remind you of some very slow progress in MCS and RHI and to ask whether there are industry vetoes or blocks operating, either formally or informally:

(a) The RHI needs to fund “net energy benefit” rather than “gross thermal energy”, in order to prevent millions of pounds of subsidy being mis-allocated to fund non-existent energy benefits. Today’s grant-looting must stop. The point here is that MCS documents clearly needs to accept this “net energy benefit” principle. At present, not all of them do so, thus licensing the misinformation of consumers, in terms of their overall energy benefit. One day some of UK’s anti-environmental newspapers are going to rip  to shreds the credibility of Government Policy on this matter of over-funding by paying for gross energy. Does anyone really care? [I think the nuclear and heat pump industries both care deeply about this issue not being sorted out soon, because this near-fraud benefits heat pump users by over 20%. Time to stop raiding the trough, lads!]

(b) The MCS solar thermal installation standard MIC 3001, still contains no reference to HSE’s Legionella ACOP L8, even though as from last week, the heat pump installation standard MIS 3005 finally does so. This is despite four years of work on MIS 3001. For how long will this anomaly continue? [As reported elsewhere in this site, we have been warned not to go near Legionella by the top brass at the Solar Trade Assocition because of the impact on “total sales”. So much for industry serving the consumer: more like industry-self-service at every trough.]

(c) third party validation of simple domestic solar thermal installations by a competent MCS installer is still not possible, thus stunting the market for solar thermal and putting installation costs artificially high for consumers. [Why shouldn’t a few competent DIY’ers be allowed to fit simple solar water heating panels, for example, provided that they do so safely and provided the final installations is as good as a professional one and provided that an MCS installer signed off and takes FULL responsibility for the system being fitted according to the relevant parts of the MCS installation spec?]

(d) MCS still has no disclosure requirements regarding the likes of freemasonry. How can you ever operate transparently and with confidence in the construction industry with incomplete disclosure in areas of known influence? [Yet another area where we have had the odd unsolicited advice / email about what is good for us. It can say a lot about an organisation when it refuses to align itself with better ways of working. We have suggested repeatedly, and have been repeatedly ignored, that MCS operates in alignment with relevant parts of the Civil Service Management Code Paragraph 4.1.3.c]

(e) MCS still has no stated “convergence aims with BSI”, either, even though BSI have plenty of well-established sound rules and procedures. Instead, MCS lurches around from crisis to crisis, with, in comparison, a handful of rules, which merely prompts it to reinvent more, often poor quality constitutional rules, too often in an on-the-hoof or reactive way. This deliberate deficit of governance had not only allowed some great innovations to be democratically sidelined, as we have repeatedly seen, it also wastes huge amounts of resources by duplication. Such obvious wastefulness is not a good use of state funds at any time, let alone in times of economic constraint. [It can say a lot about an organisation when it refuses to align itself with better ways of working. Again, this seems to be about strategic trough-grabbing. by industrial vested interests, at the expense of others.]

Do you have a clear timetable for these improvements?.

Regards, Barry.