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RHI Regulations update

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In December 2016, the Government published the outcome of the consultation on reforms to the RHI mechanism. However, as a result of the recent announcement regarding the General Election on 8 June, the RHI reforms were not able to go through Parliament.

BEIS since announced on 3 May 2017 that it had been working on emergency regulations that would update the degression thresholds however was unable to put this through in time. This means that for the time being the following applies to the RHI:

The RHI continues to operate and is open to applications. Any future changes to the RHI regulations will be a decision for the subsequent Government.

Degression
The degression mechanism will continue to function in the absence of any regulation changes. The figures for the thresholds are specified up to the January 2017 assessment date in the current regulations. The assessment for any 1 July tariff reductions will be made against these January 2017 figures and will be announced by 1 June.

Heat pump standards (MIS3005)
• The regulations currently refer to version 4.3 of MIS 3005 which is the MCS standard for the installation and commissioning of heat pumps. Version 5.0 was published by MCS on 28th April and can be used by installers from 17th May.

• Version 5.0 of MIS 3005 references a six month grace period from 28th April during which version 4.3 can still be used by MCS installers. Version 4.3 can no longer be used from 30th October.
• If installation and commissioning is completed according to version 4.3, this is currently eligible for the RHI (subject to meeting other eligibility requirements).

• If installation and commissioning is completed according to version 5.0, this is not currently eligible for the RHI. (Updated RHI regulations that include version 5.0 would allow such plants to be eligible to apply to the RHI - subject to meeting other eligibility requirements, even if commissioned before the RHI Regulations are amended. Such an amendment to the RHI regulations would be subject to Ministerial clearance.)

• Version 5.0 of MIS3005 can be found at http://www.microgenerationcertification.org/mcs-standards/installer-standards/heat-pump-systems. A table showing the full list of amendments made to the Standards can be found from page 49 onwards. The standards must be read in full by installers.

 

Summary of Updates to MIS 3005

Updates have also been made to the Heat Pump Compliance Certificate and the Heat Pump Handover Pack Information. An MCS Heat Pump System Performance Estimate (MCS 031) has been created for all MCS Contractors to use at quotation stage and a recommended procedure to follow from the initial enquiry through to the handover of a heat pump installation.

MIS 3005
Performance Estimates:

• Introduction of an MCS Heat Pump System Performance Estimate. This formula is mandatory to use at quotation stage if the property is eligible for a domestic EPC and replaces Appendix E of the standard which has been removed.

• This would give a potential consumer an estimate of heat pump running costs compared to their existing heating system as well as estimated RHI income and likely capital cost. All MCS Contractors will use the same format, providing clarity and comparability for the consumer.
• MCS Contractors will be required to use the EPC for the MCS Heat Pump System Performance Estimate to calculate a whole house demand.
• A room by room heat loss calculation will still be required but will take place as a final design/installation survey after a contract is agreed between the parties. If there is a change to the agreed design, and/or estimated performance of the system, a variation to contract shall be presented to the customer and agreed with them before proceeding with the installation. If such variation in contract cannot be agreed upon, the customer may cancel the existing contract without cost, obligation or liability. Where a change has occurred to the estimated performance, the MCS Contractor shall issue to the customer, an updated estimate of performance, in accordance with the ‘MCS Heat Pump System Performance Estimate’.

Heat Emitter Guide (HEG)
• Use of the HEG with the client will no longer be mandatory. The new procedures will be identified in MGD 002.

Intermittent Heating
• Heat pump sizing and selection. Greater flexibility has been provided to MCS Contractors to size heat pumps in accordance with the condition of the dwelling. MCS Contractors will no longer have to add 20% to the calculated heat requirement of the building when selecting a heat pump.
• The MCS Contractor will instead be required to use Table 2(B) external temperature selection (99.6%) which has now been added to MIS 3005.

Appendix D has been removed
The following will be uploaded to the MCS website on 17th May 2017 to be used in conjunction with MIS 3005 Issue 5.0:

• Heat Pump Compliance Certificate Issue 2.0 (CC 002) (CC 005).
• MCS 031 - MCS Heat Pump System Performance Estimate v1.0.
• Heat Pump Handover Pack Information

MGD 002
The guidance document MGD 002 is currently under development to reflect the changes to the standard.

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