MCS Biomass Working Group Final Minutes for meeting on 11 th August 2016

Transcription

1 Meeting of: MCS Biomass Working Group Date: 11 th August 2016 Venue: Teleconference Attendees: Name Martin Murrish (MM) Mark Lewitt (ML) Colin Meek (CM) Louise Evans (LE) (Chair) Representing Hoval Boilers KIWA RECC Gemserv Apologies: Howard Roche Bruce Allen Andrew Hopton Peter Beighton Claire Aizelwood Frank Aaskov Martin Freeman Patrick Maxwell John Holden Graham Perrior Sean Young Paul Rose Nathan Ward Vital Energi HETAS HETAS Trianco BBA REA Specflue BBA BRE Global NHBC BBA Oftec Wendron Stoves 16/08/2016 Page 1 of 8

2 Agenda: No. Agenda item Led by 1 Approval of the agenda MCS Administrator 2 Last meeting minutes and actions MCS Administrator 3 4 Steering Group meeting outcome RECC Auditor Report - Biomass specific analysis MCS Administrator CM 5 MCS 008 Biomass Cookers Annex - Outstanding comments - Implementation Timeline - Impact Assessment 6 Domestic RHI New build metering requirements MCS Administrator MCS Administrator 7 AOB and date of next meeting All 1. Approval of the agenda The MCS Administrator welcomed the members and explained that it had been agreed with the meeting Chair that in HETAS absence, the MCS Administrator will chair the meeting. The group were invited to approve the agenda. 2. Last meeting minutes and actions The group reviewed the minutes from the previous meeting and agreed the document to be an accurate record of the meeting with no contention. The MCS Administrator noted that all actions have been closed with the exception of ACTION B_ which will be discussed under Agenda Item 4. 16/08/2016 Page 2 of 8

3 The MCS Administrator also noted that as per ACTION B_ , Andrew Hopton was reelected to act as SMG representative for the Biomass WG. 3. Steering Group meeting outcome The final Steering Group meeting took place on 20th April, it was agreed that this group will sit dormant until novation is completed, but that the MCS Management Panel would continue to operate to ensure BEIS were kept up to date and industry consulted with, as needed. 4. RECC auditor feedback Integrated paper At the 14 th April Biomass WG meeting, the WG agreed to extract the biomass sections from the RECC report and to focus on identifying potential amendments to MIS CM presented the report to the group. The evidence reported by RECC auditors and the performance estimate analyses suggests that many installers appear to regard the MCS standards related to performance information to be guidelines and, therefore, not compulsory which suggests confusion. Pre-contract performance information does not appear to be the subject of inspections carried out by the Certification Bodies. Installers are frequently surprised when RECC auditors insist that specific values be included in formal pre-contract performance information. Others argue with auditors about the inclusion of figures that are clearly required by the MCS standard. Amongst the MCS heat technologies, it is most evident with Biomass that installers adjust the values required by the MCS standards where there is often little or no consistency in values such as the energy value of fuel (per kg) and how boiler efficiency should be defined and presented. Values are clearly manipulated to predict system efficiency as high as possible and fuel requirement as low as possible. The evidence shows that, because so many installers deploy non-compliant practice, Installer practice must improve to ensure that customers receive formal performance estimates that they can be confident in. RECC s analysis of performance estimates (and supported by anecdotal evidence from auditors) has found that a significant proportion of installers do not refer to the Seasonal Efficiency of the boiler in their performance estimates and do not use the SE figure in their performance calculations. Instead, many installers refer to the Manufacturer s Specified Efficiency. 16/08/2016 Page 3 of 8

4 The manufacturer s specified efficiency is often referred to as: nominal efficiency (as it is termed in the Compliance Certificate); or, boiler combustion efficiency. Installers using nominal or manufacturers specified efficiency values in performance calculations to estimate fuel levels required are exaggerating potential performance. CM reiterated the recommendations made previously: To ensure the current MIS requirements are enforced by Certification Bodies; and To consider introducing a uniform format that is clear and accurate for installers to provide to customers. MM suggested that manufacturers can only meaningfully test in standard steady state conditions and in-use performance is different as it is affected by installation design and operating patterns. ML agreed that the differences between product efficiency and in-situ or system efficiency could be better communicated in general and to potential biomass users in particular. The MCS Administrator noted that as there are no installers or installer Certification Bodes represented at the meeting, the WG will be asked to ratify recommendations made by the group electronically. The following was agreed: 1) It is not compliant practice for installers to provide customers with performance estimates based on the nominal efficiency as the standard requires the use of the seasonal efficiency listed in the PCDB or the default value published in the current version of SAP. 2) Attendees support the idea of a standardised template for provision of the estimated performance information required by the installer standard at the pre-contract stage. 3) It could be prudent to circulate a communication to Biomass installers noting that due to non-compliant industry practice, we would remind installers to adhere to the requirements of MIS ) WG to consider raising a Commonly Agreed Position (CAP) between Certification Bodies regarding acceptable methods for creating performance estimates, following the approval of the draft CAPs process. 16/08/2016 Page 4 of 8

5 ACTION B_ : MCS Administrator to raise the Biomass WG s recommendation to introduce a standardised quote template for performance estimates. ACTION B_ : MCS Administrator to consider circulating a communication to Biomass installers regarding complying with Clause 4.4 of MIS MCS 008 Biomass Cookers Annex Outstanding comments on MCS 008 Main text The WG reviewed those changes that have been raised by the working group following the public consultation period: - Page 8, amend lines to and with the provisions of the standard with which conformity is being claimed. This wording aims to clarify the approach for a family of products. - Page 9, amend lines to Table 21 of HM Government s Domestic Building Services Compliance Guide for England; 2013 Edition and HM Government s Domestic Building Services Compliance Guide for Scotland; Page 10 amend line 186 to - Page 10 amend lines to The Domestic Renewable Heat Incentive (RHI) Scheme, set limits for emissions of PM and NOx from biomass heating systems. This involves confirming that emissions of PM did not exceed 30 grams per gigajoule net heat input when a biomass product was tested in an accredited test laboratory with both parameters being measured on the same occasion. This testing must be in accordance with the applicable version of EN 14792:2005 for NOx and EN :2002 OR BS ISO 9096:2003 for PM. Further details are available from Ofgem. MM raised that it may be worth checking the standards as it could that measurements of emissions could be either via EN303-5:2012 or via the individual measurement standards. 16/08/2016 Page 5 of 8

6 - The MCS Administrator noted that BS EN 12815:2001+A1:2004 appears to be available for reference again and therefore references to pren are no longer necessary and have been removed. Attendees approved the changes subject to clarifying the RHI requirements within lines with Robert Stewart. ACTION B_ : MCS Administrator to clarify the domestic RHI requirements and amend lines of MCS 008 accordingly. Implementation Timeline and Impact Assessment Attendees heard that in terms of existing certified products that may be affected by the changes to the standard, 4 products have been certificated from 1 manufacturer by 1 Certification Body. The group discussed the potential costs that the existing manufacturer might incur as a result if the changes. ML noted that the requirements specified in Annex B of MCS 008 are set to achieve safety in operation. The perceived risk is that although primary functionality of such products is as a boiler/stove, persons may assume that it will have the characteristics of a cooker particularly in terms of surface temperatures. The Annex is structured to offer two means of addressing this. Either demonstration that maximum surface temperatures set for surfaces of cookers are not exceeded, or to in their instructions to require the use of guarding to an appropriate EN standard. ML suggested that this should not take a significant amount of the time and agreed to confirm with Klover the number of products that have been purchased by installers to assist with determining cost implications for installers. It was agreed that a 1 year implementation timeline would be appropriate for existing products. ACTION B_ : ML to discuss with Klover the number of installers that have purchased the 4 MCS certified Biomass cooker products. Post-meeting note: 217 appliances have been supplied. 16/08/2016 Page 6 of 8

7 ACTION B_ : MCS Administrator to circulate the latest version if MCS 008 and Impact Assessment to the Biomass WG for review ahead of submission at the 28 th September SMG meeting. 6. Domestic RHI New build metering requirements The MCS Administrator noted that the domestic RHI occupancy requirements have been amended to make eligible new build properties exempt from the 183 day occupancy requirement in the 12 months prior to application to the scheme. Thereafter, these participants will be subject to the standard ongoing obligations which include the annual declaration that the property has been occupied for 183 days or more in the last 12 months. This is due to the unintended consequence of eligible new self-builder properties having to wait 183 days prior to the scheme application of installing heat meters are as they were previously unable to provide evidence that they had lived in their homes for at least 183 days in the previous 12 months. The MCS Domestic RHI Metering Guidance Document will need to be amended to reflect this. 7. AOB and date of next meeting Percussive Ignitions and Minor Explosions Project Update The MCS Administrator explained to the WG that the draft funding criteria contract has been completed subject to ongoing work on the intellectual property clauses as part of the novation process. Kiwa will then be invited to populate the contract with the details of the proposal in the next few weeks so that commencement of the project can begin. Biomass Boiler Efficiency Project Update ML informed attendees that Phase 1 of the project involved installation of monitoring equipment on between 60 and 70 sites. Data collection is ongoing and is expected to be completed for Spring A further update can be provided at future Biomass WG meetings. Biomass WG Expressions of Interest 16/08/2016 Page 7 of 8

8 The MCS Administrator noted that two Installer companies have expressed interest in joining the working group. The working group s views are being sought on whether the addition of two more installer representatives, would distort the group s industry representation. Attendees agreed that as attendance at the meetings is low and no installers or installer Certification Bodies were available to attend this meeting, there shouldn t be an issue with accepting the proposed new members. ACTION B_ : MCS Administrator to invite the new members to join the Biomass WG. The dates of the next Biomass WG meetings are to be confirmed as soon as possible. 16/08/2016 Page 8 of 8