Thursday 18 September 2014

What Has the MCS Ever Done for Us?

How to fix the Microgeneration Certification Scheme (MCS)

You pay your registration fees each year. You research each and every change to the regulations and make sure to adjust your paperwork, your working practices and the products you offer to keep in line with the rules. You engage with the annual audit of your work and put right anything the auditor finds. You go further and make changes to your processes to ensure these issues never recur. 

You are, in short, an ideal MCS installation company. The kind that the folks sitting in London running the scheme like to think that they have produced. 

The problem is that there's another installation company across town. They also have an MCS accreditation, after all it's needed for customers to access government incentive schemes. Their workmanship is shoddy, they don’t seem to be in it for the long haul and cut corners to make a quicker buck. They have accumulated a string of non-conformances on their paperwork from the annual MCS inspections but nothing ever happens, so they don't waste their time making changes. The inspector comes once a year, takes a cursory look at an installation of the company's own choosing (inspecting the roof work from the ground). So long as the company has one half-decent installation to show the inspector, they're good for another year.  This company can undercut its more diligent neighbour because it doesn't have the expense of bothering with the requirements of the MCS scheme or spending the time and care to put in the "high quality installations" the scheme claims to ensure. 

Back among the glass towers of London where industry representatives meet to oversee the MCS this company simply doesn't exist, or is at worst a 'bad apple', an isolated case. 

Unfortunately, the second company and their like are a very real in the minds of people who work for companies like the first and have to compete with them every single day of the year.  I have heard numerous stories from colleagues in the industry about companies "getting away with it", about complaints to MCS not adequately investigated and annual audits of installations that amount to little more than checking there really is a solar installation on the roof.  

This, in short, is the crisis of confidence that the MCS must recognise and urgently work to fix.  If scheme officials knows that there isn't a problem, that it really is just a very few bad apples then they should publish the evidence that has led them to reach this conclusion thereby reassuring an increasingly sceptical industry. 

Many people believe that way the scheme is managed has had the perverse effect of creating ’Natural Selection’ for the least desirable traits in registered companies.  Without meaningful audits of installations and a credible threat of expulsion from the scheme, the scheme penalises the diligent by imposing higher costs, handing a competitive advantage to those that join the scheme but don't bother trying to meet the standards. 

It is a great frustration for those of us who have worked  in the MCS technology Working Groups to hear such views.  If the enforcement really is this poor, why bother writing rules?  If the only companies that are applying the standards are those that would have worked to a good standard anyway then what’s the point of all those hours donated free of charge to the scheme.

Unless MCS changes

As I revealed in an earlier blog, the MCS is sitting on a cash pile of £6.6m, growing at the rate of £1.3m last year. That kind of money would pay for a lot of surprise audits. Perhaps industry would even be willing to pay slightly higher fees and put up with more intrusive audits if proper enforcement levelled the playing field and drove the bad apples out of the industry.

My colleague at the Solar Trade Association (STA), Chris Roberts has written a draft White Paper: 'Is the MCS Fulfilling its Potential?' to stimulate debate and comment from STA members on the MCS. Having collectively contributed more than 90% of the scheme income the views of the solar industry deserves to be heard, and I urge everyone in the industry to join the debate by reading the paper and feeding in your ideas and evidence to Chris. 

Monday 15 September 2014

The MCS Hoard

So here's an interesting thing about the Microgeneration Certification Scheme  (MCS)

The MCS is supposed to be self-funding, with fees applied on a 'per-registration' basis with these fees currently set at £15 per registration.  MCS installation companies also pay £110 annual fee, collected through the Certifying Body that accredits the installer.

Gemserv administers the scheme, and its latest annual report show that MCS has a surplus of £6.6m at the end of March 2014.

Indeed, the surplus grew in the most recent financial year by £1.3m, so this is not purely an artefact of the dash for PV of late 2011.

Figures for the number of installations the registered on the scheme database are available from the MCS website and show this:

So there were 122 thousand installations in the same period that the scheme ran a £1.3m surplus, corresponding to £10.65 of surplus per installation.
All this begs the question, why?  Why is the scheme building up such a large surplus, when its terms of reference are to be no more than self-financing?  What's all this money for?  How does MCS anticipate spending it within its terms of reference?
I'm personally not against accumulating some money from each installation if it's spent for the good of the whole industry, but just saving it up for a rainy day?  What use is that to anyone?
How would you spend it if you were in charge of the MCS?  Would you just lower the registration fee, or would you be happy to keep paying the extra, were the money to be spent on something useful.  Write in the comments below...