Written evidence submitted by MCS Charitable Foundation [FPS 102]



MCS Charitable Foundation

Our vision is a world where everyone has access to affordable and reliable renewable energy and low carbon technologies – for the benefit of our environment, our communities and the general public.  As a Foundation we work to increase public confidence, awareness and access to renewable energy and low carbon solutions across the UK. We support education and engagement programmes, fund research and facilitate innovative solutions to drive widespread adoption.

In addition, the Foundation oversees the Microgeneration Certification Scheme (MCS) which defines, maintains and improves quality standards for renewable energy at buildings scale.



MCS Certified

Since 2008, MCS has been the only recognised Standard for UK products and their installation in the small-scale renewables sector. It is a mark of quality. We create and maintain standards that allows for the certification of low-carbon products and installers used to produce electricity and heat from renewable sources. We are impartial: technology neutral, manufacturer neutral, and supportive of Installers committed to quality installations and consumer protection. Membership of MCS demonstrates adherence to recognised industry standards; highlighting quality, competency and compliance. Our mission is to give people confidence in low-carbon energy technology by defining, maintaining and improving quality.






  1. Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?


1.1   The Current planning regulations do not support the Government’s net zero carbon emission target. For this to be achieved, all homes being built today need to be zero carbon. There is currently  no requirement under the new Future Homes Standard[1] being proposed by the Government for new homes to be zero carbon. Such a requirement would include very high energy efficiency standards combined with microgeneration to produce home grown renewable energy and reduce reliance on grid based supplies.  The Future Homes Standard needs to be amended to require builders to construct homes where 50% of that home’s energy needs are met through microgeneration within the home or in the community.   https://www.gov.uk/government/consultations/the-future-homes-standard-changes-to-part-l-and-part-f-of-the-building-regulations-for-new-dwellings

1.2   Energy consumption and projections for increased usage of electricity is going to place a burden on greening the grid and the demand curves projected by the Government show that increases in consumption are predicted to grow especially in the domestic (residential) sector which accounted for 29% of final energy consumption in 2017; this rises to 34% in 2035.[2] Having microgeneration solutions included in every new home being built would reduce the energy demands from new homes, especially new social housing, helping to reduce CO2 production through grid based solutions, reducing  consumers bills and helping to tackle fuel poverty. https://www.gov.uk/government/publications/updated-energy-and-emissions-projections-2018

1.3   Guidance issued in 2006 that builders meet the 10 per cent target for renewable energy in housing – a guide for developers and planners (2006 edition)[3] has not been embraced by the building industry and it is only by introducing new strict regulations that require builder to include renewables on all new homes can we build truly sustainable homes which are fit for purpose.  

1.4   The Future Homes Standard is good, but needs improvement in a number of areas.  It mentions phasing out Gas for heating in new homes after 2025, but does advocate alternatives like Ground Source, Air Source, Water Source Heat pumps or other renewable/microgeneration solutions.  Yes we understand other technology may come along in the future, but there should be a requirement for no new fossil fuel based systems and microgeneration within the home and or community and that at least 50% of that home’s energy requirements come from microgeneration, so it does not advocate any one technology and allows for new microgeneration products coming on to the market. It is also vital that new regulations are not delayed until 2025 and there is a need to introduce them more quickly and March 2022 provides an opportunity to continue growth in the renewables sector, so when RHI and the GHG expire there is a mechanism that will guarantee growth in the market.     




  1. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission?


2.1   Building 300,000 new homes a year, needs to managed centrally and not through companies, to supply the homes to the whole of the UK and not concentrated in one region e.g. the South East. It is important that new green building skills and jobs are created across the entire UK and that all of these 300,000 homes have zero carbon heating solutions and domestic renewables built in to the property, so home grown energy becomes the norm as recommend by the Energy Savings Trust.[4] https://energysavingtrust.org.uk/clean-growth-plan-2050-ready-new-build-homes-policy

2.2   The current target of 300,000 homes per year means that up to 1.5 million homes could be built between now and 2025, when the new Future Homes Standards is being proposed for introduction, meaning that they will all need retrofitting. This makes no sense when we have the ability to build zero carbon homes: now is the time to go even further rather than just ‘making homes ready’[5] which is not the same as making zero carbon homes now.  It also means that current building policies will waste five years in the production of zero carbon homes. The more homes that need retrofitting will mean the higher the Government bill. It is vital the Government introduces new zero carbon standards with microgeneration by March 2022 to achieve the carbon savings it needs to.

2.3   For the Government to build 300,000 homes per year it is vital that these need to be zero carbon homes from the ‘get go,’ where microgeneration and home grown energy provide at 50% of that homes energy needs.       




  1. How can the planning system ensure that buildings are beautiful and fit for purpose?


3.1   Beautiful is a very subjective term and should not be used as this will be different for everyone and as we all know ‘beauty is in the eye of the beholder’.  Any new building needs to reflect a locations unique architectural style e.g. Cotswold stone, Hampshire tiles, Norfolk flint & brick etc, so homes are not homogenous across the UK and retain the character and style of an areaSo we agree there needs to be a sense of place, but not at the expense of zero or very low carbon energy solutions such as Solar thermal or PV. We agree there needs to be sympathetic solutions on protected village streetscapes with any new developments and it is right to find the most appropriate zero carbon energy solution that does not damage the aesthetics of such areas, but they must still be a zero carbon building with renewables built in and it is a matter of choosing the right technical solution and appropriate technology e.g Ground Source Heat pumps are not visible externally etc.       

3.2   For a building to be ‘fit for purpose’ in a country committed under law to achieve Net Zero by 2050, it is vital that homes are built to the highest environmental standards and highest EPC ratings available and need to be constructed from 2022 with renewables such as heat pumps and solar solutions as a legal requirement under any new changes to planning regulations and new build housing estates should be designed to maximise solar/renewable potential in the alignment of buildings and street design.

3.3   Under fit for purpose of buildings it is important to consider the carbon generated through the build and the fabric of the building. It is also important that offsetting is not an option to negative responsibility.  When considering fit for purpose it is the lifetime of the building, the material used and the energy required to run and heat that building. This combined with place and the environmental impacts, green spaces and garden and tree provision, to allow a building to be truly fit for purpose. These criteria need defining in a consultation.      

3.4   A building fit for purpose should be one that is warm, comfortable and secure. It should be well insulated, and meet the highest EPC ratings and should be cheap to heat and run.  There should also be a requirement to install rapid EV charge points to all new homes (or installed in lampposts on the street), as well as a requirement for all new homes to generate 50% its own power/energy needs through microgeneration within the home or the community. It is only then that economies of scale can be achieved in the sector, bringing down prices and increase manufacturing.

3.5   There also needs to a sense of place and space for the environment for a building to be truly fit for purpose, so it is not just about the inside space. High density housing solutions do not provide space for nature and not in keeping with rural areas, new developments must reflect an increase in space for garden size, the creation of avenues with trees and to build nature and the environment in as part of that new build design, so any new developments are connected to nature.  COVID has shown us that space and nature are vital for our wellbeing and homes and places need to reflect this in any new regulation.



  1. What approach should be used to determine the housing need and requirement of a local authority?




  1. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?





  1. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?




  1. What changes, if any, are needed to the green belt?





  1. What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes? What further steps might also be needed?





October 2020

[1] Future Homes Standard https://www.gov.uk/government/consultations/the-future-homes-standard-changes-to-part-l-and-part-f-of-the-building-regulations-for-new-dwellings

[2] Centre for Sustainable energy https://www.gov.uk/government/publications/updated-energy-and-emissions-projections-2018

[3] Meeting the 10 per cent target for renewable energy in housing – a guide for developers and planners (2006 edition) https://www.logic4training.co.uk/wp-content/uploads/2014/05/ESST-CE190-guide-for-developers-and-planners.pdf

[4] https://energysavingtrust.org.uk/clean-growth-plan-2050-ready-new-build-homes-policy


[5] Future Homes Standard https://www.gov.uk/government/consultations/the-future-homes-standard-changes-to-part-l-and-part-f-of-the-building-regulations-for-new-dwellings