starts on 25 September, 2019 ends on 25 October, 2019
Should the US vote to approve the DK Member Body request to “add the agenda point of “exclusive mandate” to the REMC agenda for autumn 2019”?
The Danish member body has recently taken notice of the proposal to develop a rating system for an IECRE PV power plant as well as the exclusive mandate given in this respect.
In our considerations we have taken into account that Denmark is not a member of the PV-Solar sector and that the sector has the right to decide on its own work within the IECRE framework.
The reason we nonetheless raise this issue is that we consider the issue at hand a topic that requires a discussion and decision by the REMC how we (the IECRE) proceed the next time there is a need for a “mandate letter”. We have based our opinion on the document “A RATING GENERIC 26092018_EN.pdf”. To our knowledge this document is not available from the IECRE website and has therefore been attached to this DFA for information and background information for all member bodies.
Specifically, we consider that there are two topics to discuss at the REMC:
1. From the Danish member body we feel that the development of documents to be used within the IECRE conformity assessment system must necessarily be a transparent and open process that is accessible for representation from all member bodies and stakeholders. In our opinion the approach as presented by the “exclusive mandate” leaves insufficient room for those member bodies and stakeholders who would like to contribute to the writing process of such documents. We do understand that the documents in question will be submitted to the PV-OMC for further revision and approval. We acknowledge that the principle of openness and transparency is missing from the document IECRE 01-S, possibly because this was taken for granted to be the basis of all our work. To the extent that the REMC feels this is needed, such principles should be considered to be added to the IECRE 01-S document as follows:
In document IECRE 01-S, add the following text in the introduction,so that the first paragraph reads (added text shown in red):
“The objective of the IECRE system is to facilitate international trade in equipment and services for use in Renewable Energy Sectors while maintaining the required level of product safety as well as ensuring an open and transparent manner in developing this system based on the principle of consensus:”
2. As a more practical matter, we would like the REMC to agree that the next time a mandate letter is issued on behalf of IECRE or any of its sectors or working groups, that this matter be brought to the REMC agenda for a decision.
We request that the REMC take the above points into consideration when discussing this topic at the upcoming REMC meeting in autumn 2019.
The REMC is requested to discuss and decide on the following at the REMC meeting in Feldkirch:
1. In order to ensure transparency and of the IECRE document development process, that any future decisions regarding a “mandate letter” involving any part of IECRE be brought for discussion and decision to the REMC before further action is taken.
2. Updating the objectives or the IECRE system as per above suggestion.
NOTE: This DFA will be discussed and voted upon at the REMC meeting in Feldkirch, Austria 2019-11-18.
NOTE: USNC/IECRE ballots are to be submitted within thirty days to allow for resolution of any comments prior to the IEC deadline.