News: Solar heating market sleaze update. BSI seek to smash up Solartwin and several other solar innovations in breach of their own pro-innovation rules. 9 May 2012.

The rudderless British Standards Institution (BSI) is now proposing to stuff solar innovation in UK with a new “code of practice” standard (which is not a code but instead a technical components standard) which requires solar water heating to have “time served metallic pipes“.

TIME SERVED?!! I thought that expression applied to apprentices. Is time served an approved BSI term? Try going into B&Q and asking for “one “time served” pipe, please”!

METALLIC?!! We have used freeze-tolerant silicone pipes for 13 years. BSI Solar Thermal Technical Committee Chairman “Dr Dark Arts” Chris Laughton has repeatedly tried to exclude us from the market using this kind of stunt.

It is now time for Chris Laughton to RESIGN. The old solar mafia-lodge must STOP rigging the UK solar market. BSI standards are supposed to facilitate innovation. This one stuffs it. The BSI are breach of their carefully drafted own pro-innovation rules.

What British Standard is this anyway?

This market-rigging British Standard is called “Draft BS 5918 Solar heating systems for domestic hot water – Code of practice” was first published in 1989. It was later abandoned as being obselete. Its popular resurrection and revision is now being being used as a clever stunt to:

• Close the UK solar water heating market against Solartwin in particular, in numerous ways such as by banning our freeze-tolerant polymer pipes by insisting on metal ones, banning our safe design of open vented solar heating and so on.
• Close the UK solar water heating market against retrofit solar in general by disallowing solar installations into hot water cylinders of less than 120 litres, even though this is the standard size of a UK hot water cylinder. The minimum allowed is 140 litres.
• Consolidate via BSI the market dominance of outdated solar heating designs which use polluting mains pumps and antifreeze and high pressures so that they can money-grab all state grants in the forthcoming (summer 2013) domestic Renewable Heat Incentive (RHI) by inserting reference to this standad into the Microgeneration Certification Scheme Standard.
• Cover up and legitimise restrospectively via BSI the elevated Legionella safety risks which the old solar brigade have imposed on thousands of solar customers, without asking them, across UK using about 100,000 past state subsidised installations.

Draft BS 5918 Solar heating systems for domestic hot water – Code of practice” is available free for review and comment online via the BSI British Standards Draft Review system (DRS) here. Registration is free and takes less than a minute. Once you have registered you will be able to review not just this standard but all current draft British Standards of national origin and submit comments on them. You will also be able to see the comments made on current draft standards by other interested parties. We had already warned BSI that this standard is a market limiting stunt. That’s why we are now going public about the BSI’s stupidity. And further to the matter of BSI stupidity, discerning readers might enjoy this particularly stupid self-contradiction which the Draft Standard contains: early on (section 1.3) it says the scope of the standard is not designed for solar multiple collectors but later (in section 7.4.4) it talks about multiple collectors anyway. Doh!

Who, exactly is the BSI solar heating chairman, Chris Laughton? Here are some scary quotes from East Anglia University researchers about the Chairman of the BSI solar thermal technical committee, Chris Laughton.

“One link between an ALF approach and the ELF has been via several tiny green anarchist networks. Green Anarchist (GA), a newspaper produced by radical greens, has long championed the ALF and sought to diffuse EF! to UK. Chris Laughton who wrote for GA, attempted to use it to launch EF in the UK in 1987 but failed. The growth of the EF! (UK) in the early 1990s was also aided by GA. Another joint EF/GA activist noted:
“‘a key model throughout the 80s was the Animal Liberation Front of course in terms of they were directly resolving things in a clandestine manner’.

“A second network- Greenpeace London- also had early networks links with EF! and was sympathetic to the ALF. ELF tactics were also influenced by the ‘ecotage’ of EF! (US) and then re-exported from the UK back to North America. Chris Laughton, a physics graduate who had come into contact with EF! (US), attempted to establish an EF! (US) by importing copies of ‘Ecodefense’ and promoting ecotage during the late 1980s. He was disillusioned by the emergence of EF! (UK) which in his opinion did little to promote sabotage.

“Laughton’s libertarian right wing sympathies were rejected [by] the ELF who believed that direct action should explicitly link environmental and social issues. The ELF was strongly promoted by a minority amongst a minority of direct action radicals using the Animal Liberation Front as a template. A number of ELF publications including the Terrarist aimed to propagate covert repertoires of contention and a discourse of anti-capitalist.”

A few explanatory notes from Wikipedia:

• Ecotage = covert (ie secret) sabotage, such as arson.
• Ecodefense = a book on how to do this covert sabotage
• ALF = Animal Liberation Front
• ELF = Earth Liberation Front
• GA = Green Anarchist
• EF = Earth First!

So Chris Laughton, global solar guru and Chair of the BSI solar thermal technical committee which produced this market-rigging standard is also a specialist in writing anarchist polemics and in promoting covert sabotage. There is nothing criminal in that, is there? Nor, of course is there anything criminal in being on the cusp of rigging the UK solar thermal market so that British innovation inconveniently does not get any access to the hundreds of millions of pounds of RHI state subsidy.

Let’s say it again: hundreds of millions of pounds of RHI state subsidy about to be lost to UK innovation. Are the Office of Fair Trading (OFT) reading this? Will OFT please take a wee look-in, this time?

To be fair, to Dear Mr Dr Laughton, I spoted an error in the above academic article, and so perhaps there are more errors I have not spotted…

PHYSICS GRADUATE?!! “Dark Arts Dr” Chris Laughton has let many believe he was a physics graduate, even telling DTI in the past in an interview that was published on their site they he had “studied physics at university” until I queried its accuracy, and then the article vanished, but it seems that he has no degree in anything. Chris Laughton may be great at writing pro-sabotage article in the anarchist press but is a past promoter of covert sabotage the the best person to be leading the production of solar technical standards for the BSI?

Chris Laughton, FIDHEE, to give him is correct name, has indeed letters after his name: for all you common ignoramuses reading this, it means, of course, “Fellow of the Institute of Domestic Heating and Environmental Engineers” (I think that means really he is a domestic plumber, don’t you?) For his other honorary letters (eg RSHL) and a Laughton book review please read here.

As long ago as 13 January 2010 we warned BSI of our concerns regarding the revision BS 5918.

Here are some extracts:

“Lack of clarity… purpose unclear or even unjustifiable. It might be a better use of time to amend the existing EN standards instead – to bring innovations into scope, but our experience here is of past amendments to standards being inappropriately blocked by BSI’s Chairman, Mr Laughton. …wholly inappropriate for BSI Standards to be used for the purposes of myth consolidation and market limitation by one dominant section of the solar thermal market, saying: “Don’t correct a commercially valuable myth: repeat and recycle it as high up as possible, in order to develop a false consensus.” seems to be the tactic here. While there are plenty of competition-related reasons for excluding direct solar, there is no valid technical rationale for doing this. It is unreasonably component-specifying, seemingly in a way which will stop innovation. It is a backward looking old solar specification. It is a detailed component (not performance) focussed standard. It does not meet most of the requirements of BS 0, the standard on how Standards should be, eg: represent current technology, be open to innovation, etc. It delivers a Legionella cover-up.  A particularly urgent commercial imperative of the conventional solar industry is that of delivering a robust and documented validation of years of apparently legally unjustifiable risk-taking. A solar regulatory document which sweeps away this mess has been long awaited. What better home for this than the BSI? Claiming compliance with a resurrected British Standard, presumably means that if a solar customer gets sick with Legionella, the company responsible will get off the liability hook. BSI …neatly, validates the L8 noncompliant installations (while also firing numerous exclusionary shots at those who think differently) . To deliver retro-validatation most of the 80,000 or so L8 Legionella guidance noncompliant solar installations that already exist in UK would be a coup for today’s largely uninsured solar industry! This standard may well buy them time. But what about the needs of solar customers? If Legionella infections start to be confirmed as being due to twin coil solar cylinders, then, it will be too late. It makes sense now (not later) for the safer approach of heating daily to the base OR to use thermal stores to become the official, preferred British Standard approach. From the consumer’s perspective, there is a clear need to meet HSE guidance. Dr Tom Makin reports that conventional solar is “highly likely” to be creating a Legionella risk. But from 80% of the industry’s perspective, there is instead a need to drop the safety bar – using the BSI as a tool. This is because solar installers of twin coil cylinders are potentially uninsured right now: a leading insurer classifies these installations as “defective”. From the public health perspective, BS 5918 is an old solar industry document (to be delivered at all costs and at the expense of the consumer, of the environment and of innovation). In summary, I have been expecting the conventional solar industry to start a drive against us soon, given our gains on MCS and our asking vald but uncomfortable Legionella safety questions at MCS and elsewhere, but I was rather surprised that the chosen vehicle was to be quite as delapidated as a 20 year out of date standard. There seems to be few, if any, legitimate reasons for this old standard to be resurrected. (But plenty of invalid commercial reasons.)”

Silly old BSI just seem to have pressed ahead regardless and have ignored my repeated warnings. What a shambles! I want to be helping to shape my business and support my colleagues during this difficult times, not blogging at 11 pm, fending off endless market foreclosure attacks which are conveniently badged by a BSI stalking horse. Enough is enough!

BSI bungle update of 21 May 2012.

The market-wrecking BSI have written to a Solartwin customer saying that their technical committee has known about our systems for years but that they are excluded from UK’s Microgeneration Certification Scheme. This is not what we and the MCS think. In fact, just this week we registered some new solar heating installations with MCS. Our product has Solar Keymark, a BSI and CEN recognised quality mark for solar heating panels. Its certificate number is PSK 055 2011 and you can find it here. The BSI need to get their facts right.

The BSI Chairman Dr Chris Laughton apparently also wrote that:
1/ Solartwin is suited to DIY [This is very true, but certainly not a reason to prevent professionals from installing it, and neither was it a valid reason for him excluding us from a state funded installers manual which Dr Chris Laughton wrote for the STA.]

2/ Is not fully in compliance with some UK standards [Arguably  true, on the basis of self-referencing circularity, for example, (a) you conflate a “guidance” document into a standard – which Dr Chris Laughton wrote for Energy Saving Trust – which defines old solar as best practice – which EST have subsequently agreed is a flawed document and (b) you look at our superior approach to Legionella, which the old solar industry abhors in its numerous “industry consensus” documents). It is presumably the Greek Nightmare Scenario of this self-referencing mythmaking pack of cards (I only mention two of them here) collapsing, along with Dr Chris Laughton’s credibility which keeps him from being deposed as BSI chairman.

3/ Offers good value. [This appears to be Dr Chris Laughton’s code for “and should therefore not deserve any state subsidy because state funds are spent on technological losers, rather than on green disruptive innovations like Solartwin”].

Why have the respected British Standards Institution stooped so low?

Here are a few of our other concerns about this market rigging draft British Standard BS 5918.

• Title is wrong: It’s not a Code of Practice but a market limiting spec to help a cartel. Finessing in component specifications under a supposed CoP is market rigging. Just call it a market rigger and be done with it.
• Wrong revision starting point. Written from a clunky old solar perspective. There was only one main kind of solar thermal at the time this was written. It is now becoming obsolescent.  A new document needs to be started from scratch. Today’s approach is almost as stupid as BSI taking a specification for looking after a pet donkey and using it as a template for maintaining all forms of wheeled transport today.
• Better starting point should be more like a cut down version of the revised (not old) BPEC solar installers manual combined with a serious revision of MIS 3001.

• Direct solar is unreasonably excluded. Not excluded specifically in the scope but elsewhere such as in Annex A (informative). Full inclusion is needed.
• Direct solar is not even defined properly because of a missing definition. Secondary system is defined. Primary is not. Primary and Secondary are both referred to in the direct solar definition. In any case both terms are obsolete.

• It validates legionella-unsafe plumbing design and it even validates unsafe use of that design in various diagrams and basic underpinning assumptions and definitions.
• Market limiting and dangerous in Fig 4 diagrams. They need Legionella shunt pumps and it is vital to show retrofit heat to base and direct systems, currently omitted.
• There is even the usual Legionella linguistic cover-up again here. Say legionella – don’t cover up – not bacteria.

• Market limiting becauseit omits freeze tolerance – add this. Our pipes freeze without cracking.
• Market limiting again. Allow inclusion of silicone pipes rather than “time served metallic” in 4.10.
• Market limiting by exclusion of retrofit systems. Needs inclusion of retrofit systems, whether direct (us) or with heat exchangers.
• Market limiting because arbitrary 140 litre min cylinder size rule to be removed. Retrofits are usually to existing 120 litre systems. Where a combined cylinder is used, Veff = Vs + F (Vtotal ? Vs) and Vtotal should not be less than 140 L; naked market rigging… 120 litres….
• Market limiting sect 4.14 because primary pressures are best limited by using open vented systems, not sealed systems with relief valves as it says.
• Market limiting because “backup heat to base” cylinders are excluded. Ie dedicated solar volume in time to be permitted.
• Market limiting 4.15 omits simple sensible low cost safer expansion in open vented systems. Our system is open vented.
• Market limiting 4.16 warnings and flow rates may be needed for high pressure systems which may explode etc, but not suitable of reasivble with PV pumpes low pressure open vented ones. Similarly 7.5.8 requires kit only suitable for dangerous old solar. 7.5.9 pressure gauge is simply not neede in open vented systems
• Market limiting against thermal stores etc by wording on long term evaporation: should define no significant loss loss instead.
• Market limiting as it specifies “control devices” when in fact devices are not needed with some new designs and operation methods they are also impossible to implement.
• Concealment of problems of old solar add a section on saving energy and carbon via low energy pumping etc. Supposed to be greentech!
• Market limiting 4.7a backflow protection which is not used in normal plumbing just here to rig the market because impossible usual market limiting stuff
• Market limiting: Over-specific d delete UV do not name a tech.

• Market limiting 4.11 Non Return Valve is market limiting. Our must NOT have them. Getting rid of them is a safety feature!
• Market limiting over-specification. 7.2.8 Over specifies temps to open vented systems which don’t exceed 100C. Draft says 150C is a min insulation temp. This is expensive and pointless with our pipes. All we need is 100 or 105C.
• Market limiting volumes again 7.4.2 area issues are there to limit the market. What is the def on the 2 coll types? Why not 25l as dscg? stops at 30.
• Market limiting. Cylinder vols as Vols/sqm of panel are the wrong criteria anyway. Needs to relate to peak energy deliver in summer not sqm. Peakk energy is what you must be able to store! Current BSI approach hinders the retrofit market…
• Market limiting by omissions. Heat export as an over heat control strategy must be mentioned. This is great in systems with no heat exchangers or HEs which run top to bottom.

• Plain lies. 7.4.3 re Heat exchanger! say that no HE is best for performance. Not having one! Be honest. Also as sizing guide do they mean %? Active area do they mean absorber area? Use a relevant term.
• Stupid self contradiction 7.4.4  The system plumbing should be designed to be balanced and ensure that there is an approximately equal balanced circulation through matched collectors in an array. But arlier says NO multiple collectors in scope 1.3 Oops. Be consistent.
• Pointless safety controls which would actually cause malfunction in 7.5.7. You do not need controls if you have an open vent! Vents are the best.
• Parasitics cover up. It says that AFTER installations the annual electrical consumption of pumps and controls should be assessed and presented to the client. This should surely be done BEFORE sale! Users need to know then so they can choose systems which use nonmains power.
• Stupid myth making, the acceptable of which which leads to danger. Many examples 3.27 solar fraction. This is a pointless metric. You can push SF to 100% by having no backup heating, lots of cold and tepid showers which may be laden with legionella.

• Missing useful customer info in 6 Customer information add the really useful stuff even if it embarrasses old solar eg…
• likely CO2 clawback since this could be 20%
• annual gross thermal energy
• annual pump energy
• net energy (difference of above)
• expected CO2 savings ,,,expand re pump?
• under maintenance requirements; expand to state if used, water hardness control requirements and antifreeze concentration, replacement interval, replacement costs, and consequences of not doing so. do not cover this up!
• Typical lifetime emitted carbon breakeven time according to LCA assumning a 20 year life expectancy

These notes are far from complete and needs a lot more work, but I hope this is useful as a starting point to show

– how far off the mark it is

– how badly market limiting it is

– that a totally new starting point is needed

– that BSI need a better chair for solar thermal

Feel free to contact us with your thoughts.