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Solar News 10 October 2009
Edited Letter to the UK Department of Energy and Climate Change follows:

We now have written confirmation that most of UK’s grant aided solar water heating appears to be uninsurable from a solar installers’ perspective, due to a foreseeable Legionella risk which could be better controlled than it is currently. As evidence of this uninsurability, attached is a letter from [insurance broker name], who are insurance brokers to [a major UK trade body which includes solar plumbers]. I understand that thousands of UK plumbers hold insurance brokered by [this same broker]. This letter says that installers of noncompliant solar thermal systems (ie not Solartwin’s) would undoubtedly face voided insurance overage in the event of a claim. The letter is a reply to our suppling them with documents about:

• The HSE’s Legionella guidance to heat to the base of hot water cylinders to 60C daily not being followed in some solar thermal and ground source heat pump installations, and
• Dr Tom Makin’s “highly likely” to be creating a legionella risk statement for solar thermal installations in which the hot water cylinders do not heat to the base every day.

Of course, Government has known about this HSE noncompliance matter for many years. Given this written evidence of uninsurability I once again ask that Government to respond with effective and prompt action to protect the consumer of solar water heating systems. For the sake of the taxpayer, I hope that the lunacy of state subsidy being specifically and preferentially given to consumers of noncompliant and uninsurable systems will be rectified immediately. Also for the sake of customers of suppliers such as ourselves which install Legionella guidance compliant hot water stores please can you immediately give them access to state funding, instead of today’s position which is exclusion.

On the issue of how big is the noncompliance problem for the rest of the industry, my estimation is that the majority of UK state funded solar thermal installations fall into this uninsurable category and that tens of thousand of UK homes contain these installations. Do you have any figures?

As a solar company which is excluded from the UK’s main solar trade association the Solar Trade Association (we are told this is specifically because we have ask probing questions such as on Legionella) we remain outside the main industry consultation loop, and so we ask to be kept informed directly by yourself. So I hope you are able to let me know directly what Government plans to do next regarding:

• Informing the UK consumer in a balanced way about these matters.
• Allowing safer installations to be grant aided without delay.
• Risk assessing/rectifying any uninsurable/noncompliant installations.
• Seeking compensation for Government from experts or consultants it has used, if they have been incorrect in giving advice, given that taxpayers’ money has been involved.

I have copied Government Ministers David Miliband and Joan Ruddock into this email since this matter obviously affects the credibility of Government renewable energy policy. You and they are welcome to call me to discuss this matter.

I look forward to your reply, one which I hope will be prompt and complete.
Regards, Barry Johnston. Managing Director of Solar Twin Ltd.

Addendum:

This – “highly likely” to be creating a Legionella risk – statement is now fully in the public domain following us obtaining it under the Freedom of Information Act after leading players in the solar industry were made aware of his concerns and the paper not being published on the Water Regulations Advisory Board’s website as had originally been intended.
One is forced to ask why has one small  individual company (ourselves) was obliged to take on the role and take the flak from of (a) releasing Dr Makin’s paper to the public and (b) asking about the insurability of conventional solar industry?
Dr Tom makin’s “highly likely concerns were circulated very widely indeed. We know, thanks to Freedom of Information Act, that the following bodies were aware of it:
- Department of Energy and Climate Change (who fund the Low Carbon Buildings Programme – solar grant scheme).
- Department of Food and Rural Affairs (who also have energy responsibilities)
- Department of Communities and Local Government (responsible for Building Regulations).
- Health and Safety Executive who wrote the Legionella Guidance document L8.
- Water Supply Regulations (Again part of Government), Water Regulations Advisory Service, WRCNSF, (all three are involved with water safety)

Plus to major commercial and trade players including:

• Alphatherm
• Atmos
• Bosch
• Ferroli
• Vokera
• The Very Efficient Heating Company (including installer and consultant Dr Chris Laughton)
• The Solar Trade Association. STA repeatedly ordered us not to discuss Legionella, backed up with threats such as regulatory or market access exclusion if we do, orders and threats which they know that can issue and execute with OFT impunity. Has a potentially embassessed Government told OFT to back off from our representations? One hopes not.
• The Ground Source Heat Pump Association
• The National Energy Foundation
• The Society of British Gas Installers
• The British Standards Institution.

Did any of these eighteen players ask any insurance company for any comment? Can you assure me that there is no collusion or cover-up whatever taking place by Government?

For a change of subject, here is a blog extract which we came across recently at:

http://lowcarbonlifestyle.blogspot.com/2009/10/tuesday-6th-october-09.html

“…On the way back I decided to pop into a house just down the road which has a SolarTwin hot water panel on it’s roof, distinctive because of it’s photovoltaic inset which runs the pump. Malcolm was in, a very engaging gent, and was delighted to tell me all about the system, which he is very very happy with. He has kept good records of all his meter readings and bills… Very interesting stuff… the household of two used about 2000 thermal units of gas a year before the installation, but now averages 1500, a reduction of 25% on their annual gas bill. They also now don’t use an electric immersion heater and this electricity use has reduced too. Malcolm reported good customer service and was very satisfied…”