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Seven ways to clean up / green up the solar heating and microgeneration industry.

Filed under: Latest News

Solar Panels & Microgeneration Certification Scheme Governance. Toothless Renewable Energy Industry REAL Consumer Code Watchdog. Senior Solar Cowboys Making “Zero Carbon” & “Free Hot Water” false claims. Renewable Heat Incentive Grants for DIY Solar Heating. Getting The Best Solar Installers. Heat Pumps & Solar Water Heating Legionella Safety. Seeking Low Solar Prices.

Here is an edited version of some of Solar Twin Ltd’s correspondence which was sent to the UK’s Department of Energy and Climate Change (DECC) today, proposing a wide ranging upgrade of performance, transparency and safety for UK’s renewable energy industry.

Taking advantage of the calm before the storm of UK’s new Renewable Heat Incentive subsidy for solar water heating panels and other microgeneration technology, we suggests that UK consumers (and, in some cases, Solar Twin Ltd) would benefit from:

  • a much less self-serving, and more consumer-oriented microgeneration industry
  • which aligns itself with (instead of distances itself from) accepted BSI standards of performance and governance
  • where gummy consumer watchdogs grow sharp teeth which they sink them into those who over-claim on the environmental and financial performance of solar heating (even when “captains of industry” make these claims)
  • where the number of years to energy breakeven, for all microgeneration systems can easily be compared
  • where DIY installers of really simple microgeneration systems can be fairly subsidised for doing so
  • where prices fall while quality rises because installers no longer have to be overqualified in irrelevant subjects
  • where solar customer safety, including Legionella safety, is paramount.

Here are these issues, expanded point by point:

1/ General perspective: a less self-serving, more consumer-oriented microgeneration industry.

Unfortunately, renewable energy innovators in UK are too often being tied down by their competitors’ vested interests. Systemic   “industry consensus” boycotts still operate widely across the solar thermal industry. “Industry consensus”, almost by definition, limits the access to market for innovation. There are some particularly entrenched problems with parts of MCS, with REAL, the STA and, also with several training and solar guidance / best practice type documents, some documents of which I believe, are now being addressed, news which is encouraging. But many live blocks and constraints in these areas remain as significant competition issues for innovators such as us. I look forward to more improvements being made – and I hope that we are available to participate in their development, if appropriate.

2/ Microgeneration Certification Scheme (MCS) and Quality. Where the microgeneration industry which aligns itself with (instead of distances itself from) accepted BSI standards of performance and governance

There is a pressing quality upgrade need within MCS for much higher BSI-type levels of governance – and for BS 0 “the standard for standards” compliant standards. It amazes us that senior players in MCS oppose the implementation even of BSI-referenced transparencies and improvements. Delays, boycotts of innovation and blocks of safety improvements and the lack of BS 0 compliance in the crummily written document MIS 3001, for example (BS 0 requires openness to innovation) remain a major competition issue for UK’s renewable energy innovators who have lost many £millions of business as a consequence of failures at MCS.

3/ Solar thermal over-performance “zero carbon” and “free hot water” claims. Our gummy green consumer watchdogs need to grow teeth. Then to sink them into those who over-claim on the environmental and financial performance of solar heating – even when respected “captains of industry” from the Solar Trade Association make these false claims.

I hope that MCS can (constructively and critically) support the renewables industry watchdog REAL as an OFT supported consumer code in promptly cleaning up the myriad of solar thermal industry false claims such as zero carbon / free hot water / free solar energy / free solar heating etc. The virtually REAL-licensed persistence of these false claims set an appalling low standard of conduct – which makes ethical selling very challenging indeed. These “passing off” false claims remain a major competition issue for us as honest suppliers of zero carbon operation systems delivering free hot water.

Like all suppliers of PV pumped solar water heating systems, we are losing substantial business precisely because so many lying solar cowboys are not being robustly challenged by REAL. Clearly this potentially game-changing challenge (do REAL or don’t REAL take on the lying big boys) may have implications for RHI, DECC, MCS and REAL and I do hope that any future news on this will be encouraging. Of course REAL may have an extremely tough time asking a dozen or so REAL members, including some top players in the Solar Trade Association to stop misleading the public. But with solid support from other independent players, I think this cleanup is, in fact, an achievable task, and will not be too much to ask from staff at REAL.

4/ Environmental performance reporting is needed under MCS. The number of years to energy breakeven, for all microgeneration systems needs to published and easily compared by consumers.

Again on the long-resisted issue of environmental transparency in our in our supposedly environmental industry, it is surely time for MCS start requiring the public reporting of the environmental performance of environmental technology. In particular, there is a need for MCS to start requiring technology suppliers / installers to start publishing some basic generic environmental performance indicators of their systems.

Such environmental indicators could include: (a) coefficient of performance, (both in terms of (a1) energy and (a2) carbon) so that people can know which technologies use how much bought-in mains electricity can deliver how many times more that amount as renewable energy. Also (b) life cycle analysis, so that people can know after how many years of operation the environmental impact (such as (b1) energy or (b2) carbon) of different types of kit takes to break even. Customers can already compare some microgeneration technologies such as Volartwin solar thermal Vs. PV (photovoltaic installations). Thanks to a study done some years ago by Bath University, we have established independently that our PV installations must generate power for about 5 years before an energy breakeven point is reached, while for solar thermal only 2 years are required. Also we know from independent research that mains pumped solar thermal takes much longer than 2 years to break even. Microgeneration customers really like to know this jimnd of numerical information – it helps them (and the Government) to made good buying (and policy) decisions.

Our customers are forever asking us : how green is my system?” and we are glad to be able to tell them. But sadly most Microgeneration suppliers are unable (or unwilling?) to tell them, even though the some of the standard methodologies which can be used for answering such questions (at not too high a cost) are over a decade old. I am hope to have th e opportunity to take generic aspects this matter forward to MCS to speak briefly to the matter, and to discuss it in person. This is such an important strategic decision to ask MCS to take:   to require the publishing of comparative environmental information on MCS microgeneration technologies so than consumers can ask “how green is my microgeneration installation” and get a real, typical, quantitative answer instead of today’s shedload of flummery.

5/ End the MCS installer monopoly lock-out of simple DIY microgeneration installations. DIY installers of really simple microgeneraton systems should be fairly subsidised for doing so. Their exclusion from MCS, and thereby from state solar grants should end.

It is time for MCS to accredit some simple DIY and plumber assisted solar thermal installations (such as our simple retrofit installations) in certain quality controlled circumstances such as where we specify suitable roofs and where we photo-validate 20 plus post-installation photos against our own installation compliance criteria, and, of course against those of MCS. Why should MCS admit as eligible DIY and plumber assisted work when all our installations already do exactly what they say on the tin?

The point is that Solartwin’s simple 4-6 hour DIY installations are completely indistinguishable from (and also perform exactly the same as) professional installations. This DIY-installed and plumber-assisted-installed exclusion from MCS is yet another major competition issue for us. Our DIY customers deserve grants!

6/ End the MCS installer monopoly lock-in of irrelevant qualifications for Solartwin! Industry needs balanced, proportionate, appropriate   and crucially, product-based MCS installer accreditation. Prices will fall while quality will rise when microgeneration installers are no longer have to be overqualified in irrelevant subjects!

Solar thermal systems comprise a range of design and operational configurations and there is a pressing need for MCS to accept this diversity and that fact that, some systems have passed their popularity peak and are now declining, some are simply mature while other innovations, such as Solartwin and several others, which are on the upward trajectory. MCS’s old fashioned, prescriptive and inflexible “one size fits all” approach to installer accreditation is not only wasteful and expensive. It is actually market limiting – even though today’s MCS-led uniformity suits the majority of installers who fit generally rather complex older or mature styles of systems.

As a solar thermal supplier, (we also do solar PV), Solar Twin Ltd never do high pressure plumbing, nor do we fit mains electrics on our solar thermal installations, yet under MCS it seems that we have to be expensively and irrelevantly qualified to these levels. This very wasteful MCS imposed nonsense puts up our internal costs and our installation costs. These excessive overqualification requirements are a serious competition issue. I would much rather train our staff and our installers on relevant, productive and customer-focussed skills than on irrelevant skills that they will probably never use. Product-specific MCS installer accreditation is long overdue. Could this flexibility be permitted, please?

7/ Legionella safety. For state subsidies only where customer safety, including Legionella safety, is paramount.

Please note that the following is not a quote from the Health and Safety Executive: it is attributable only to Solar Twin Ltd.

Today’s laudable drive for renewable energy should be balanced with due consideration given to the potential risks to the users’ health and safety. In some solar heated water systems, according to a WRAS report, (a report which was once unavailable to the public until we gained it following a Freedom of Information Request) these risks are “highly likely” to include risks from exposure to Legionella bacteria.

Solar thermal systems comprise a range of design and operational configurations, some of which appear to pay little heed to established parameters to control Legionella growth. One particularly common and reliable parameter which is used in virtually all hot water stores is that of heating the cylinder daily to the base to 60C to pasteurise against legionella. However, in most heat pump and solar thermal installations where this very parameter is left unheeded. Crucially, nor is it replaced by any other parameter of comparable effectiveness.

Indeed Solar Twin Ltd’s internal numerical risk assessment of these calculates that such cylinders carry up to ten times more risk than non-solar alternatives. With the anticipated growth of the renewable energy market it is essential that proper consideration, in the form of an independent re-consideration, is given to safe system design. So on balance we think that conventional twin coil cylinders might need to be excluded from general MCS approval under MIS 3001, unless they also heat to the base daily. We also think that that even safer alternatives, such as thermal stores, should be given more emphasis by MCS.

Despite being repeatedly ordered to shut up on this sensitive topic by the STA’s Chief Executive, who sits on the MCS solar thermal committee, and despite being vilified for not doing so by other members of the solar thermal industry (as nasty scaremongering, paranoid liars who are playing a cynical stealth marketing campaign, for example) having looked at the safety data which are available, we are in fact comfortable about taking a lead on this matter. (We hope that this lead will only be a matter of days.)

Having also liaised with a number of bodies, including our local Trading Standards, we are conducting a free product upgrade for past Solartwin customers who are affected, for whom, twin coil cylinders, fortunately, comprise a minority (under 1%) of all of Solartwin’s past installations. Last week this free upgrade was announced nationally on the Trading Standards Institute website. The ramifications of this potential show-stopper / show-cleaner matter may again have implications for RHI, DECC, MCS and REAL.

Finally.

My hope is that MCS and DECC can take a lead on not just considering, but also adopting and implementing all seven of these urgently needed changes – before the RHI-led thermal market booms. MCS and DECC have already been kept informed in the past about these matters. I now look forward to progress being made.


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