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Solartwin advises UK government how to clean up the gateways to solar hot water grants.

Filed under: Latest News

Solar Twin Ltd have suggested formally to regulators that the way the Microgeneration Certification Scheme (MCS) works should be overhauled.

MCS is the gateway for most of UK’s renewable energy grants such as solar water heating. It is currently set up in a way which constrains innovation and thus which stops UK from delivering the best value for money in terms of money spent for carbon saved.

Here are some of our comments and suggestions. For convenience, I have grouped the topics into three areas: installation, product and governance.

While we have several concerns, our top concern is the exclusion of “dedicated solar volume in time” under MIS 3001 and the Legionella compliance issues which link to this.

1/ MCS Installation specifications including MIS 3001 issue 1.4 (Solar Thermal)

In effect there has been an unreasonable exclusion of installations which use “dedicated solar volume in time“. Also an inexplicable refusal by BRE to certify for the remaining installations of the “domestic heating compliance guide” type.

There is a significant discrepancy between the MCS solar thermal and the MCS heat pump installation specifications regarding the storage of hot water. This occurs even though both collect mainly solar-derived energy which can be used to heat water. The MCS solar installation specification MIS 3001 excludes our common domestic installation method (of dedicated solar volumes in time), apparently because we make sure that what we install complies with THe Health and Safety’s Legionella Code of Practice and Guidance, called L8. What is odd is that the MCS heat pump installation specification MIS 3005 does not exclude our approach. Indeed for heat pump installations MCS makes no reference to hot water storage at all. But for solar thermal, its references are market limiting.

So it seems that our safer approach of backup heating from the bottom is allowed for with heat pumps but not for solar. Why is this? Why does the specification of water storage equipment not form part of the heat pump installation specification when it is part of the solar thermal installation specification? It is because the heat pump specification, quite correctly, is not seeking to prescribe equipment at all, given that equipment is to specified elsewhere, under the MCS technology section, which in fact, is the appropriate place for this?

Or conversely, why is the specification for solar hot water storage not applied to heat pumps?   The non-alignment of these two documents functions to keep innovative solar thermal installations off the grant aided market. Common areas such as hot water storage should be treated commonly across technologies rather than reinvented each time – with a risk that they might diverge unjustifiably. Is it time to implement this suggestion?

Regarding Legionella and solar water heating, MIS 3001 makes no reference to the HSE’s Code of Practice and Guidance L8. This is surprising. Reference to full compliance (not just to partial compliance, such as a raised backup heat exchanger) needs to be inserted. MCS has in effect taken a position to exclude L8 in violation of its own rules to comply with all applicable regulations etc. Perhaps this matter should be examined by an independent and informed body. Certain contributing parties to MCS such as the Solar Trade Association have been violating L8 para 158 for years (and which excludes those who have not such as ourselves). Please adopt the precautionary principle and refer to L8 compliance in all relevant MCS documents.

There is selective application of Government guidance. Where this happens appears to be arbitrary and it has to date resulted in the unfair exclusion of our installations from MCS. It is inconsistent that while the HSE’s guidance on Legionella (L8) is ignored (even though we comply with this and most MCS solar installations in UK don’t), on the other hand, another guide, the Domestic Heating Compliance Guide (which excludes our technology) is in effect treated as a specification. This selective application of guidance needs to be addressed properly. What if the position were to be arbitrarily reversed? The current selective approach to guidance is unreasonable and needs to be rectified.

Plus there is the fact that L8   also warns against cylinders plumbed in series. But that this is also being ignored by MCS, who permit these too.

Not only is the absence of Legionella guidance a problem – particularly when it is actually a legal requirement to comply with L8 in rented and commercial properties. Elsewhere, where guidance is actually present it unreasonably becomes a de facto specification. I refer to the unreasonable transformation of this Domestic Heating Compliance Guide into a near-exclusive specification.   It is surely anomalous and anticompetitive for MIS 3001 on the one hand not to require proper compliance with L8 guidance at the same time as turning the Domestic Heating Compliance Guide into a specification. The consequent problem is that Domestic Heating Compliance Guide type installations gain accreditation even though most of them do not comply with L8’s guidance para 158 on Legionella. And bizarrely, installations which do comply with L8 guidance are currently excluded from accreditation.

Technically, heating solar cylinders right to the bottom at sunset for about 2 hours is an efficient way of operating a solar thermal system which complies with HSE’s L8 guidance on Legionella para 158. Any installer who uses this approach, called dedicated solar volume in time, currently has their installation unfairly and illegally excluded from MCS. This generic (not brand-specific) exclusion of safer ways of installing needs to be remedied by its prompt inclusion.

Then there is the discretion issue: discretion which allows certifiers to charge a fee to look beyond the Domestic Heating Compliance Guide specification (yes this is a contradiction!). But BRE looking beyond this guide is not happening in reality. I refer to the last paragraph of MIS 3001 para 4.4.3 here. BRE, who were until recently monopoly providers of solar installer accreditation, had initially agreed to implement this paragraph for consideration of our dedicated solar volume in time installations. But when we asked for our installations to be considered in the proper context of safety (including   Legionella) BRE changed position and refused to do so, thus leaving our technology unconsidered and in limbo – with substantial loss of business as a consequence. While the carbon losses to the environmentstack up too.

DCLG’s Domestic Heating Compliance Guide when used as a specification is market limiting and it is essential that alternatives to guidance are available and properly considered, (not least in the context of HSE guidance being ignored on Legionella).

The national territory issue. In any case the Domestic Heating Compliance Guide falls only under the English and Welsh building regs. The Scottish Solar Heating Guidance document does not exclude our technology. On whose authority are Scotland’s fairer rules being overridden by England’s less fair rules? Why are BRE / MCS in effect stopping our Scottish invention from being rolled out in Scotland under the LCBP grants scheme?

Besides the Domestic Heating Compliance Guide, several other of the documents referred to in MIS 3001 are also inaccurate and market limiting.

The next example concerns repeated reference to the The Solar Trade Association (STA) endorsed guidance document CE 131. This was published by the Energy Saving Trust (EST) apparently with the help of state funding. While this is supposedly for indirect installations, but the question of whether the funding was delivered with this intention has not been satisfactorily answered yet. Despite this supposed limited technical scope, this EST document nevertheless takes several inaccurate and commercially biased swipes at direct solar thermal systems. Alarmingly it also describes “established” products as best practice. This backward looking approach is a sure way to slow or even to halt innovation. CE 131 is multiply flawed. For example it also incorrectly describes solar water heating as zero carbon when most of it is not. I refer you to the attached document as evidence of it being market limiting and misleading, and as an inappropriate document to refer to in MIS 3001.

Another problematic document referred to in MIS 3001 is the Government’s Standard Assessment Procedure for energy and carbon impacts etc, (SAP 2005). As for its exclusionary nature, no thermal stores are shown in SAP, despite our requests for them to be included. SAP as a calculator is a blunt instrument which under-represents the performance of our technology, according the attached independent technical review by TUV NEL. Might it be possible to permit the use of more accurate alternative methodologies for energy and carbon calculation? Or to ask for the fast tracking of the development of a much better SAP?

Again regarding other exclusionary uses of standards and documents, there appears to be an exclusionary reference to BRE’s in house website, grenbooklive for product accreditation in the foreword. Solar Keymark is not mentioned. Please could Solar Keymark be included in all appropriate places?

Ii is clear that initial assurances to us that MCS was not to be a repeat of the previous Clear Skies scheme with its exclusionary “industry consensus” producing market limiting component specifications and further reliance on market limiting external documentation – have not been fully met. One glaring example of such as component based specification is the exclusion of the use of bought in heat as a freeze control strategy in para 4.4.1 This does not affect us but is still worth of comment. Given that older designs of solar thermal systems negate 10% or even more of their captured energy as bought in as electricity for running pumps and controls, it surely seems reasonable in systems which do not use so much, or indeed not at all, for them to be allowed to use up to a similar amount of bought in energy for any purpose at all that   they require – including freeze prevention. But para 4.4.1 operates as an unlawful market barrier on solar designs which occasionally allow warmer water to circulate to prevent freezing. While we are not affected by this issue at present, it is cited as another example of poor regulation. Innovators or suppliers of existing systems may want it opened up for the future.

Why reinvent the wheel? Of course there is an existing pan-European accreditation system already available for solar collectors and systems. This is called Solar Keymark. Having initially taken a “sponsor me if you want me to be flexible” approach” Solar Keymark now appears to be managing in a more equitable way to accommodate the way that European solar thermal standards are market limiting against innovations. UK taxpayers funds should never have been wasted on tryng to duplicate an almost identical accrediation system. Constitutionally, the laboratories which test solar panels have a major input into Solar Keymark, while, thankfully, industry lobbyists now have less influence than before. The unfortunate fact is that in UK the total number of accredited solar thermal testing labs is zero. This begs the question of whether the UK is simply too lightweight and open to manipulation by industry to take a lead in developing solar standards – not least compared to Solar Keymark’s Europe-wide technical heavyweight approach.

2/ MCS 004 (Solar Thermal Product Specification)

MCS refers to the solar water heating standards EN 12975 and EN 12976. These are out of date and market limiting, as is Solar Keymark (more on this later) which is based on these standards. Testing, when required under these standards, should only require relevant tests in these standards, not to irrelevant or inappropriate tests, a can sometimes be the case at present. If tests are not relevant then, where appropriate, alternatives may be sought. Where concerns are raised about the conduct of regulatory bodies, these should be taken seriously. For example MCS needs to be aware that regarding Solar Keymark, that the Chair of the Solar Keymark Network has told me that the sponsorship of the Network by an evacuated tube company which gained special exemption from an irrelevant test in EN 12975 and its timing as gaining Europe’s first award of Solar Keymark was influenced by it having provided sponsorship.

The use of out of date standards with limited technical scope such as EN 12975 and EN 12976 as the near-exclusive entry route for solar thermal is inappropriate. I offer to supply evidence of the market limiting nature of these standards, some of which is already in the public domain, for example on youtube. If these are to remain as named standards, genuinely viable alternatives must be accessible, affordable and achievable in a timely way. Reference to these standards mean that MCS 004 excludes roof integrated systems such as Megasol and solar slates systems illegally and unreasonably. These need to be included.

Eco-labelling is absent. The fact that MCS fails to incorporate any viable product Eco-Labelling scheme is another major missed opportunity given that simple mechanisms already exist for this to happen. But perhaps such a scheme would show up the flaws in old solar technologies so glaringly (such as double the lifetime carbon footprint of some newer forms of solar thermal vs old solar) is a conclusive industry-embedded reason for such a consumer-oriented approach never to happen.

The training requirements are unreasonably old solar product-specific. As such they include requirements for 1/ inappropriate levels of formal qualification, 2/   a possible requirement for irrelevant qualifications, and 3/ qualifications based on state aided training material such as BPEC/STA material – which is blatantly exclusionary. I addition I am concerned more generally about the unreasonable continued exclusion of simple and appropriate types of DIY solar thermal from state aid including via MCS.

To introduce the matter, MIS 3001 v 1.4 says that Item 5 covers the competence of staff and adds:

“Note: Due to the current development of the Sector Skills Agreement and the review in progress
of the National Occupational Standards for this technology, the indicated suggested scope in the
appendix “A”, may change.

So what is contained in Appendix A? At present it states:

APPENDIX A: QUALIFICATIONS OF STAFF The following qualifications may be suitable to satisfy the requirements detailed under item 5:

1 NVQ Level 2 plumbing or H&V (Domestic) or equivalent
2 Part P for electrical works, limited scope or above
3 Recognised solar system design and installation course.

I appreciate that these requirements may change – and I hope that that indeed they do, provided they actually address my concerns properly.

But before I address these three points, I would like to address the fact that the appendix first refers to “staff”, rather than to “installer”. Because even this interesting choice of word, staff, rather than installer, makes an exclusionary presupposition against DIY solar. It would be interesting to know who produced this wording. The exclusion of DIY solar installers, whether implicitly or explicitly, unreasonably excludes our simple and different technology from accessing the DIY solar thermal market because of unneccessarily restrictive access to state funding – via accreditation schemes such as MCS. Here goes…

1/ On the NVQ Level 2 plumbing or H&V (Domestic) or equivalent requirement. Might this be an inappropriate (too high) level of formal qualification for some simple but innovative installations? For repeated professional installations, we can accept this restriction for the sake of equity. But for a DIY Solartwin at home it is too onerous. Here is an explanation: the installation of a typical Solartwin, as a low pressure open vented retrofit system, as applies to most homes, it it very easy from the plumbing perspective to follow our detailed manual. The only connections into your home’s plumbing involves just 2 new connections to existing pipes. These connections are very easy to do: they are virtually the same as you would need to make to fit a washing machine or an outside tap for the garden. True, there are 4 other pipework connections to make,   (two at the pump and two at the panel) but we have deliberately made these very easy as well. Indeed these connections are simillar to pushing and securing a hose on to a connector at an outside tap. No soldering is required.

There is no reason why a homeowner should be excluded from connecting a new tap, nor a hose to that tap by the UK solar thermal industry. Similarly, nor should a DIY solar installer be prevented from connecting up a Solartwin – for a grant – by MCS installer rules as they are currently written.

The fact that old solar is far more dangerous and complex than several innovations, including as ours is well accepted as a drawback for this particular technology. But their technology-specific technical problems should not exclude our DIY customers from accessing grant aid via MCS. Nor should the solar industry and Sector Skills Agreement / Solar Trade Association (STA) stranglehold (which operates informally on the implicit industry consent that all state aid on solar should be channelled ONLY via solar installers) prevent them from gaining what is due to them in UK (and in Ireland as a result of BPEC’s cross-border application into the republic of Ireland).

2/ On the Buildng Regulations Part P for electrical works, limited scope or above.   There seems to be a blanket requirement for an irrelevant qualification here. The Electrical aspects of the building regulations Part P are not relevant for systems where the voltage is under 50V. Solartwin’s is under 12V. The solar installer lobby, via MCS, might equally unreasonably try to mis-apply part P to prevent people from replacing batteries in torches or from connecting loudspeakers to their home stereos! We think that BRE accept our position here. But the documents must be re written to drop its incorrect, current “old solar is all solar” presumption here.

Looking at the issue of discretion of Part P compliance from another perspective, I am not 100% confident that all MCS solar installers whom I have met meet the MCS requirement for part P anyway. Perhaps you can check whether there is use of discretion by certifying bodies in this matter, despite there being little scope in the document for this. One would certainly expect that, where mains electrics are involved, there is no discretion to exempt this Part P requirement for installers, at least without reference to an independent higher body. I ask this in the context of BRE’s intransigence in using their discretion NOT to consider the performance of our HSE Legionella L8 compliant installations in the context of safety under clause 4.4.3. – where the use of discretion IS specifically allowed.

3/ Regarding the recognised solar system design and installation course, firstly there appears to be no definition of what “recognised” means. Can this be defined? The interpretation which we have had from BRE is that it must be the STA / BPEC qualification and that alone. Is there any agreed position or is it informal and ad hoc? STA/BPEC qualifications are based on state funded training material which is blatantly exclusionary. Having no alternative I attended this as a 4 day course at the Centre of Alternative Technology (CAT), and persisted with it to the final day (and passed!) despite being dismissed as paranoid in front of other course members, by an angry course coordinator, after I had tried to suggest some helpful ways for the course provider to overcome its shortcoming and market limiting effects. My verbal and written requests that CAT might want to notify their concerns on the training material they use being market limiting to a higher level, appear not to have been taken up.

If regulators need to see numerous detailed pages of evidence of the STA / BPEC manual content problems I can send regulators a detailed analysis of a past version of their manual, few improvements from which have been adopted. There is also a summary of some correspondence with BPEC here: http://www.aecb.net/forum/index.php?topic=240.new

I suspect that complex old solar installations do in fact need to be highly regulated, given that many of them use mains electricity, can even use naked flames for solder plumbing, require handling large pieces of glass at rooftop height, and that even in normal use many systems regularly store large amounts of energy in the form of superheated steam in private homes. So perhaps even extreme constraints may need to be placed on who installs it – with the development of an high priced elite guild-like mentality among installers.

But when innovators such as ourselves have deliberately, and at considerable cost, designed out such serious and numerous barriers to safe, high quality DIY installations, for example by our installations being low pressure, low voltage and by usually operating at lower temperatures, and by requiring detailed photographic validation of compliance with our instructions for warranty and commissioning purposes then we think that such systems need separate, fair consideration.

Innovation can be radically different – and ours is. No longer should our installation requirements be tied in alongside inappropriate and market limiting restrictions – which are written for (and to a great extent by) our old solar competitors.

The wider DIY exclusionary context. Besides the above concerns about MCS, we also believe that similar unfair market limitations have been unreasonably applied against DIY solar in the Clear Skies solar grants schemes and in numerous other regional schemes such as Solar For London.

3/ Governance of MCS   (and its management of BRE as an MCS certifying body)

Representation of innovation on MCS committees. Asking established trade bodies to represent new technologies which threaten their members’ interests is as unlikely as asking turkeys to vote for Christmas. There must be accessible routes for inclusion of innovation. At present, if it is able to gain representation at all, and this is not always the case, fair access to innovation usually gets marginalised and excluded by the majority dominance process of “industry consent”. Because innovation cannot command a majority, it needs direct representation at MCS and a more inclusive approach from those who draft documents.

Composition and influence. MCS should deliver confidence that access membership of MCS committees is balanced. Who can and cannot attend meetings (also the voting rights) need to be clarified and interpreted consistently. Are there enough independents, academics or representatives of safety and consumer interests at the MCS Solar Thermal meetings? I would also suggest that a representative from UKAS and an independent adviser be present to cover competition issues.

Clearly written, high principles of personal conduct are required. These should cover all relevant areas – including of potential conflicts of interest. I hope it is useful to suggest that perhaps these should align with those in The Civil Service Management Code. I draw particular attention to this document’s section on Principles and the details contained in 4.1.3 para a, c and d including freemasonry.

Conduct of meetings / document writing. MCS meetings should be chaired and minuted by an independent secretariat, not by parties who may have commercial or other interests. Care should be taken to avoid a particular individual, lobby or organisation dominating the content of either MCS documents or the documents which are referred to by MCS. Technical authors and consultants who also promote themseves as “regulations consultants” or as lobbyists then should no longer be used. Documents where such potentially double funded consultants have had a significant input should be scrapped and rewritten from scratch.

The above precaution will avoid suspicions of “the Lord Truscott effect” affecting this scheme.

We have made repeated requests to BRE staff to pass on our concerns regarding regulations and governance to those who need to know. I think that a reasonable duty should be applied to certifying bodies to do this We have on numerous occasions also passed concerns to DTI/BERR/DECC, only to be disappointed to find that that they have not been taken on board on in most cases, either.

In addition there is the problem of BRE’s complete refusal of any certification whatever of our company as solar thermal installers. While we hope this will be solved very soon, this problem has two components. First BRE refuse certification for us installing even traditional solar installations despite BRE confirming to us that there were no outstanding issues at all with our application in this area. Second, they have also backed away from proper consideration of the additional “dedicated solar volume in time” extension to scope which we requested under MIS 3001 para 4.4.3. despite BRE contracting with us to look at this.

We must point out our concern at BRE refusal to assess dedicated solar volume in time installations in the context of safety. Also that this is a generic industry issue and not a single company specific issue, even though we had offered to pay for its consideration, and it could have benefited others in the industry, not just us. As a consequence of this refusal and other issues, including BRE’s repeated failure to pre-emptively to solve such issues last year when we raised them, we view BRE’s conduct as repeatedly falling below the high standard that which we had expected them to deliver, given that they were at that time, a monopoly installer certifier under MCS.

This continued unreasonable delay means that we are unable to offer grant accredited installations to our customers while our MCS installer competitors are able to install our own product with thermal store installations, for example, under the UK grants scheme LCBP. This anomaly appears to be illegal and anticompetitive. It needs to be fixed soon.

If the above are properly addressed together, then today’s market limiting nature of MCS may be rectified. If not all issues are rectified, a real risk exists that minimal improvement will be achieved. I hope that this makes a useful contribution to debate.

Regards, Barry Johnston.

Managing Director Solar Twin Ltd

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