The UK Solar Trade Association’s unlawful boycott of Solartwin must end.
Here is a “to-do list” for the STA Solar Thermal Technical Committee.
A/ Totally end the boycott: including of STL people, of the STL company, of STL technologies, of routes to market, and totally end the nasty culture which supports it. Accept the technical validity of the Solartwin Freeze-Tolerant PV Pumped Solar Water Heating Technology in full and without further delay or reservation. Protect STL and its technologies from unfair denigration and unfair attacks by any STA members. Implement its technical acceptance fully and promptly. Deliver a level playing Field. Take full action to undo all past damage and all of its accumulated and ongoing negative effects including financial.
B/ Correct the numerous errors and incorrect documents, undo the reputational damage, repair the representational omissions and and procedures unperpinning the boycott, in full and rapidly. Represent STL’s interests fairly at regulatory and all other fora of actual or potential market significance. Allow STL to be directly represented where its expertise is needed to broaden or balance the knowledge base. Notify the appropriate authorities of an urgent need to correct market limiting material and programmes in all affected documents including but not limited to:
- MCS MIS 3001 solar installers standard
- Domestic Services Compliance Guide
- BS EN 12975 which needs to fully accommodate innovation including polymers and operational methods.
- SAP 2009
- The CIBSE solar guide
- The EST document CE 131
- The EST draft new solar thermal consumers guide
- PAS 2030
- The STA / BPEC solar training courses documentation.
- The EST Solar THermal Field Trials Report which states gross energy when net would be more honest, and which fails to mention legionella and which fails to state that CO2 pollution is an avoidable consequence of mains solar pumping.
C/ Oppose the revision of BS 5918, a defective 23 year old standard, which STA have been lobbied to revive by BSI Solar Thermal Technical Committee RHE 25 Chairman, Chris Laughton, apparently as part of a Legionella cover-up.
D/ Solar Thermal Training. Immediately seek to undo the “route to market” limitations caused by the BPEC training manual by recommending that all training centres properly represent innovationin their required training equipment, real current examples of freeze-tolerant, PV pumped, direct-in, open vented, heat export, designs. The BPEC manual (like its market limiting predecessors) were funded by state funds. In this case £86k, were passed to STA, then to Filsol, then to Chris Laughton for its publication. Fund the retraining of existing BPEC installers.so that the STL technology is properly understood, specified and installed. Revised assessments should reflect these changes fully. We offer to assist where we can in delivering this.
E/ On legionella: State publicly, that dedicated solar volume in space is not recommended on safety grounds in any solar thermal installation. Also that L8 guidance is the starting point of reference for hot water and solar thermal installations, except where regulations override them, such as medical plumbing. Publicly withdraw STA’s position that not heating daily to the base of hot water cylinders is a safe practice in domestic homes. Stop seeking to support or implement the Legionella safety and liability cover up via numerous fora and documents. Ensure that performance is always considered in the context of Legionella. The past position of doing so our of context needs to end even if it conveniently validates exclusion of our technology.
F/ Also regarding performance, press for changes in MCS to end the fraudulent 75kWh pump power deletion from MSC 3001’s performance estimate. Press for net (not gross thermal) energy under SAP to be quoted and funded under RHI and in all other areas. Press for net energy benefit to be funded under RHI. Tell all STA members and the wider solar thermal industrial community very clearly and promptly that false claims like the following for mains pumped solar, are not permitted by MCS, REAL, STA and ASA.
- Free energy
- Free hot water
- Zero carbon / Virtually zero carbon operation
- No maintenance / no scheduled maintanance
G/ Environmental performance transparency. Press for Life Cycle Analysis (LCA) and Coefficient of Performance (both Carbon and Energy) CoP data to be supplied by STA members under MCS for named, typical microgeneration installations, including solar thermal.
H/ Close the Non-REAL Loophole. Address promptly the continuing third party false claims problem of major STA members, including STA members which are solar thermal equipment suppliers, but which are not REAL members, such as Worcester Bosch, who hold the Vice Chairmanship of the STA, making performance claims which may not comply with REAL and ASA such as: “6 year payback” (in a no grants scenario) and “very little maintenance” (yet needing “a thorough check by an engineer every 3-5 years”.) Identify the false claiming members concerned. Name them, and warn STA members who are installers of their product not to repeat such claims to consumers unless the claims can be properly verified.
I/ Clarify / amend the STA website and allow us to contribute other reasonable amendments in a timely way.
State that there are at least five types of solar plumbing, these being (They all need to be illustrated and listed as suitable. Not just the first two – and even the first two need to have shunt pumps shown. Issues such as comparative legionella safety, heat to base stores, direct stores, retrofit systems and thermal stores should not be marginalised or boycotted any longer.)
- Indirect twin series cylinders with shunt pumps
- Indirect twin coil cylinders with shunt pumps
- Indirect heat to base cylinders (retrofits or replacements)
- Direct heat to base cylinders (retrofits or replacements)
- Thermal stores.
State that solar thermal collectors can be:
- metal flat plates
- evacuated tubes
- unglazed collectors
- Freeze tolerant flat plates (which should not be marginalised or boycotted. The pros and cons of not using antifreeze but using soft water instead, with drain down or freeze tolerant systems should covered fully and fairly – and not be distorted, marginalised or boycotted.)
State that circulation can be
- thermosyphon or forced, and if forced then
- low speed (using energy saving microbore pipes) and high speed (wasteful fat pipes)
- on/off or variable speed
- mains powered or PV powered
- Low speed, variable speed and PV pumping (which should not be misrepresented, marginalised or boycotted any longer. Quantitative clarity on operational energy and carbon clawback (parasitics / coefficient of performance etc) should not be marginalised or boycotted any longer.)
J/ Remove the installer monopoly and the DIY solar boycott where it is appropriate to do so. Press for changes in MCS to allow third party MCS installer-validated domestic solar thermal installations at least where they are retrofit, all voltages below 12V, and solar circuit is open vented, not sealed or pressurised. Press to Support Fuel Rate VAT (currently 5%) or lower, for DIY environmental technologies.
K/ Press to scrap the Enhanced Capital Allowances’ current exclusionary and market-distorting “minimum efficiency” component eligibility criteria and replace them with wider carbon-related and energy related criteria including carbon payback time and low Coefficient of System Performance and relevant life cycle analysis data.
L/ Stop trying to censor STL. Allow us to bring the debate about the solar industry conduct and ethics to a wider audience. Allow us to sing uncensored about our technology’s benefits and to make accurate statements and descriptions fair comparisons including:
- The lower a backup heater is in the cylinder the more effectively it is likely to do its job of heating the water to the bottom and also killing Legionella.
- Ultra low flow systems using small diameter pipes have smaller volumes and smaller surface areas and will inevitably lose less distribution energy from their pipes.
- PV pumping is inherently more sustainable than mains powered pumping.
- Low voltages are less likely to injure or kill than high voltages.
- An open vent is simpler and less likely to malfunction than a mechanical valve.
- Low pressure is safer than high pressure. This is why the Pressure Equipment Directive was brought in.
- Using less glass than normal is safer.
- Traditionally built solar thermal typically has a 20% carbon clawback. Zero carbon operation is greener
- Our republishing and recalculate data from EST / DTI DECC etc publications which support this 20%
- Calling for discloure of LCA / CoP is important in Microgen / solar.
- Our industry needs much better governance, perhaps even statutory regulation.
- More than half the solar industry mis-describes or mis-sells.
- Solar industry leaders have been manipulating reglations to their commercial advantage, obstructing innovation, covering up and lying about legionella and performance shortcomings and thereby distorting the solar thermal market for many years.
More generally the WG could participate actively in the following as well:
M/ Boost Industry Governance.
- End the culture of impunity. End Intimidation, threats, coded warnings
- Work to of proper constitutions (MCS solar Thermal WG does not even have quorum after all these years!)
- End the “off-table and off minutes” culture
- Minimise last minute agenda iteams which contain key issues
- Prevent, where possible papers being submitted by people who fail to turn up to speak to them
- Condemn tart-consultants who spread their legs to the highest bidder
- End influence via sponsorships, gifts, reciprical favours
- End abuse of position
- End abuse of definition eg “best practice”
- End the practice of selective inclusion: eg in MIS 3001 the market limiting CE131 is IN while the HSE Legionella safety document L8 is OUT
- End selective interprtetation of rules and standards etc to the detriment of innovation
- End fillibustering, like what happened in the MCS solar themal ctee when we sought to be included
- End selective naming and promotion (eg photo credits for your mates in EST documents)
- End selective leaks, info, people (we have had our confidential documents leaked by STA)
- End secrecy in the operation of STA committees and regulators etc. This just allows misconduct to thrive.
- End the use of secrecy banning even the disclosure even of misconduct.
- End the cross linking and cross-reinforcing of junk market limiting docs
- Stop performance specs from becoming market limiting component specs
- End snap consultations on market breaking / making issues and timing such as 3 weeks over Christmas!
- Recognise that this is a false conflations industry consensus is different from a majority vote. The latter may bring exclusion.
- Take responsibility. When competition problems happen everyone becomes too busy, becomes a Jobsworth, says ot my buck, I’m moving on soon etc
- End the “you are ar single business” exclusion
- Exoend these issues to the international dimensions eg ESTIF / CEN / Solar keymark
- Commit to supporting innovation
- Commit to moving MCS into a far better regulated BSI framework. Press government for all MCS standards to be promptly superseded by BS or EN standards, to produced transparently by BSI and CEN procedures.
- Commit to transparency and a regulatory system which gives technical merit precedence over might and fat wallets and which fails to disclose hidden links such as freemasonry.
- Campaign for the RHI to fund net energy benefits only.
Please let’s now have a complete end to dirty tricks!
N/ Look at the people. Investigate whether all members of STA including the STA board, STA Council, STA Working Group and STA delegates or representative on other bodies including ESTIF, BSI, REAL and MCS are fit and proper people with regard to their roles and if not fit and proper then to ask them to step down.Press for immediate resignations of senior industry people who have not been helpful towards innovation including:
- Chris Laughton, the Chairman of BSI Solar Thermal Technical Committee RHE 25. Ask to replace him with a genuinely independent chairman.
- Seek replacement of Virginia Graham, REAL Code’s head who has pushed UK’s solar panel consumers away from great national suppliers and protected the STA’s Chairman from investigation when he made false environmental performance claims.
- Ask David Matthews, Ex-STA CE, and MCS multiseater to leave all his MCS seats. He has issued threats and ordered cover-ups about Legionella and parasitics in solar heating.
- Chris Roberts, MCS Solar Themal Chair who presided over dreadful fillibustering which kept safer innovations off the market and who was also obstructive while he worked at BRE.
- Howard Johns, STA Chairman. He lied repeatedly about environmental performance of solar heating.
- Stuart Elmes. Solar Trade Association’s TechHead & Market Maker/Breaker repeatedly failed to be balanced towards innovation.
I hope this to-do list is useful.
Regards, Barry Johnston, Managing Director, Solar Twin Ltd, 50 Watergate Street, Chester CH1 2LA