Solar news 10 January 2012:

Will UK’s old solar crummy old MCS regulations be changed soon?

UK solar consumers need to know that influential members of the “traditionally-built” old solar-heating lunch-club have put the brakes on the UK solar thermal market for over a decade, to the detriment:

• of consumers themselves, (eg in areas of both safety and information, such as legionella safety, and telling people about solar installation performance, maintenance, operation costs, and money savings).
• of innovators (not only ourselves but other solar innovators).
• of free speech (I have been ordered by solar industry top brass to shut op or face “action”, which has turned out to be nasty).

One wonders, will a new multilayered revenge attack on the viability of several innovative solar thermal products (including Solartwin’s) soon be launched in a coordinated way by the established solar heating industry? Will they choose the Microgeneration Certification Scheme (MCS) as the arena for the usual reasons, ie that:

• MCS is where eligibility to the RHI is decided. Hundreds of millions of pounds of subsidy may soon be approved for or denied from UK-made innovations like ours.
• MCS contains a rump solar thermal committee where old solar interests have numerical majority control.
• MCS governance is weak, despite MCS being a standards-setting body. For example, the solar thermal committee has not even got a number for a quorum (one person could attend and legitimately decide the fate of over £100million of state spending – it’s that BAD!) and MCS even refuses to adhere to BSI’s more rigorous standard-making procedures. Even where written governance exists, it is often ignored, for example by giving members (ie those who are not in the same circle as the Chair) only 2 working days notice to read documents which could decide the fate of an industry. What a crummy regulator!

In summary, I fear that the following could happen. But it does not have to happen. I think readers need to know that old solar’s latest approaches again could include numerous wrecking tactics, any one of which could ruin us, such as seeking to:

• Block us by seeking one MCS-favoured plumbing approach which excludes us by reopening the old “dedicated solar volume in time” issue which was accepted by MCS 3 years ago. The market needs inclusion, not exclusion of innovation.
• Block us by banning freeze-tolerant collectors by giving reference to a poorly written external training document which says you must stop freezing (rather than tolerate it). Again UK needs inclusion, not exclusion of innovation.
• Block a huge market segment from us by excluding installers from needing to be trained about our technology, thus closing off the potentially huge installer-reseller market to us again by giving reference to this external training document.

There are many other issues as well: this is just an example of what might happen. We fear a rapid resumption of the old solar industry’s usual revenge attacks / market grabs, now that the OFT have diverted their gaze away from the solar industry again.

Of course, Government knows full well what needs to be done: [but they sit on their hands] full declarations of interest, proper consumer representation, academic representation, an independent Chair, a neutral rep to the SMG, not one who threatens dissidents, members’ requirement to be more inclusive, members being given proper notice to read documents, MCS getting a proper BSI type constitution and proper conduct. But much of this is just not happening because it simply suits UK’s powerful market benders to stodge up UK’s regulators. Is MCS fixable?

My suggestions for improvement in UK’s solar water heating standard (called MCS MIC 3001) include:

1. Solar Legionella safety. Firstly, alignment of its wording to mention HSE Approved Code of Practice and Guidance on Legionellosis document ACOP L8 (as the MCS heatpump standard did last year). Perhaps secondly, accurate reference to Dr Tom Makin’s once covered up solar and Legionella report, now a neglected four year old, which, with reference to twin coil solar cylinders, says damningly: “In twin coil storage cylinders a solar coil positioned at the base of the cylinder is used to pre-heat the water, and a boiler coil is fitted above the solar coil to raise the temperature of the water at the top of the vessel to 60OC. This arrangement may permit temperature stratification that supports the growth of legionella bacteria at the base of the vessel. If the solar coil does not generate temperatures that bring about thermal inactivation of legionella bacteria, and if the residence time for water in contact with the boiler coil at 60OC is less than that required to effect thermal inactivation, then it would be necessary to provide a further level of control e.g. consideration should be given to programming the boiler coil to heat the entire contents of the solar hot water cylinder once daily, preferably during a period when there is little demand for hot water. Where legionella control is not achieved through raised or lowered temperatures, alternative measures such as the use of appropriate biocides, should be considered.” and “…it has been clearly demonstrated in HCWS and in many other varied water systems that Legionellosis and Lochgoilhead Fever) can arise from any water system that supports the proliferation of legionella, and which discharges the bacterium in the form of aerosols proximal to individuals who may be predisposed to such infection. It is therefore highly likely that those solar pre-heating water systems which support the growth of legionella bacteria and do not achieve thermal inactivation or control of legionella bacteria in some other equally effective way, are creating a health risk with regards to legionella infection. UK, manufacturers, suppliers, installers, and owners of such water systems as solar pre-heating systems, have a statutory obligation to assess such risks and implement measures that will effectively control those risks.” How on earth MCS can allow David Matthews (the ex-Solar Trade Association Chief Executive who has even ordered me and threatened me to shut up on the Legionella issue to represent the Wider interests of the UK Solar Thermal Industry at the MCS’s Top Level Standards Management Group is an interesting question.
   
2. Allowing MCS installers to validate third party domestic solar heating installations. A hands-off approach already happens for trade only and so today’s rules are blocking MCS accreditation of simple installations which are being done by other competent people. If your solar heating installation “does what it says on the tin” then it deserves an MCS certificate – and a subsidy.
3. Temporarily deleting a market limiting reference to EST’s flawed CE 131 solar water heating guidance document, until it is updated (EST have acknowledged that it is flawed. See our notes on its annotated version in the link below.
4. Making sure that solar panel installer training requirements are actually relevant to particular solar water heating technologies (ie not all have mains leccy, antifreeze, high pressure, etc) This will ultimately save the solar thermal consumer money by not requiring irrelevant installer qualifications. Right now solar installers are trained mainly on old solar and not on innovations sch as ours. This means that plumbers and the like will not promote innovations and there is an old solar technology lock-in to the solar market. National training and skills organisations like Smmitskills really will have their work cut out getting the skills scope widened.
5. Getting rid of solar red tape which takes the form of a burdensome formal quality management system, for solar installation micro-businesses of 4 people or less.
6. Perhaps in return for this red tape cut, improving and extending consumer information about solar panel microgeneration vastly, including:

• By ending the mains pump power concealment in the solar thermal system energy performance estimate (where the “SAP 75kWh pump figure” was, er, omitted). This change will reduce fraudulent performance claims and save the taxpayer money from paying out money for non-existent energy benefit under DECC’s RHI domestic solar panel subsidy scheme phase 2. This issue also applies to heat pumps.
• By introducing relevant geographic variations in the energy performance estimate of solar panels, as Which? magazine has asked. This means that in Cornwall your solar performance estimations will be higher.
• By MCS installers telling consumers plenty of real useful information about maintenance, running costs, and environmental performance in several new areas including “life cycle analysis” and “years to breakeven” for “embodied energy and carbon” for solar panel installations which make hot water.

Last year, I formally offered these suggestions, in a more wordy technical format, to the Microgeneration Certification Scheme. This is an industry-led, self-regulating organisation which may or may not choose to adopt some or all of them. Or it might kick them into the long grass.

What will happened?

Because of MCS secrecy rules, members of the public, many of whom who support the principle of open government, will not be able to find out if any of them are accepted until the next version, if any, of MCS’s MIS 3001 solar water heating installation specification is eventually published.

Happy waiting!

I hope that this is interesting. Incidentally, outside the above MCS solar heating installer envelope, I have also asked, for at least the sixth time, for MCS to be categoric about convergence with BSI‘s far better procedures and approaches to innovation, which has not been taken on board, also about disclosure related to freemasonry, which has, predictably, been fudged to mean: not unless they want to.

Incidentally, I am the founding and sole member of regarding the Praiseworthy International Society of Secrecy. Whoops! Now I must expel myself for disclosure.