Conversations with Efficiency NB and various MLAs

Solar Domestic Hot Water and Solar hot water heating for homes and pools
Conundrum
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Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 12:22 pm

This thread is an archive about the ongoing conversations I have had with Efficiency NB, The minister of energy, my MLA as well as other local MLAs. The purpose is to provide anyone interested with the progress that we have made. The 'government' user is actually a posting account I have set up to help to organize the conversation.

Any notes that need to be made inline with the text will be done in red.

Feel free to comment on any posts. The idea behind this is to convince the government to offer rebates on solar hot water systems with a minimum amount of red tape and additional (expensive) requirements to the home owner.

I have probably annoyed alot of people with this because every time one of the 'low level' people replies to me, I return the mail CC'ed to all of the MLAs and anyone else who will listen. So far the process has been frustrating but I think I am making progress.

The goals are:

1. Have our solar collectors made eligible for the $2500 solar rebate.
2. Remove the requirement of F379 certification that drives the cost of a solar system from $3800 to $10,500 while doing nothing for the consumer.
3. Remove the requirement for an 'Energy audit' to be preformed.

In the past, only 5 solar rebates were given out because of various restrictions. I have inquired to see if these 5 were only test sites such as the Fallsbrook center, but I was unable to determine this due to the privacy act. I suspect that they were, and that would mean that the solar rebates did not benefit any homeowners in NB.

Without further preamble, here are the emails as they happened:



Conundrum
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Re: Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 12:23 pm

First contact email sent through the 'Contact Us' form on the Efficiency NB web site:

Hi,

I have a few questions to ask about the latest rebate program for solar hot water.

1. The wording for qualification of SDHW systems states: 'Must be certified to CSA F379 - Packaged Solar Domestic Hot Water Systems'. Does this mean that it requires a CSA certification, or can PEng sign off that the system in question meets this standard (as it works in Ontario and BC)?

2. If the system is sold to an individual, can the individual install it themselves, or are they required to pay an installer to put it in?

3. In the case of an existing residence, does the existence of an electric resistive heating system as a primary heat source make the user ineligible for the SDHW rebate?

Thanks,

-Brooke

Efficiency NB
Posts: 9
Joined: Tue Jul 19, 2011 12:29 pm

Re: Conversations with Efficiency NB and various MLAs

Postby Efficiency NB » Tue Jul 19, 2011 1:00 pm

Canned response, proving that a human did not actually read the email:

Hi Brooke,

Through the Residential Energy Efficiency Program, Efficiency NB provides advice on energy efficiency and financial incentives to help offset the costs of energy efficient upgrades so you can enjoy permanent energy savings.

To qualify for financial incentives for energy efficient upgrades, simply follow these four simple steps:

Step 1: Contact a Service Provider and have a Pre-Upgrade Assessment completed. A report and summary will be provided by the Energy Advisor who conducts the assessment.

Step 2: Upgrades are planned based on the information contained in the report. Upgrades must be completed and documented within 18 months of the Pre-Upgrade report. While building owners are encouraged to implement as many of the upgrades as possible, program participation does not require a specific completion level.

Step 3: Contact a Service Provider and schedule a Post Upgrade Assessment. The Service Provider does not have to be the same company as the one who conducted the Pre-Upgrade Assessment. A report and summary will be provided by the Energy Advisor, who conducts the Post-Upgrade Assessment.

Step 4: The Energy Advisor will assist with the completion of the paperwork necessary for application to Residential Energy Efficiency Program. The information will include some detail regarding project costs. The application package will be submitted, with the building owner’s consent, to Efficiency NB.

Step 5: The application package will be processed at Efficiency NB and the Residential Energy Efficiency Program incentive cheque will be mailed.

The following service providers have been licensed by Natural Resources Canada. Contact a licensed service provider to book an energy assessment of your home:

· Amerispec 1-866-922-6607
· Enercheck Solutions 1-866 990-2499
· Exp. 1-866-363-7752
· Legacy Technical 1-888 545-1882
· Sustainable Housing 1-877-722-2842

Do not hesitate to contact our toll free number for further inquiries 866 643 8833 ext 200.

Regards,

Conundrum
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Re: Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 1:08 pm


And this is why dealing with your monkeys is so frustrating. Please read the email before sending me a form letter.

-Brooke


2 things happened next. I sent the unfortunate response shown above because frankly I was frustrated that someone wasted my time to reply without answering my questions. I should also mention that I have asked direct questions under another email address and received similar canned responses, implying that if you take the time to send them an inquiry then obviously you are not intelligent enough to read the web page.

In response to the letter above, I received a phone call from the director of Efficiency NB. His rather rabid response was that it was not the fault of the staffer answering the email. He told me that they simply 'responded to the wrong email' and that I shouldn't refer to his hard working dedicated staff as 'Monkeys'. I had other names but I felt that this was least offensive.

As anyone in the internet age knows, when you click 'reply' you don't fill in the 'reply to who'. Thats a given. In any case, my name was on the email above, so unless they replied to someone else named Brooke, he simply lied to cover himself.

In the off chance that he ever actually reads this and wants to dispute it, the conversation was recorded so I have no problem debating that point.

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Re: Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 1:21 pm

The next step was to go directly to the source. I decided to email my MLA and all the local MLAs and have them pose the questions to the Minister of Energy. As the person who oversees the implementation of the Efficiency NB programs, it seemed like the most logical next step and followinf the proper etiquette, I did not contact him directly. Here is the email sent to my MLA, John Betts:

I recently had a conversation with a gentleman from Efficiency NB in reference to the solar hot water systems that we offer. They were not terribly helpful and I was hoping you could lend your weight to a question I have.

In the previous energy program they offered, ending in April 2011, they had a solar hot water rebate available. I would like to know how many of these rebates were actually paid out. It would be good for my own research to know how many applied as well, so that I can gauge the interest and the likelihood of being denied the rebate. I have had reasonably bad luck talking to the people in that office and I would appreciate your help on this matter.

Thanks,

Efficiency NB
Posts: 9
Joined: Tue Jul 19, 2011 12:29 pm

Re: Conversations with Efficiency NB and various MLAs

Postby Efficiency NB » Tue Jul 19, 2011 1:33 pm

Ok, getting somewhere, but now apparently I am female. No matter, thats a simple operation and quite common to correct. :)

Dear Ms. Flecknell:

Your e-mail dated May 27, 2011 addressed to Mr. John Betts, MLA, was forwarded to me in my capacity as Minister of Energy and Minister responsible for Efficiency NB.

Prior to April 1st, 2011, Efficiency NB’s program offered a 20% incentive or 0% loan for residential energy efficiency upgrade eligible under the Federal ecoENERGY Program administered by Natural Resources Canada (NRCan). As to the eligibility of domestic solar hot water systems, NRCan made several changes to the eligibility criteria through the life of the program. Efficiency NB records indicate that
only five systems were installed prior to the closure of the ecoENERGY program on March 31, 2011.

Significant changes to Efficiency NB’s program took effect on April 1, 2011. One of these changes was to enhance the incentives available for solar hot water systems for existing homes to $2,500 as well as to include an incentive of $2,500 for eligible new homes that have a system installed. The CSA F379 standard has been adopted by Efficiency NB.

I hope you will find the information provided useful. Should you wish to discuss this issue further, I encourage you to contact Mr. Joe Waugh, Senior Technical Advisor, Efficiency NB, at (506) 643-7832 or by e-mail at joe.waugh@gnb.ca.

Sincerely,

Craig Leonard
Minister of Energy
Last edited by Efficiency NB on Tue Jul 19, 2011 1:39 pm, edited 2 times in total.

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Re: Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 1:36 pm

Thanks for your reply to this matter. It is important to know how many people were actually able to obtain rebates from this program. The questions I had attempted to raise in previous contact with the Efficiency NB office were simply these:

1. The wording for qualification of SDHW systems states: 'Must be certified to CSA F379 - Packaged Solar Domestic Hot Water Systems'. Does this mean that it requires a CSA certification, or can PEng sign off that the system in question meets this standard (as it works in Ontario and BC)? Or does it even require an engineer to look at it, as long as we agree that any system we submit for rebate meets the standard?

2. If the system is sold to an individual, can the individual install it themselves, or are they required to pay an installer to put it in?

3. In the case of an existing residence, does the existence of an electric resistive heating system as a primary heat source make the user ineligible for the SDHW rebate? The wording in this clause seems to indicate if the home has electric heat, they must replace their heating system to qualify for a hot water rebate.

I was not able to obtain a satisfactory answer to these questions. Although admittedly, I am writing to you to try and further my business. As you can see from only 5 previous rebates, either the rules were interpreted too harshly, or the cost of the systems it too high for the home owner to afford.

As an importer of the products, I intend to distribute these systems to plumbing contractors. My complete system retails for $3800 for a 2 person household. The closest retail cost I have seen for a system that has CSA certified collectors is closer to $10,000. For my price, I could literally start selling these door to door if I am sure that the homeowner will meet the requirement and get the rebates. This will benefit everyone involved including the plumbing contractors, home owners and tradespeople that can install them. The system I offer meets the F379 standard, however we have not paid the additional fees to make them a 'certified package'. The only company that has, as far as I know, is Viessmann, a German company with money to burn. They offer a system that is almost identical and because of the costs to the end user, it is priced out of reach for the majority of New Brunswickers. This is why I asked question #1 above.

If the province is serious about moving forward with this initiative, the answers to the 3 questions I have asked should be obvious.
If the answers are:
1. No engineering stamps or certs are required, only efficiency reports or UL/CSA certs (as it should be if the system actually works and makes hot water)
2. Anyone can install it, and
3. Home heating system has no bearing on the eligibility

If the above statements are true, I can start advertising that we can supply a system that offers these rebates and actually install more than a handful of solar systems. Realistically by next year at this time, your office could advertise that 100 people took advantage of the rebate program instead of 5.

Please consider what I have said and give me your thoughts on these matters. Also, I should probably point out that I am a MR, not a Ms.

-Brooke

Efficiency NB
Posts: 9
Joined: Tue Jul 19, 2011 12:29 pm

Re: Conversations with Efficiency NB and various MLAs

Postby Efficiency NB » Tue Jul 19, 2011 1:43 pm

Dear Mr. Flecknell:

Further to your e-mail dated June 1, 2011.

Minister Craig Leonard has requested that I respond to your questions. As mentioned in his earlier response, prior to April 1st, 2011, Efficiency NB’s program offered a 20% incentive or 0% loan for residential energy efficiency upgrades which were also eligible under the Federal ecoENERGY Program administered by Natural Resources Canada (NRCan). The Federal ecoENERGY Program was discontinued on March 31, 2011.

During the period when both of these programs were running simultaneously, a homeowner wishing to install a solar domestic hot water system on an existing home could qualify for $1250 from the Federal program and qualify for the 20% incentive or 0% loan of up to $10,000 from Efficiency NB. At that time solar domestic hot water systems were required to use solar collectors that met the CAN/CSA F378.87 standard and provide a minimum energy contribution of 6000 MJ.
For reference, our collectors produce much more than this. Despite these significant incentives, only five systems received incentives from Efficiency NB.

To be eligible for these incentives, homeowners had to participate in the EcoENERGY upgrades program for existing homes. As part of this evaluation they were made aware of the incentive for solar domestic hot water systems as well as the incentives for a wide range of other improvements to their home’s building envelope and mechanical systems. With the aid of this information, homeowners made their own decisions. In many cases the most effective upgrades included increased insulation and installation of high efficiency heating equipment.

Efficiency NB’s program changes that came into effect on April 1 now require solar domestic hot water systems to be certified to CSA F379 – Packaged Solar Domestic Hot Water Systems and have a minimum output of 7000 MJ. At present there are six companies with certified systems and more that are in the process of being tested through the National Solar Testing Facility in Mississauga. Since this is the industry standard for a complete system, Efficiency NB has chosen to offer incentives to fully tested and certified CSA systems. A system could be installed partially by a homeowner but usually a plumber and possibly an electrician would be required for parts of the installation. Most municipal jurisdictions would require the use of backflow prevention to insure against accidental contamination of the drinking water which requires a licensed installer.

Under our Residential Energy Efficiency Program for Existing Buildings houses with electric resistance heat can qualify for any of the available incentives. Our Residential Energy Efficiency Program for New Construction does not offer incentives to houses where electric resistance heat is the primary heat source.

All residential equipment eligible for an incentive from Efficiency NB must meet certain criteria that can be confirmed by third partly testing or certification. This includes heating, ventilation or solar domestic hot water equipment. These third party bodies include CSA, ENERGY STAR and the US Environmental Protection Agency for wood burning equipment.

At this time there is a process for solar domestic hot water systems to be certified through the CSA standard. We can provide you with contact information for the testing facility if you wish.

In response to your three questions:

1. CSA F379 certification is required

2. Installed should meet local or provincial plumbing or electrical codes requirements

3. Home heating system has no bearing on the eligibility for existing homes. New homes with electric resistance heat are not eligible for any of the new home incentives

Again, I hope you will find the information provided useful. Should you wish to discuss this issue further, I encourage you to contact, at (506) 643-7832 or by e-mail at joe.waugh@gnb.ca.

Joe Waugh
Senior Technical Advisor
Efficiency NB

Cc Craig Leonard, Minister responsible for Efficiency NB
John Betts MLA
Jacob Beasley Executive Assistant to the Minister of Energy
Monica Mallalley Efficiency NB

Conundrum
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Re: Conversations with Efficiency NB and various MLAs

Postby Conundrum » Tue Jul 19, 2011 1:46 pm

In regard to your email about the solar hot water system rebates, I have a few comments on your email reply (attached below) that I need to point out. I will take this a piece at a time so that it is properly addressed.

Although I agree that it is helpful to require a test of some description for solar systems, the level of certification in this case does nothing for New Brunswickers and serves only to line the pockets of certification entities and ensure that only large corporations are able to profit from the sale of solar hot water systems.

As it was mentioned in a previous email, the rebates available under the previous program using only the NRCan certified collector list totaled only 5. The products are new in this market because of the certification requirement and therefore they are still a 'new' technology in the eyes of many consumers. It is true that the rebate amounts were not as generous as they are now, but in reality the requirements have now put the solar systems out of reach while simultaneously wasting the money of the smaller companies who bought the NRCan and/or CSA certifications for their solar collectors.

The CSA certification on the collectors that I offer, that cost over $10,000 is now nullified by requiring yet another certification to F379. In reality, this only adds to the cost to the consumer and ensures that fewer people are able to afford this type of energy saving equipment. It also serves as market protection for companies like Viessmann to ensure that they are the only product sold in an area. The product should be eligible for the rebates if it produced the proscribed 7000 MJ of energy and if it must be certified, then the certification of the collectors should be enough to satisfy the requirement. If the energy is being produced, it does not make sense that the owner would not use the energy in a hot water system, therefore the idea of a 'packaged' system certification is redundant. Further, if I were to install a 'packaged' system and add additional collectors to heat the homeowners in floor heating, that breaks the 'package' certification and therefore is no longer eligible because the F379 package has been adjusted.

Solar systems have been in use for over 60 years. They are an efficient means of heating water and are used almost everywhere but Canada. The evacuated tube system has been in use for 30 years and its efficiency has not improved that greatly. Most countries that are serious about reducing energy costs are not interested in red tape and making the wheels turn for the benefit of a few companies. That is why Germany, for example requires only CE certification. The cost for these runs the manufacturer $500 each instead of the CSA $10,000 certification fees. This reduces the cost of the solar system so that the average person can afford it. With financing and the $2500 rebate, we are able to install a system for 2 people at no cost to the home user through TD financial, the cost being financed with the rebate paying a large share and the power savings paying off the balance monthly.

I am not making the claim lightly that the F379 certification is simply to protect market share. Again, using the Viessmann example, the systems selling in Canada under the F379 banner are approximately $10,000 as a package. This easily puts them out of reach of all but the hard core environmentalists with a cash surplus. It would be simple to say that Viessmann products are sold at that price because they are of a specific quality, etc. except that all of the components can be purchased retail in Germany and shipped to Canada for a little over $5000. On this point I ask that you do not take my word for it. You will find them on the German Ebay auction site and I can provide a link if requested.

You also mentioned the requirement for backflow prevention on solar system installations. This should not be a requirement if food safe glycol is used such as the Dowfrost range of products, as we require of our installations. I hope that the backflow (and additional costs associated with it) is not something that you are advocating to potential solar system customers. This is a large cost to the home user that is not required as food safe glycol poses no hazard to drinking water.

In closing, I ask that the certification requirement to F379 is modified to require only the collectors to be certified as producing a minimum of 7000 MJ for any eligible solar system. This will open the market and allow a reasonable number of people to take advantage of this system. It will allow me to personally expand my workforce and instead of having only 5 rebates given out over the entire duration of the last program, you can help to make a difference and give out several hundred in the next year.

-Brooke

Efficiency NB
Posts: 9
Joined: Tue Jul 19, 2011 12:29 pm

Re: Conversations with Efficiency NB and various MLAs

Postby Efficiency NB » Tue Jul 19, 2011 1:50 pm

As amusing as this is, it underscores the attentiveness of the parties involved. This email was received 22 June 2011. Maybe he means he will be vacationing until next March?

I will be on vacation until March 3. Please direct inquiries to Hector Doiron for new home questions Hector.Doiron@gnb.ca 506 866-0551 and Mike Brun for existing home questions Mike.Brun@gnb.ca


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