The Louisiana Department of Health and Hospitals (DHH) and their PROHIBITED solar water heaters?

When the first DHH “Letter of Intent” came out in 2010 it almost completely eliminated the sale and installation of Solar Thermal water heaters in the state of Louisiana.  The restrictions were so bad that people actually stopped installing them.  This is a shame because solar water heating has a much faster payback time than solar electricity (PV).  It also has a much lower cost.  While we got MOST of the restrictions removed, one remains.

“Direct-Circulation Systems” are still prohibited.  Direct-Circulation is the simplest and most low-cost type of solar water heater available.  They have been in use for over 100 years and are ideal for areas like Louisiana when the temperature rarely goes below freezing.  I brought this to the attention of Mr. Jake Causey, the author of both the original and revised “letter of intent”, with the email below:

____________________________________________________________________________

Mr. Causey,

I am concerned that certain solar thermal systems were erroneously prohibited by the “Solar Water Heating System Design Requirements” revised letter of intent.  I reviewed our state regulations on solar water heating with Ole Pilgaard last week.  Mr. Pilgaard is on the Board of Directors of the Solar Rating and Certification Corporation (SRCC).  They serve local, state and federal regulatory bodies as well as consumers and the industry.  SRCC, from their website http://www.solar-rating.org/ is:

In 1980 the SRCC was incorporated as a non-profit organization whose primary purpose was the development and implementation of national rating standards and certification programs for solar energy equipment.  The corporation is a non-profit, independent third-party certification entity that is wholly funded through fees paid by participants and users. It is unique in that it is the only national certification program established solely for solar thermal products. It is also the only national certification organization whose programs are the direct result of the combined efforts of state organizations and an industry association involved in the administration of standards.

I am referring to what you call a “Direct-Circulation System” in the definitions.  These systems are utilized worldwide, popular throughout the United States and are not prohibited anywhere other than Louisiana that I can find.  They are recommended by our Federal government on the “energy.gov” website for climates like Louisiana.  http://energy.gov/energysaver/articles/solar-water-heaters  They were recommended for approximately ten years by the Louisiana Department of Natural Resources, Technology Division until the DHH letter came out.

There is no mention of any health concerns for this type of solar thermal water heater system.

While there may possibly be issues with home-made batch type water heaters I feel that as long as a solar thermal water heater system is “SRCC” certified it offers no health risks.

I urge you to revise the Letter of Intent to allow only SRCC certified water heating systems in Louisiana and remove the restriction on Direct-Circulation Systems.

Thank you,

Jeff Shaw, President
Gulf South Solar
4836 Revere Ave. Suite F
Baton Rouge, LA  70808
1-225-932-0035 (office)
1-225-932-2330 (fax)

NABCEP Certified Installer
_______________________________________________________________________

His response:

Mr. Shaw,

I thank you for your comments and concerns.

It is important to note that on February 20, 2013 the new 2013 Louisiana Plumbing Code became effective.  It can be found in the Louisiana Administrative Code Title 51 Part XIV.

It is available for download free online at http://doa.louisiana.gov/osr/lac/books.htm or a print version of the state Sanitary Code can be purchased from the Office of the State Register for about $30 I believe.

The solar thermal heating requirements were incorporated into our plumbing code revisions and are now a final rule.  As part of this rulemaking process we formed a revision committee comprised of engineers, plumbers, plumbing inspectors, and sanitarians in both the public and private sectors.  Many meetings were held and topics discussed with special interest groups including the solar community.  The final rule promulgated on November 20, 2012 that became effective on February 20, 2013 was the results of that workgroup and discussions.

Regards,

Jonathan “Jake” Causey, P.E.

Chief Engineer
DHH-OPH Engineering Services
628 N. Fourth Street
P.O. Box 4489

Baton Rouge, LA 70821
(P) 225-342-7499
(F) 225-342-7303

___________________________________________________________________________
My final response:

Mr. Causey,

I appreciate your prompt and detailed response to the issue of solar water heating.  I was able to locate and read in the document where “Direct-Circulation Systems” are still prohibited.  I would assume this would have to be revised the next time changes are made or with a special ruling.

I find it odd that whoever was contacted in the “solar community” did not spot this erroneous restriction.

The solar community that I am involved in (and on the board of), the Louisiana Solar Energy Society, was founded in 1999, and is an excellent source of information as well as a resource of experts in the field of solar.

I will refer this issue to the national organization, the SRCC, as well as the LSES.  We will publish all the information as it stands now as well as Louisiana’s contradiction on this issue to the rest of the country.  Feel free to call anytime to discuss this or any other solar matters.

UPDATE: It was discovered that a solar group in New Orleans was contacted about SHW and provided the input that got us here.  The 2014 Louisiana Legislature tried to take Solar Hot Water systems out of the jurisdiction of the DHH but was unsuccessful.  Maybe next year!

Thanks,

 

Jeff Shaw, President

NABCEP Certified Installer