Analysing the 2018 amended EPBD and the impact on TM44 Air Conditioning Inspections and energy efficiency
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The outcome of the review and the Commissions impact assessment indicated that a series of amendments are required to strengthen the current provisions of Directive 2010/31/EU and to simplify certain aspects.
On the 30th of May 2018, the European Parliament and the Council of the European Union amended Directive 2010/31/EU on the energy performance of buildings (EPDB) and Directive 2012/27/EU on energy efficiency.
Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 10 March 2020.
Article 15 of Directive 2010/31/EU on the energy performance of buildings (EPDB) requires that member states implement the necessary measures to establish regular air conditioning inspections. Part 4 of The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations, sets out the requirements TM44 air conditioning inspections and air conditioning reports in England and Wales.
The current requirements for TM44 air conditioning inspections in England and Wales are indicated below;
all systems commissioned on or after 1 January 2008, required a first inspection within five years of commissioning date, and every 5 years thereafter
for air conditioning systems, with an effective rated output of more than 250kW the first inspection should have taken place by 4 January 2009, and every 5 years thereafter
for air conditioning systems, with an effective rated output of more than 12kW the first inspection should have taken place by 4 January 2011, and every 5 years thereafter
From 6 April 2012, all TM44 air conditioning inspection reports needed to be lodged on the national Government Landmark register, where after a report and certificate can be generated.
So what EPBD amendments have been approved for Article 15 - Inspection of air-conditioning systems which could impact the current inspection and certification of air conditioning systems in England and Wales?
1. Member States shall lay down the necessary measures to establish regular inspections of the accessible parts of air-conditioning systems or of systems for combined air-conditioning and ventilation, with an effective rated output of over 70 kW.
The inspection shall include an assessment of the efficiency and sizing of the air-conditioning system compared with the cooling requirements of the building and, where relevant, consider the capabilities of the air- conditioning system or of the system for combined air-conditioning and ventilation to optimise its performance under typical or average operating conditions.
Where no changes have been made to the air-conditioning system or to the system for combined air-conditioning and ventilation or to the cooling requirements of the building following an inspection carried out pursuant to this paragraph, Member States may choose not to require the assessment of the sizing of the air-conditioning system to be repeated.
Member States that maintain more stringent requirements pursuant to Article 1(3) shall be exempt from the obligation to notify them to the Commission.
2. Technical building systems that are explicitly covered by an agreed energy performance criterion or a contractual arrangement specifying an agreed level of energy efficiency improvement, such as energy performance contracting, or that are operated by a utility or network operator and therefore subject to performance monitoring measures on the system side, shall be exempt from the requirements laid down in paragraph 1, provided that the overall impact of such an approach is equivalent to that resulting from paragraph 1.
3. As an alternative to paragraph 1 and provided that the overall impact is equivalent to that resulting from paragraph 1, Member States may opt to take measures to ensure the provision of advice to users concerning the replacement of air-conditioning systems or systems for combined air-conditioning and ventilation, other modifications to the air-conditioning system or system for combined air-conditioning and ventilation and alternative solutions to assess the efficiency and appropriate size of those systems.
Before applying the alternative measures referred to in the first subparagraph of this paragraph, each Member State shall, by means of submitting a report to the Commission, document the equivalence of the impact of those measures to the impact of the measures referred to in paragraph 1. Such a report shall be submitted in accordance with the applicable planning and reporting obligations.
4. Member States shall lay down requirements to ensure that, where technically and economically feasible, non-residential buildings with an effective rated output for systems for air-conditioning or systems for combined air- conditioning and ventilation of over 290 kW are equipped with building automation and control systems by 2025.
The building automation and control systems shall be capable of:
(a) continuously monitoring, logging, analysing and allowing for adjusting energy use;
(b) benchmarking the buildings energy efficiency, detecting losses in efficiency of technical building systems, and informing the person responsible for the facilities or technical building management about opportunities for energy efficiency improvement; and
(c) allowing communication with connected technical building systems and other appliances inside the building and being interoperable with technical building systems across different types of proprietary technologies, devices and manufacturers.
5. Member States may lay down requirements to ensure that residential buildings are equipped with:
(a) the functionality of continuous electronic monitoring that measures the systems efficiency and informs building owners or managers when it has fallen significantly and when system servicing is necessary, and
(b) effective control functionalities to ensure optimum generation, distribution, storage and use of energy.
6. Buildings that comply with paragraph 4 or 5 shall be exempt from the requirements laid down in paragraph 1.
Some other potentially positive developments taken from amended Directives 2010/31/EU and 2012/27/EU
It is important to ensure that measures to improve the energy performance of buildings do not focus only on the building envelope, but include all relevant elements and technical systems in a building, such as passive elements that participate in passive techniques aiming to reduce the energy needs for heating or cooling, the energy use for lighting and for ventilation and hence improve thermal and visual comfort.
The energy needs for space heating, space cooling, domestic hot water, ventilation, lighting and other technical building systems shall be calculated in order to optimise health, indoor air quality and comfort levels defined by Member States at national or regional level.
A smart readiness indicator should be used to measure the capacity of buildings to use information and communication technologies and electronic systems to adapt the operation of buildings to the needs of the occupants and the grid and to improve the energy efficiency and overall performance of buildings. The smart readiness indicator should raise awareness amongst building owners and occupants of the value behind building automation and electronic monitoring of technical building systems and should give confidence to occupants about the actual savings of those new enhanced-functionalities.
The Commission shall, before 2020, conclude a feasibility study, clarifying the possibilities and timeline to introduce the inspection of stand-alone ventilation systems and an optional building renovation passport that is complementary to the energy performance certificates, in order to provide a long-term, step-by-step renovation roadmap for a specific building based on quality criteria, following an energy audit, and outlining relevant measures and renovations that could improve the energy performance.
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