An insight into future legislation

Peter McCree - ICOM Energy Association
Looking for workable and practical regulations — Peter McCree.

Peter McCree of ICOM Energy Association, the body that represents the UK’s commercial heating industry, reflects on how proposed legislation could impact on the industry.

With the current concerns regarding energy usage and emissions of greenhouse gases rightly driving energy policy across Europe, the volume of legislation, regulation and directives coming out of both the UK and European governments is steadily and constantly rising.

Representing the interests of the UK’s commercial heating industry, ICOM Energy Association is constantly vigilant in identifying and influencing the discussions surrounding legislation, playing a key role in ensuring that legislation is both effective and practical.

Two key pieces of forthcoming legislation that ICOM has been working on are the Energy Using Products Directive (EuP) and the Energy Performance of Buildings Directive (EPBD — recast draft), both of which will have an important influence on the design and use of boilers.

The commercial-heating industry has been involved in the Ecodesign Directive, better known as the Energy Using Products Directive (EuP), since 2005, and its products have ended up in the first tranche to be considered under this EuP Directive as lot 1 (boilers) and lot 2 (water heaters). ICOM is in regular dialogue with the various departments and consultants bringing the directive together, trying to iron out areas of difficulty and anomalies within the legislation.

For example many would consider that looking at heating systems in an holistic way makes considerable sense. However, when you take a system approach to the nth degree and include multiple load point labelling, the installer would arrive at the client’s premises with a package which takes no account of what is already installed. This was what was being promoted as an energy-efficient solution.

On the domestic front, this approach would undoubtedly lead to trouble — with perfectly good working products being replaced with no increase in efficiency. On the commercial and industrial front things are handled differently, and systems would be bespoke with a mix of manufacturer, controls specialist and merchant supplying what is required for the new or refurbished building.

There is, however, a problem once again over the labelling. Who is to decide what label should be used as, in theory, it is the manufacturer’s responsibility? Will we be able to persuade the consultants working on this project and ultimately the EU, that the installer must have the responsibility to decide on a label which equates to the system that he has installed or upgraded? Should that label system be A-to-G based or more complex with a number system allowing the scales to be altered as more efficient products come to the market. After all, today’s A grade boiler may get a D rating in three years time when more efficient products come to the market.

The next area under negotiation is the software to carry out the calculations on system requirements. We are all familiar with SBEM and have learned to live with its shortcomings, though there are particular problems for those involved in tall industrial buildings, for example, which require heating over a large area. The anomaly is that SBEM thinks air conditioning is the only solution! Worse may yet be to come, with single pan-European software being proposed which has been modelled on the use of a small domestic boiler and extrapolated to cope with anything larger.

Further discussion is also under way over NOx limits, with the different applications in the UK at odds with the installations in mainland Europe. For domestic and small commercial applications we have favoured small and medium-sized utility boilers, whereas in Germany and many other European countries heating plant is located in a stand-alone building or basement with a ‘man-size’ boiler servicing the property. Oil heating appliances are currently unable to match the proposed low limits of 35 mg/kWh or 70 mg/kWh with renewables, with the current EN Standards for gas being between 80 to 230 mg/kWh.

Finally, the consultants suggest that there should be one label across all fuels. Both the EHI and ICOM consider that this would be confusing to the end user as, for example, in the UK there is a substantial difference in the level of carbon across the variety of fuels available to the end user.

The EU has set ambitious targets in energy policy for Europe. The 20/20/20 target of 20% reduction in energy consumption, 20% reduction in greenhouse-gas emissions and 20% use of renewables would be a considerable achievement. The UK is offering 15% of renewables by 2010 and, most recently, the UK Energy Minister offered to achieve an 80 % reduction in CO2 by 2050!

It is claimed that the buildings sector is responsible for over 40% of the EU’s total energy consumption and CO2 emissions, but there will need to be some drastic changes to the energy mix to achieve the UK’s ambitious 2050 targets.

It is recognised that EPBD regulations, which state the minimum requirements, have so far been poorly enforced across most states. It has also been recognised that member states will need to provide more financial and fiscal incentives, information, training etc. to achieve the improvements under the directive.

A review of the EPBD has been carried out, and the conclusions within the draft were that ambiguous interpretations existed throughout the community. It is stated that there is potential for up to half a million new jobs by 2020, mainly in the construction sector for energy managers, certifiers, auditors’ inspectors and, of course, the resulting additional refurbishment work. The energy requirements for both new and refurbished buildings require strengthening. The criteria for energy performance certificates and the inspection of boilers also need to be strengthened. There is a proposal to remove the current 1000 m² lower; whilst there would be added cost of the additional workload, the payback is estimated at three times the cost.

To summarise, the proposed actions include the clarification and simplification of the wording, extending minimum energy requirements when a major renovation is carried out, reinforcement of the provisions on EPCs, inspections of heating , energy performance and independent experts. The directive continues to provide a benchmark; however, it still leaves the responsibility for setting the requirements with individual member states. It stimulates member states to set out a ‘road map’ with clear targets and timelines and encourages the public sector to provide a leading example. It looks as if the draft will be accepted in its entirety with one or two amendments.

The role of organisations like ICOM Energy Association and the European Heating Industry in reviewing, lobbying and representing the industry in discussions around forthcoming legislation is crucial if the regulations are to be workable and practical. In addition, they play a key part in feeding the information back to the industry. Individual companies could not possibly commit the resources required to undertake this work, so the industry body’s ability to draw in resources from members to work together is crucial if the regulations produced are not to create major implementation issues for the industry.

ICOM Energy Association continues to identify new potential legislation in its earliest stages so it can influence its progress and development.


Peter McCree is chief executive of the ICOM Energy Association.

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