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IRI June 27, 2011 0 Comments

Whatever happened to Inspection of AC Systems under EPBD?

Some members may recall that in the IRI Autumn 2010 newsletter (available in the Members Area of the IRI website), we explained how the requirement within the 2002 version of the Energy Performance of Buildings Directive (Article 9 Inspection of air-conditioning systems) for a mandatory regular inspection of air conditioning systems had changed significantly in the 2010 recast of the Directive.

In the recast Directive (Articles 15 & 16), inspections are limited to the “accessible parts”. Member States can set different inspection frequencies depending on the size of the systems, the likely cost savings, and the presence or otherwise of electronic monitoring and control. In so far as is possible, air conditioning inspections should be tied in with inspection of heating systems and FGas inspections. And perhaps the most significant change, Member States can opt out of mandatory inspections by satisfying the Commission that they can achieve equivalent results through the provision of advice to users. All these requirements have to be transposed by Member States into national regulations before 9 July 2012. In the meantime, presumably, Members States’ legislation enacting the original Directive will stand.

Some of the reasoning behind these changes is made clearer in a book published recently by the “Concerted Action—Energy Performance in Buildings” – a European Commission sponsored forum of national agencies charged with implementing the Energy Performance in Buildings Directive.

The book, ‘Implementing the Energy Performance of Buildings Directive (EPBD)’ reviews the collective experience of 29 countries in implementing the original Directive and gives a summary of conclusions for each of the five Core Themes examined by the forum during the period 2007-2010 (Certification, Inspections, Training, Procedures and Information Campaigns).

It also brings together a collection of reports from each country describing the status of the EPBD-related issues at the end of 2010, including a report submitted by SEAI. You can download a copy of the Irish status report or, if you prefer, the overall report, from the EPBD Concerted Action website at www.epbd-ca.org

Among the conclusions reached under the Core Theme of Inspections, were the following:

  • There is a widespread agreement among Members States that, while inspections of larger installations are clearly cost-effective, inspections of smaller units, option A, especially in moderate climates (low heating or low air-conditioning loads), are clearly not cost-effective.
  • It is recommended that Members States consider the adoption of a combined approach, using the most effective elements of both inspections and measures for provision of advice, having in mind the objective of improving the energy efficiency of the systems.
  • Marketing of the inspection scheme, provision of information, technical assistance, training, performance standards and ratings (mandatory or voluntary), as well as financial incentives, must all work together in order to significantly improve energy efficiency.
  • There is a significant scope for energy savings in AC inspections, but it may not be necessary to have detailed (expensive) inspections and tests for all systems. It is necessary for an effective AC inspection scheme to allow the identification of the systems which are consuming too much energy, where inspections may be cost-effective.
  • There is a range of options which allow AC inspections to be simple and not expensive, without losing the majority of the energy efficiency benefits. One of these options includes introducing a “graded or step-by-step” inspection scheme on air-conditioning systems (pre-audit, inspection, audit, advice).
  • The coordination of energy efficiency inspections with other types of inspections is an interesting avenue for keeping the costs as low as possible, even if the objectives of the inspections differ.
  • The issuers and recipients are not always aware of the role and added value of inspection. Recommendations for heating/ cooling system efficiency improvements should always be included in the reports.
  • Most Members States still need to improve their methodologies, train experts and start with regular inspections; Members States are encouraged to complete these tasks soon and start regular inspections shortly, as required by the EPBD.
  • Every year, millions of new small air-conditioners are installed all over Europe. Their inspection should provide answers about their proper installation, as well as some guidelines for the end users about their management. However, most Members States have no public registers of AC systems, no obligation of regular maintenance, no checks made by public authorities on their efficient performance, except for leak checking requirements under Fgas. Therefore, the task imposed by Art. 9 of EPBD is particularly new and challenging; in most Member States, little progress has been observed in this respect.

The EPBD Implementation Status Report submitted by Ireland in November 2010 and included in the EPBD Concerted Action book published in April 2011, has this to say about progress on AC Inspections:

“EPBD Article 9, in respect of air conditioning energy efficiency inspections, was transposed into national law by means of Statutory Instrument SI 346 of 2006. This sets out the obligations on system owners and on qualified technicians, commencing from the 1st of January 2008.

The approach applied towards implementation has been a pragmatic one, encouraging inspection in conjunction with EU F gas regulations where feasible and in conjunction with routine system servicing.

The legislation has been followed by publication in 2008 of an air-conditioning inspection manual which includes the procedures to be followed by qualified technicians.

Following the publication of the EPBD recast, the matter of air-conditioning inspections (Articles 15 and 16) and the manner in which this will be achieved is being reconsidered at present. There are discussions on-going and once a firm and detailed proposal is adopted this is likely to be published for public consultation in due course.”

The report fails to mention that the inspection manual was only published as a draft and the legislation was therefore valueless but at this stage, this is probably a moot point.

The real question is what exactly SEAI and the Department are planning to do about implementing the Air Conditioning Inspection component of the EBPD this time around?