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  • Energy Performance in Buildings Directive (EPBD) – Recast legislation published in June 2010: Implications for Inspection of Air Conditioning
IRI December 7, 2010 0 Comments

In the 2002 version of the Energy Performance of Buildings Directive, Article 9 (Inspection of air-conditioning systems) called for a regular inspection of air conditioning of more than 12 kW, including an assessment of the air-conditioning efficiency and the sizing compared to the cooling requirements of the building. It also required that appropriate advice be provided to the users on possible improvement or replacement of the air-conditioning system and on alternative solutions.

In June 2010, following a lengthy consultation process, the recast of the Directive was published. The new legislation introduces significant changes to the requirements for inspection of air conditioning systems. Most of these are contained in Article 15 and are summarized below:

  • Member States shall lay down the necessary measures to establish a regular inspection of the accessible parts of air-conditioning systems of an effective rated output of more than 12 kW.
  • The inspection shall include an assessment of the air-conditioning efficiency and the sizing compared to the cooling requirements of the building. The assessment of the sizing does not have to be repeated as long as no changes were made to this air-conditioning system or to the cooling requirements of the building in the meantime.
  • Member States may reduce the frequency of such inspections or lighten them, as appropriate, where an electronic monitoring and control system is in place.
  • Member States may set different inspection frequencies depending on the type and effective rated output of the air-conditioning system, whilst taking into account the costs of the inspection of the air-conditioning system and the estimated energy cost savings that may result from the inspection.
  • Member States are asked to ensure, as far as economically and technically feasible, that inspections are carried out in accordance with the inspection of heating systems and with the inspection requirements of the FGas Regulations.
  • Member States may opt, as an alternative to regular inspection of air conditioning systems, “to take measures to ensure the provision of advice to users on the replacement of air-conditioning systems or on other modifications to the air-conditioning system”. Members States will have to satisfy the Commission that the overall impact of this approach will be equivalent to that arising from regular inspections.

Clearly, the rules have changed significantly. 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. The requirements about qualified inspectors and controls have to be implemented before 9 January 2013. Finally, the requirements about inspection and inspection reports have to be applied before 9 January 2013 for buildings occupied by public authorities and before 9 July 2013 for other buildings.

As of October 2010, we have yet to hear any news from the Department of Communications, Energy and Natural Resources regarding implementation of Article 15. But given the extended deadlines set out above, and the pace of progress the last time around, it seems unlikely that we will have a decision any time soon.

A copy of the recast Directive can be downloaded from the Members Area.