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IRI September 1, 2011 0 Comments

The Institute of Refrigeration Ireland sought and was granted a meeting with representatives of the Sustainable Energy Authority of Ireland (SEAI) over the summer months in relation to the following: (a) the Accelerated Capital Allowance scheme; (b) new legislation and government policy on Green Public Procurement; and (c) implementation of the provisions within the recast Energy Performance in Buildings Directive for Inspection of Air Conditioning.

We had a number of specific aims going into the meeting, namely:

  1. To get the latest update from the SEAI on each of these topics
  2. To raise some issues of concern to members regarding the ACA scheme
  3. To request the SEAI’s participation in an industry briefing for our members
  4. To highlight the work of the Institute and the important contribution that our members can make to improving energy efficiency
  5. To express interest in further co-operation for our mutual benefit

Some of the key outcomes from the meeting are given below. The SEAI also agreed to participate in an industry briefing for IRI members in the coming months. As soon as the details are agreed, we will let our members know.

(a) ACA Scheme / Triple E Product Register

  • The SEAI confirmed that in order for products to be eligible under the Accelerated Capital Allowance (ACA) Scheme, they must be listed on the Triple E Product Register. They define the Triple E Products Register as “a new benchmark register of best in class energy efficient products. Products on this register all meet a minimum set of stringent efficiency criteria and typically will be of a best in class efficiency standard. As such, procuring against this register will provide you with the assurance that you are purchasing a product of very high efficiency.”
  • They have wider ambitions for the Triple E Products Register. While currently the Triple E register is based solely on the existing Accelerated Capital Allowance (ACA) list of eligible products and eligibility criteria, it is planned in the future to extend the product range beyond that covered by the ACA.
  • The SEAI wants the Triple E Products Register to be used by all specifiers, not only those seeking to avail of the capital allowances under ACA.
  • Green Public Procurement (see below) will be an important driver.
  • The ACA Scheme itself has grown very considerably since its introduction. It now covers 10 different equipment categories and 52 associated technologies.
  • The SEAI has seen a high level of interest from heat pump suppliers since their recent inclusion in the ACA scheme with many suppliers seeking to register products on the ACA scheme in advance of the next deadline.

The IRI raised some concerns expressed by our members, including:

  1. technical difficulties uploading information
  2. lack of communication as to whether products were to be included on register
  3. lack of clarity as to who we are dealing with in the SEAI
  4. cost and practicality of product certification specifically for Irish climate
  5. poor uptake on the scheme overall

In response, we were told:

  1. the template used to upload technical data has been changed and improved;
  2. they are aware that there have been some hitches with communication and gave an undertaking that this will improve;
  3. while outside consultants may be employed to develop technical criteria and to assess products against these criteria, we will have point of contact within in the SEAI should the need arise;
  4. independent product certification is a standard SEAI requirement. Localising the performance data, e.g., using Irish weather data to arrive at COP outcomes, is required in order to protect the buyer. If the IRI has specific concerns, we should write to the SEAI and they will respond as best they can;
  5. the SEAI wants the Triple E Products Register to be a success and to be used by all specifiers, not only those seeking to avail of the capital allowances under ACA. They would welcome IRI involvement to make it a success.

(b) Green Public Procurement

The SEAI confirmed that following a public consultation stage earlier this year, the new requirements for Green Public Procurement are now in place. They are supported by a Statutory Instrument (SI 151 of 2011) which amends and updates an earlier Statutory Instrument (SI 542 of 2009) on “energy end-use efficiency and energy services”.

According to the legislation, all public bodies must specify and purchase products that are included on the Triple E Product Register. To quote SI151 of 2011:

(1) a public body shall only procure equipment or vehicles which (a) are listed on the Register, or (b) satisfy the published SEAI energy efficiency criteria for the equipment…..concerned, and the public body shall specify this requirement in any documentation describing its procurement requirements.

We asked whether this meant that procurement officers simply have to “consider” these products and will be able to ignore them based on wide interpretation of Par (2) below, taken from the same piece of legislation:

 (2) To ensure adequate competition in a public procurement process, paragraph (1) does not apply where, in the opinion of the public body concerned, there is, or is likely to be, an insufficient amount or number, as the case may be, of equipment or vehicles either listed on the Register or likely to satisfy the SEAI energy efficiency criteria.

The SEAI position is that this will be the exception rather than the rule. They see the change to public sector procurement as a key driver in the success of the Triple E Product Register and the wider adoption of energy efficient products, both in the public and private sector.

The SEAI sees Green Public Procurement as “very good public policy”. If Ireland is to pursue the “Smart Green Economy” we need the public sector to provide leadership in the adoption of green technology. This will increase the supply of energy efficient products and encourage the development of a good base of competent installers.

(c) EPBD Inspection of AC Systems

We reviewed briefly the history of the SEAI approach to this (see previous issues of IRI newsletter). The SEAI confirmed that given the changes in the recast Directive, the SEAI’s preference is to demonstrate to the European Commission that an informational campaign can achieve the same or better results than a mandatory inspection regime. They would like to be able to point to an existing register of competent companies and competent individuals as part of the informational campaign and they will engage with the IRI on this.

The IRI Council will discuss this matter at our next Council meeting. We would welcome any feedback from members.