Improving Technical Installations in Buildings
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This document provides input from the European Copper Institute into the public consultation on the evaluation of the Energy Performance of Buildings Directive (EPBD). While the EPBD has helped improve energy efficiency in buildings, it has primarily focused on new builds and major renovations, failing to capture significant potential savings from improving existing building technical systems. Upgrading controls and equipment offers cost-effective savings across the entire building stock. The EPBD could be improved by better addressing operational energy use and ensuring cost-optimality assessments properly consider all options like building automation.
Improving Technical Installations in Buildings
- 1. IMPROVING TECHNICAL INSTALLATIONS IN BUILDINGS ECI inputs for the Public Consultation on the Evaluation of the Energy Performance of Buildings Directive (EPBD) October 2015 ECI Publication No Cu0233 Available from www.leonardo-energy.org
- 2. Publication No Cu0233 Issue Date: October 2015 Page i Document Issue Control Sheet Document Title: Improving technical installations in buildings – ECI inputs for the Public Consultation on the Evaluation of the Energy Performance of Buildings Directive (EPBD) Publication No: Cu0233 Issue: 01 Release: Public Author(s): Diedert Debusscher, Hans De Keulenaer, Fernando Nuño, Paul Waide Reviewer(s): Document History Issue Date Purpose 1 Oct 2015 Initial public release 2 3 Disclaimer While this publication has been prepared with care, European Copper Institute and other contributors provide no warranty with regards to the content and shall not be liable for any direct, incidental or consequential damages that may result from the use of the information or the data contained. Copyright© European Copper Institute. Transparency register ID number: 04134171823-87 Reproduction is authorised providing the material is unabridged and the source is acknowledged.
- 3. Publication No Cu0233 Issue Date: October 2015 Page 1 SUMMARY The EPBD has thus far been partially successful in improving the energy performance of buildings. It definitely has introduced or promoted a culture of insulation in most EU member states. It has set Europe on a course towards near-zero energy buildings, which would eventually eliminate or strongly reduce the need for space heating and cooling, currently a major energy end-use in Europe. We are on course towards energy-efficient buildings, but only at a slow rate because the EPBD mandatory measures essentially only apply to new build or major renovations and not to the more frequent renewal cycles for building technical systems. For that reason, EPBD is failing to deliver vast energy savings potentials, in particular those associated with technical building systems and with the proper application of Building Automation and Control Systems (BACS). Building energy services equipment and their associated controls are renewed on a more frequent basis and offer very significant and cost effective energy savings potentials. Thus, the development of measures that explicitly target improvement in the efficiency of operation of building energy services equipment can help bridge the gap between the longer term deep renewal of the building stock and the need to produce quick wins across the whole building stock towards the Energy Union objectives. A paradigm shift is needed to put the building in use – not the intended design – the central focus for building energy performance strategies. This not only avoids building energy policies on the sandy grounds of predicted energy savings, the user-centric thinking will also become the driver for continuous improvement in the energy performance of the building in use and during the entire lifecycle – even when the building changes functions. Next to accelerating the course towards energy-efficient buildings, it is also time to address other, wider challenges. Buildings are an inherent part of the European energy system, and the electrification rate of their heating & cooling systems and resulting demand response potential will have a significant impact on the new energy market design, on the integration potential of renewables, on the decarbonisation rate of the energy system and on the cost of energy services to final users. The stakes are high, and not all can be solved by the EPBD, but where EPBD cannot offer a solution, it should not hold back other policy instruments from playing their role. This document compiles ECI’s input into the Public Consultation to the Evaluation of the Energy Performance of Buildings Directive (EPBD). For smooth reading, the document follows the outline of the Consultation document, but only answers those questions that are relevant to ECI’s expertise and/or concerns.
- 4. Publication No Cu0233 Issue Date: October 2015 Page 2 A. OVERALL ASSESSMENT QUESTION 2. HAS EPBD HELPED IMPROVE ENERGY EFFICIENCY IN BUILDINGS? While there has already been significant improvement in the overall energy performance in buildings, considerable potential still remains. One of the largest savings potentials that remain to be captured is the mitigation of ineffective control of energy-using systems such as heating, cooling, ventilation and lighting. Such ineffective control is still endemic in Europe’s buildings: spaces are heated when it is not necessary, lighting is left on, ventilation operates continuously at maximum capacity and so forth. Greater adoption and improved operation of building automation technologies and controls (BAT/BACS) could progressively result in estimated savings of up to 22% of the annual building energy consumption - this is ~9% of the total final energy consumption of the entire European Union1 . These savings are highly cost effective, with benefits being 9 times higher than costs, and hence merit consideration in the context of the EU’s Efficiency First principle. From a policy perspective there seems to have been a serious under-appreciation of the magnitude of this opportunity and of the barriers faced (lack of awareness, fragmented supply chains, lack of clarity about the value proposition, initial cost and risk barriers, quality of design and installation, need for more reliable diagnostics and troubleshooting etc.). There are many areas within the EPBD that could be adapted to lend some support to realise these savings but the existing measures are mostly of a horizontal nature and hence only provide indirect encouragement. As a result there is very little that is currently being done to practically deliver these savings. QUESTION 3. HAS IT HELPED TO INCREASE RENOVATION (MORE THAN 25% OF THE SURFACE OF THE BUILDING ENVELOPE) RATES? With low demolition rates (0.1% per year), low refurbishment rates (1.2% per year) and moves to highly energy efficient new-build (1% additions per year)2 , Europe’s energy efficiency challenge in buildings mainly concerns the speed and the depth of energy efficient refurbishments and investments in its existing buildings stock. On top of the low renovation rates comes the fact that only part of the renovations have an effect on the building’s overall energy performance. As few as 0.1% to 0.4% of the non-residential buildings in Europe undergo major energy-related renovations each year3 . Yet renewal of the factors that affect the energy performance of the building stock are not all tied into the new build and major renovations cycles. Building energy services equipment and their associated controls are 1 Waide Strategic Efficiency et al. (2014). The scope for energy and CO2 savings in the EU through the use of building automation technology. Second edition, 13 June 2014. Retrieved from: http://www.leonardo- energy.org/white-paper/building-automation-scope-energy-and-co2-savings-eu 2 EEFIG (2014). Energy Efficiency – the first fuel for the EU Economy. Part 1: Buildings (Interim Report). Retrieved from: https://ec.europa.eu/energy/sites/ener/files/documents/2014_fig_how_drive_finance_for_economy_1.pdf 3 Schimschar, Sven et al. (2011). Panorama of the European non-residential construction sector. Retrieved from: http://www.leonardo-energy.org/white-paper/panorama-european-non-residential-construction-sector
- 5. Publication No Cu0233 Issue Date: October 2015 Page 3 renewed on a more frequent basis and offer very significant and cost effective energy savings potentials. Thus, the development of measures that explicitly target improvement in the efficiency of operation of building energy services equipment can help bridge the gap between the longer term deep renewal of the building stock and the need to produce quick wins across the whole building stock towards the Energy Union objectives. In particular, they can be deployed more rapidly across a broader mass of the building stock, and because they don’t involve such disruptive intervention are much more acceptable to building owners and occupiers and hence are not tied to periods of in-occupancy. While the Ecodesign Directive has helped to promote higher efficiency of specific building services equipment it has been unable to trigger very important savings in the assembly of these products within energy using systems. It is time therefore for the EPBD to focus on strengthening the requirements for building energy services equipment systems, and especially through the strengthening of provisions within Article 8 on technical systems. Such actions can deliver relatively rapid energy savings across the whole building stock. QUESTION 4. IN YOUR VIEW, HAS THE EPBD SUFFICIENTLY CONTRIBUTED TO ACCELERATING INVESTMENT IN IMPROVING THE ENERGY PERFORMANCE OF THE EU'S BUILDING STOCK? WHY/WHY NOT? The EPBD has contributed to accelerating investment, but with too narrow a focus on envelope-related improvement measures, leaving out significant opportunities for lifecycle energy savings within other areas of building energy performance (especially the building energy services equipment). The design phase of a building project focuses on investment capital, not on operation costs. All legislated measures are covered first (design compliant thinking), leaving almost no budget for energy improvement measures that are not legislated but would result in large energy savings during the operation phase of the buildings. In that sense, current EPBD stimulates investment compromises with a negative impact on both the lifecycle cost and the energy performance of a building. The paradigm shift lies in making the ‘building in use’ – not the intended design – the central focus for building energy performance strategies. It not only avoids building energy policies on the sandy grounds of predicted energy savings, the user-centric thinking will also become the driver for continuous improvement in the energy performance of the building in use and during the entire lifecycle – even when the building changes functions. Package financing is an important issue for building renovation, because it allows exploitation of the short payback time of the ‘low hanging fruit’ to help finance less cost-effective solutions in the package. Care should be taken to avoid a stepwise approach of the realisation of insulation-only and postponing more complex technical measures (related to effective control of the energy consuming services) to a later stage. QUESTION 5. OVERALL, DO YOU THINK THAT THE EPBD IS CONTRIBUTING TO COST- EFFECTIVE IMPROVEMENTS OF ENERGY PERFORMANCE? WHY/WHY NOT? EPBD provides a good framework, but the implementation of lifecycle cost optimisation currently only applies to building code development while there is a strong need for policy measures to encourage application of lifecycle cost optimisation principles for each aspect of the building system whenever it is first installed or renewed. As an example, Building Automated Technologies and Building Automation and Control Systems, are not properly treated within the cost optimality assessments for building codes of almost all MS, although they represent a cost-optimal energy saving design option.
- 6. Publication No Cu0233 Issue Date: October 2015 Page 4 It is important to understand that the cost optimisation methodology needs to consider all available design options and assess their cost-benefits. Only then can this methodology successfully identify the level of building efficiency corresponding to the lowest lifecycle cost. The findings of life cycle cost optimisations assessments are extremely sensitive to the degree to which all available options are included and individually assessed. This aspect is likely to have even greater bearing on the results than the choice of discount rate or other macroeconomic factors which were identified and investigated in the EU’s sensitivity study4 . It is clear that the cost optimality assessment process within the EPBD is not currently being applied properly by MS. As a result cost-effective energy savings options using BACS are either not being considered at all when assessing the cost-optimality of energy performance codes or are being aggregated with other options in such a way that the true benefits are not properly accounted for. This results in both, a reduced appreciation of how much BACS can contribute to energy savings objectives and in sub-optimal building codes. QUESTION 7. HAS THE EPBD EFFECTIVELY ADDRESSED THE CHALLENGES OF EXISTING BUILDINGS' ENERGY PERFORMANCE? See question 8. QUESTION 8. HAS THE EPBD SET EFFECTIVE ENERGY PERFORMANCE STANDARDS FOR NEW BUILDINGS? Current building energy performance standards are systematically overestimating the impact of the intended savings5 . In other words: high energy performance buildings often do not deliver on their design expectations. This gap between predictions and real performance is not tackled in current legislation. Accelerating renovation rates without tackling the main causes of this performance gap, would mean a locking-in of poor (or at least far from optimal) energy performance in our dwellings and service buildings across the continent. This conflicts with other calls by European leaders, such as Hans Bruyninckx, the EEA's executive director, who said that “to achieve the emissions cuts demanded by science, member States must ensure that they are not making choices today that become obstacles to a low carbon future”6 . There is a lot of evidence to prove that buildings do not perform as well as was anticipated at the design stage. Case studies demonstrate actual energy consumption to be twice as much as predicted7 . More recent studies even report outliers where the Energy Performance Certificate (EPC) underestimated the actual energy use in 4 http://www.epbd-ca.eu/ 5 The Carbon Trust (2011). Closing the gap: Lessons learned on realising the potential of low carbon building design. Retrieved from: https://www.carbontrust.com/media/81361/ctg047-closing-the-gap-low-carbon- building-design.pdf 6 Retrieved from: http://www.eea.europa.eu/media/newsreleases/climate-and-energy-targets-2013 7 CIBSE - PROBE - Post Occupancy Studies. Retrieved from: http://www.cibse.org/probe
- 7. Publication No Cu0233 Issue Date: October 2015 Page 5 the first year by five times8 . There are many causes to this energy performance gap, but they all more or less boil down to the following three categories: 1. The thermal characteristics of the as-built envelope (insulation, glazing, air-tightness etc.) is much lower than the intended design. 2. Installed services and appliances consume more than predicted, because adequate control systems are lacking or poorly tuned. 3. Occupants behave differently than the calculation rationale based on default values imposed by regulation QUESTION 10. HOW SUCCESSFUL HAS THE INCLUSION OF ENERGY PERFORMANCE CERTIFICATES IN THE EPBD BEEN? HAVE THE CERTIFICATES CONTRIBUTED TO IMPROVEMENTS IN ENERGY PERFORMANCE OF BUILDINGS? There is an opportunity to improve the quality and usefulness of the EPCs, by including an assessment of the building energy controls system. Many MS have opted for operational ratings i.e. based on historical energy use. This has the merit of being easy to determine but the demerit of not normalising out the influence of user behaviour on energy use. In practice this behaviour has a big impact, often because of differences of occupancy between users but also because of differences in set-points and other factors. If a building has an effective control strategy its operational energy consumption will tend to align with the asset rating. Basic differences in occupancy rates will still affect the asset versus operational rating but the important aspect of control will have been removed. Conversely, when the control of building energy services is poor the difference between the operational and asset ratings will increase. QUESTION 11. WHAT HAS WORKED WELL IN THE EPBD? WHAT NEEDS TO BE IMPROVED? Ensure the cost-optimal methodology is applied appropriately. Note, that too many options are being ignored or treated superficially at present and as a result are not being factored into implementation of building energy code determinations. Improve the quality of EPCs. This is particularly necessary to resolve the user-behaviour and control related differences between asset- and operational-based ratings. Explore and consider a move towards the implementation of dynamic EPCs that build on smart metering data and can better inform user behaviour. Recognise that good practice is to set minimum energy performance requirements, not only for the fabric which is common at present, but the whole building, including the main building energy services. This is because in practice many of the professional actors concerned take decisions quasi-independently of each other and are often only weakly motivated by the consolidated project outcome. Continue to improve the completeness, usability and accuracy of technical standards used to assess building energy performance. Place analytical tools in the public domain that can be used by professional actors and private individuals to estimate building energy performance and the impact of design and operational changes. 8 The Carbon Trust (2011). Closing the gap: Lessons learned on realising the potential of low carbon building design. Retrieved from: https://www.carbontrust.com/media/81361/ctg047-closing-the-gap-low-carbon- building-design.pdf
- 8. Publication No Cu0233 Issue Date: October 2015 Page 6 Ensure the quality of building energy control strategies is properly treated and strongly promoted as a key means to achieve substantial and rapid energy savings; controls effectively integrate all single nZEB requirements, such as an insulated, airtight building shell, efficient HVAC systems and a high share of renewable generation; they reduce the primary energy consumption of a building in operation with variable load and occupancy patterns; they facilitate high penetration of renewables and provide grid stability by unleashing built-in load shifting and storage management. Ensure demand and supply-side flexibility technical options related to buildings are adequately facilitated, or at least not excluded. Think beyond the building and consider its operation in the energy system. Integrate with the objectives of the RED and the need to diversify renewable energy supply. F. ENSURING NEW HIGHLY EFFICIENT BUILDINGS USING A HIGHER SHARE OF RENEWABLE ENERGY QUESTION 50. HAS THE EPBD FRAMEWORK IMPROVED THE SELF-CONSUMPTION OF ELECTRICITY IN BUILDINGS? There is a lack of coordination between on-site generation practices driven by building codes and the valorization rules for electricity produced. Incompatibilities have been reported between building codes and renewables support schemes in certain countries9 . Rules for self-consumption are shaped at national level, sometimes without consideration of building codes. Countries address self-consumption and on-site generation with varying degrees of support. National policies addressing renewable energy generation targets (in application of Renewable Energy Directive) largely define the behaviour of self-consumption in a country. There is a need of coordination between building codes and renewable support schemes, particularly in the field of self-consumption of electricity. Such coordination should be extended to cogeneration as well. QUESTION 52. IS DEMAND RESPONSE BEING STIMULATED AT THE INDIVIDUAL BUILDING LEVEL AND IF SO, HOW? Not currently. Demand response is a market design issue. Currently, there are very limited business models that enable market participation from the demand side, while there are many barriers for aggregators. Demand response requires electrification of energy services that have temporal flexibility. EPBD could help to ensure market access for these electrification technologies, e.g. by ensuring a fairer side-by-side comparison of energy carriers taking the full lifecycle into account. 9 The building code in Spain requires the installation of PV panels to a certain category of buildings (>5000 m2 , PV power proportional to the built surface), while the electricity market regulation penalizes with a special tax self-consumed electricity. PV panels become then an obligatory non-profitable investment.
- 9. Publication No Cu0233 Issue Date: October 2015 Page 7 QUESTION 53. WHAT OBLIGATIONS ARE MISSING AT EU LEVEL AND NATIONAL LEVEL, AND AT REGIONAL AND LOCAL LEVEL TO MEET THE GOALS OF THE EPBD? Most of the potential power of the EPBD to produce cost-effective savings through Building Automation and Control Systems is currently untapped. To help address this it would be helpful were the Commission to: a. Ensure BACS are included in MS calculations of whole building (or renovation) energy performance in a sufficient level of detail to capture the diversity of outcomes and to reward good practice so that their contribution can be properly accounted for in delivering prescribed whole building or renovation performance levels b. Encourage MS to take BACS properly into account in the determination of rankings for energy performance certificates and to include BACS options among the set of options recommended to improve performance c. Encourage MS to complement whole building (or renovation) energy performance requirements with minimum requirements for BACS to ensure that building services are deploying cost-effective control strategies d. Ensure that the cost optimal methodological assessment used to define or justify the codes at MS level includes a proper assessment of BACS differentiated by their various levels of functionality and that these are not aggregated with other options that might be less cost effective to implement e. Develop guidelines regarding the design of programmatic actions to stimulate savings through BACS as an alternative means of complying with Article 14 requirements f. Develop guidelines on how best to treat BACS within EPCs g. Encourage MS to consider partially satisfying Article 10(2) requirements regarding financial support measures with measures that target effective BACS deployment h. Encourage MS to amend their application of EPCs to analyse the difference between asset and operational ratings and use this to provide direct guidance on the need to improve the BACS/control strategy (as discussed in the EPC section above). If necessary, trial this concept and support the development of analytical tools to support this process. G. LINKS BETWEEN THE EPBD AND DISTRICT AND CITY LEVELS, SMART CITIES, AND HEATING AND COOLING NETWORKS QUESTION 57. ARE SMART METERS AND THEIR FUNCTIONALITIES CONTRIBUTING TO MEETING ENERGY EFFICIENCY TARGETS AND THE PROPER IMPLEMENTATION OF THE EPBD? ARE OTHER TARGETED METERS FOR HEAT, GAS AND WATER HAVE SPECIFIC PROVISIONS SUCH AS THOSE FOR ELECTRIC METERS NEEDED? Provision of sufficient metering and feedback on energy use is a necessary but insufficient means of saving energy through building controls and related technology. In theory metering, sub-metering and feedback provisions could be specified and made mandatory in a manner that differentiates according to circumstances and the size of the savings opportunity and/or information barrier to be addressed. Metering is already highly regulated and hence extension of provisions to provide greater richness of information would be a natural extension of existing requirements. Care is obviously needed to ensure this is done in a manner that is wholly consistent with the public good and is not gratuitously driving demand for metering with little practical value. Thus careful research is needed to define the appropriate level and boundaries of such requirements and to ensure they are implemented as part of a complementary policy package that ensures the value of additional energy performance information is acted
- 10. Publication No Cu0233 Issue Date: October 2015 Page 8 upon in practice. This has not always happened in previous policy driven dynamics where “smart metering” has sometimes been rolled out on the basis of a potential to realise savings that are not practically realised unless linked to other control capabilities and human response factors that were not directly addressed by the smart meter policy. J. BUILDINGS SYSTEMS REQUIREMENTS QUESTION 72. BASED ON EXISTING EXPERIENCE, DO YOU THINK THE SETTING OF MINIMUM REQUIREMENTS IN THE EPBD FOR TECHNICAL BUILDING SYSTEMS IS MISSING? WOULD HAVE TECHNICAL BUILDING SYSTEMS MINIMUM REQUIREMENTS CONTRIBUTED TO THE IMPROVEMENT OF BUILDINGS' ENERGY PERFORMANCES? BUILDING AUTOMATED TECHNOLOGIES (BAT) AND BUILDING AUTOMATION CONTROL SYSTEMS (BACS) Based on ECI’s experience, it seems likely that overarching whole building energy performance requirements combined with minimum functionality prescriptions for individual building services will result in surer delivery of cost-effective energy savings. In particular, this logic applies to BAT/BACS, of which the awareness of the impact on the whole building performance is likely to be less than for other building energy systems such as lighting and HVAC. However, it is also true of these other building energy systems. ELECTRICAL INSTALLATIONS Electrical energy is lost not only in end-use devices (being addressed by Ecodesign regulations) but also in the electricity supply cables. Today’s cable losses, which amount to approximately 2% of the EU’s total electricity consumption (60 TWh/year), could be halved by increasing the cross section of the conductor up to its economical optimum. In the large majority of cases, minimising the Total Cost of Ownership (TCO) results in a cross section that is substantially greater than prescribed in today’s technical standards. The current standards for cable sizing take safety aspects (thermal impact, short circuit current) and voltage drop into account, but not energy efficiency. A new standard that includes energy efficiency (IEC 60364-8-1) has recently been published, but its scope is much broader than cables and therefore it influence on economically optimum cable sizing is expected to be low. The bulk of energy savings corresponds to tertiary sector and industrial buildings. Such electrical installations are designed using specialised software. However, economically optimum cable sizing is far from common market practice (due to split incentives or competitive bidding procedures). The benefits of improved cable sizing are in the range of 20-30 TWh electricity per year. These savings are accompanied by important reductions in Greenhouse Gas Emissions (in the range of 8-10 million tonnes per year, on life cycle basis). From an economic perspective, the improved scenarios are attractive. The incremental investment remains reasonable, typically less than a fraction of the entire building investment cost, and is generally recovered in less than 4 years. These efficient investments will also support directly the electrical engineering and manufacturing sectors. QUESTION 73. BASED ON EXISTING EXPERIENCE, DO YOU THINK IN THE EPBD MINIMUM REQUIREMENTS FOR TECHNICAL BUILDINGS SYSTEMS FOCUSSING ON OTHER FACTORS THAN
- 11. Publication No Cu0233 Issue Date: October 2015 Page 9 HEATING, AIR CONDITION, LARGE VENTILATION SYSTEMS AND DOMESTIC HOT WATER E.G. CERTAIN BUILDING CATEGORIES, BUILDING SIZE, ETC., IS MISSING? Article 8 is not supporting BAT/BACS, nor the electrical installation. It only states in vague terms to do “something” with technical systems, but the article is not fleshed out and is merely focusing on HVAC (and even then left to individual MS to decide). In practice, nothing is happening as a result of this article in most MS. A rationale often put forward for not setting specific requirements for technical systems is that whole building performance requirements will address savings in technical building systems (as they are often the most cost effective); however, this reasoning is flawed because: 1. the pace of renewal of technical building systems will occur faster than for new build or major renovations (at which point whole-building requirements would apply) and hence technical systems replacement is often done independently of building code provisions 2. in practice contractors responsible for meeting the codes for the whole building or renovation usually ensure that the code requirements are met through the envelope performance and seldom leave it to the building energy services stage, as this carries higher risk of non-compliance due to having different contractors involved and occurs at the end of the project when it could be too late to address issues - in consequence the pressure for optimisation of building technical systems is weaker than often presumed. In consequence best practice is to set mandatory energy performance requirements for the whole building and for each of the key technical buildings systems to ensure that each contractor is bound to provide optimised services and can be held accountable for their part of the system. Article 8 should thus be amended so that MS are required to set mandatory standards for each of the main technical building systems in accordance with a proper cost-optimised methodology. QUESTION 74. BASED ON EXISTING EXPERIENCE, DO YOU THINK IN THE EPBD REQUIREMENTS IS MISSING FOR REGULAR INSPECTIONS OF THE TECHNICAL BUILDING SYSTEMS TO ENSURE: (A) THAT SYSTEMS' PERFORMANCE IS MAINTAINED DURING THEIR LIFETIME? For complex buildings or complexes of buildings the process of continuous commissioning is recommended as experience shows that the benefits outweigh the costs many times over. Continuous commissioning is a process, focused on operation, by which a building and its services are conceived, designed, constructed, commissioned, operated, maintained and decommissioned to provide the optimum of cost and value for the occupier. Research results demonstrate that the application of continuous commissioning to existing buildings delivers substantial operating-cost savings and greater occupant satisfaction. There is already a small industry in Europe providing continuous commissioning services, however the scale needs to be increased (through stronger and more concerted promotion of the value added it offers and through public sector leadership) and the quality of the service offer needs to be assured (through training, certification, accreditation and either underwriting of outcomes or promotion of shared-benefits business models). Regular audits or regular commissioning, as a less costly version of continuous commissioning, could be an intermediate step. While such audits are certainly useful they are less likely to identify problems than a continuous commissioning process and will also lead to less timely interventions, thus they are suited to buildings with intermediate energy use rather than those with higher energy use.
- 12. Publication No Cu0233 Issue Date: October 2015 Page 10 A recent study from France 10 highlighted the savings potential from proper maintenance of technical installations. Not only are these savings of a similar order than savings in insulation, but they also prove to be highly cost-effective. (B) THAT OWNERS/OCCUPIERS ARE PROPERLY INFORMED ABOUT THE POTENTIAL IMPROVEMENTS TO THE EFFICIENCY OF THEIR SYSTEMS? Diagnostic and auditing systems are essential to ensure proper operation of energy services. Ideally these need to go beyond simple hardware and software solutions (albeit these are the core of the solution) to become fully embedded with corporate human organisational structures into a quality assurance process. Methods to automatically highlight deficiencies in building services and associated controls performance are needed as it would be unviable for experts to analyse system performance for all buildings on an ongoing basis from a practical and financial viewpoint. Much excessive energy consumption can be identified with relatively simple rules, and there is considerable potential for expert and other rule-based automated diagnostic systems to identify wastage. Manufacturers and others have undertaken some development in this area, but little has yet been commercialised. In addition to expert systems, techniques such as data mining have considerable potential. These can identify patterns in the vast numbers of data available from building management systems (BMS) and can identify when systems are not working as expected. They can assist in the ongoing analysis of systems to improve energy performance and, as with expert systems, identify when systems are performing poorly and the likely causes. There has been a significant increase in meter provision and sub-metering, yet very little is done with the results. Where sub-metering is available and analysed, it is often in isolation from BMS which actually control much of the energy usage. Advanced analysis techniques linking systems operation and metering are essential to facilitate more objective and effective analysis of system operation and energy efficiency. This can lead to more effective fine-tuning of systems with effective feedback of the results. These techniques are being developed in the USA, but little appears to have been done in Europe. While much of the technology is similar, there are many differences between the European and US marketplaces. These include both the types of systems installed and the way they are used and operated. Development of systems suitable for the European marketplace has enormous potential for improving energy efficiency. It is therefore recommended that advanced data-analysis techniques and routes to market be developed. These tools will be of significant benefit and complementary to continuous commissioning and associated factors in improving building performance. (C) THAT REPLACEMENT/UPGRADING OF THE TECHNICAL BUILDING SYSTEMS IS TRIGGERED? Mandatory inspections of heating and AC equipment above 12kW are already a requirement within the EPBD so in principle the same type of requirement could be applied to ensure conformity of building automated controls. That noted, this has been one of the more contentious provisions in the EPBD and it would be advisable to consider means by which the value added of inspections could be maximised and the burden minimised before imposing new requirements. For BAC systems this could be done through a triage according to building energy use such that buildings with poor energy ratings and high energy use, as determined by the existing mandatory 10 Rénovation du patrimoine immobilier - http://www.cardonnel.fr/renovation-du-patrimoine-immobilier- fedene (checked October 2015)
- 13. Publication No Cu0233 Issue Date: October 2015 Page 11 energy performance certificates (see above) could be subject to mandatory BAT/BACS inspections to see that the level of control capability is sufficient and is properly implemented. Indeed, such a provision is likely to produce much greater savings if competently implemented than mandatory heating and AC systems inspections. Those MS that have opted for alternative routes to mandatory inspections should be encouraged or required to demonstrate that they have implemented large scale and robust programmes to promote savings through measures such as BACS. The Commission could produce guidelines illustrating what such programmes would look like and use these to benchmark compliance. QUESTION 75. HAVE INSPECTIONS REQUIRED BY THE EPBD, BEEN INCORPORATED INTO OR MORE TIGHTLY LINKED TO OTHER INSPECTION/CERTIFICATION/ENERGY AUDITING ACTIVITIES AND SCHEMES UNDER OTHER EU OR NATIONAL DIRECTIVES? Building inspections for boiler systems, air conditioning systems, safety of gas and electrical installations (a.o.) could be better streamlined to make the less onerous to building owners. K. OPERATIONAL MANAGEMENT AND MAINTENANCE QUESTION 77. BASED ON EXISTING EXPERIENCE, DOES THE EPBD PROMOTE THE KEY WAYS TO ENSURE THAT BUILDINGS MEET STRINGENT EFFICIENCY TARGETS IN THEIR OPERATION? Building codes will only address the quality and performance of energy service equipment in the event of new- build or major renovations. On the other hand, Ecodesign specifications can only apply to components and not to the installed system as a whole. This leaves a large gap when new or replacement HVAC systems or their controls are installed that is not easily addressed with the currently implemented measures. This raises the scope, therefore, for a new type of policy instrument aimed at setting requirements for the energy performance of installed systems. It could be designed to apply to a host of systems types including lighting, HVAC, cables, motor systems etc. and if implemented at EU level would most likely would need to be structured with a subsidiarity principle embedded, i.e. that it could impose obligations on EU Member States to develop and enact installed system requirements according to a common set of principles rather than centrally specifying precisely what such specifications should be. This would reflect that the single market is only lightly involved in the market for installed systems as most service provision is at the local rather than transnational level. Such a Directive or amendment to the EPBD would clearly require considerable development work to establish the nature of such an EU driven process, however, the scale of potential savings are such that this effort would be justified and could help complete the EU’s portfolio of energy efficiency legislation. Even in the absence of such EU measures individual Member States could develop their own requirements should it not prove to be possible to develop a common EU framework. QUESTION 78. BASED ON EXISTING EXPERIENCE, DOES THE EPBD PROMOTE THE BEST WAY TO CLOSE THE GAP BETWEEN DESIGNED AND ACTUAL ENERGY PERFORMANCE OF BUILDINGS? The main element which explains the difference between the designed and actual energy performance of a building lies in the adequacy of the control of energy services. If a building has an effective control strategy its operational energy consumption will tend to align with the asset rating because energy will not be being wasted due to the provision of energy services when unneeded i.e. to unoccupied spaces or due to the over provision of energy services i.e. overheating a space. Basic differences in occupancy rates will still affect the asset versus operational rating but the important aspect of control will have been removed. Conversely, when the control of building energy services is poor the difference between the operational and asset ratings will increase.
- 14. Publication No Cu0233 Issue Date: October 2015 Page 12 It should be viable to determine EPCs both through asset ratings and operational ratings, to determine the typical historical occupancy characteristics (through a simple owner survey conducted when drawing up the EPC) and then use the difference between the two (post normalised for the difference in actual occupancy compared to the occupancy considered in the asset rating calculation) to then determine the adequacy of the control strategy. If a large gap is found (i.e. the operational rating is significantly worse than the occupancy adjusted asset rating) it would imply a failure in the control strategy. Several MS already use EPC determinations based on both asset and operational energy ratings so in this case it would be a simple step to add this additional aspect. This in turn would allow direct recommendations to be given to the building owner/occupiers with respect to the control strategy.