Article 8 of the EPBD offers two options:
1. either inspection of boilers (8.a) or
2. provision of advice to the users that must achieve an overall equivalent impact to that of inspection (8.b).
The first option (inspection of boilers) requires regular inspection ofÿboilers fired with non-renewable liquid or solid fuelÿof an effective rated output of 20 to 100 kW and inspection of boilers of an effective rated output of more than 100 kW without restriction about the fuel used.
The Directive also states that regular inspection of boilers from 20 to 100 kW may apply to fuels other than non-renewable liquid or solid fuels.
Regular inspection of boilers is therefore not compulsory for all types of fuels or all rated outputs, especially as an alternative (but equivalent) approach is allowed.
Author: François DURIER (CETIAT)
Date: 04/04/06
If a Member State chooses to implement inspection of boilers (by referring to article 8a), the following requirements should apply to wood-fired boilers:
- regular inspection of wood-fired boilers with a rated output of more than 100 kW at least every two years,
- one-off inspection of the whole heating installation with wood-fired boilers of more than 20 kW rated output which are older than 15 years.
The Member State may also require regular inspection for wood-fired boilers between 20 and 100 kW.
Author: François DURIER (CETIAT)
Date: 04/04/06
The frequency of inspection of air conditioning systems is not specified in the Directive. It is up to the Member States to specify and implement.
Author: Michèle MONDOT (CETIAT)
Date: 24/03/06
The definition of air-conditioning systems in article 2 of the EPBD (“a combination of all components required to provide a form of air treatment in which temperature is controlled or can be lowered, possibly in combination with the control of ventilation, humidity and air cleanliness”) refers to the whole system where the temperature of the air can be cooled, clearly including, therefore, its distribution and control systems.
EN standard 15240 (“Guidelines for inspection of air-conditioning systems”) includes specific items covering inspection of the distribution system and the controls of air-conditioning systems.
However, the details of the inspection procedure are fixed by each Member State and, therefore, different requirements may be found in different Members States.
Author: Eduardo MALDONADO (University of Porto, Portugal)
Date: 27/11/07
The definition of air-conditioning systems in article 2 of the EPBD (“a combination of all components required to provide a form of air treatment in which temperature is controlled or can be lowered, possibly in combination with the control of ventilation, humidity and air cleanliness”) refers to the whole system where the temperature of the air can be cooled. If that system also includes a heating mode, which is quite common, the heating component is just one more component of the whole system and, according to article 9 of the EPBD, the air-conditioning system (as whole) should be inspected. However, the details of the inspection procedure are fixed by each Member State. Thus, national procedures for inspection of air-conditioning systems may specify which components of the air-conditioning system must be inspected and how often and with which methodology that inspection is to be carried out, including, or not, the specific configuration when it operates in a heating mode. EN standard 15240 (“Guidelines for inspection of air-conditioning systems”) deals exclusively with “cooling” components and issues. Procedures for inspecting heating systems, including boilers and heat distribution systems, e.g., ventilation systems, are described in EN 15378.
Author: Eduardo MALDONADO (University of Porto, Portugal) Date: 27/11/07
If a ventilation system has no thermal component, i.e., if it strictly serves only the purpose of providing fresh air to guarantee a suitable indoor air quality, the EPBD requirement for inspections does not apply. The same applies for ventilation systems where the inlet air is only heated (e.g., when the outdoor air is too cold and would cause discomfort to the occupants or the possibility for formation of frost or condensate if brought inside the building untreated).
However, if the fresh air provided by the ventilation system can also be cooled before delivery to the occupied spaces, then these ventilation systems are, in reality, air-conditioning systems, in accordance with the definition of air-conditioning systems in article 2 of the EPBD (“a combination of all components required to provide a form of air treatment in which temperature is controlled or can be lowered, possibly in combination with the control of ventilation, humidity and air cleanliness”) and, as such, they are required to be periodically inspected, according to article 9 of the EPBD, if the cooling power is larger than 12 kW.
Author: Eduardo MALDONADO (University of Porto, Portugal)
Date: 27/11/07
The EPBD requires (article 9) that “Member States shall lay down the necessary measures to establish a regular inspection of air-conditioning systems of an effective rated output of more than 12 kW.”
The text in the first paragraph is ambiguous as it allows several interpretations: whether the effective rated (thermal) output of 12 kW (above which inspection is required) relates to one air-conditioning unit or to the sum of all units in one building, or even to the sum of all units in one building that are owned by the same owner.
It is possible to find Member States who have adopted any one of these different interpretations in the transposition, and they all seem to be strictly correct from a legal point of view. Each interpretation has its own advantages, and MS adopted the alternative that they considered most applicable to the local market conditions.
Limiting inspections to individual units above 12 kW reduces the number of inspections to be carried out. The cost of inspecting smaller units is usually large compared to the expected energy savings, and the cost-effectiveness of these inspections may be questionable. Moreover, fewer inspections mean the need for fewer inspectors, and their lack of availability is one of the main bottlenecks for implementing this EPBD requirement.
Requiring inspections for all units in a building (or owned by the same owner in a building) when the total installed AC capacity is above 12 kW cuts the loop-hole whereby an owner needing, e.g., 20 kW of AC opts to install two smaller, but less efficient, 10 kW units just to avoid inspections. This approach promotes installation of larger more efficient units, avoiding the proliferation of smaller units which also potentially have a non-negligible visual impact.
However, the same article 9 goes on to specify that “This inspection shall include an assessment of the air-conditioning efficiency and the sizing compared to the cooling requirements of the building”. So, if one space is served by more than one AC unit, the EPBD seems to indicate that the inspection must really cover all the units simultaneously, as otherwise it will be impossible to give advice about the sizing of any individual unit without carrying out a global analysis.
Author: Eduardo MALDONADO (University of Porto, Portugal)
Date: 27/11/07
The categories of buildings listed in Article 4, paragraph 3, for which Member States may decide not to set or apply minimum energy performance requirements, do only relate to Article 4, paragraph 1, and not to the inspection of boilers (Article 8) and air conditioning systems (Article 9).
The cases in which inspection of boilers and air conditioning systems could not be required are listed below:
In Member States that choose option (a) of Article 8 (regular inspection of boilers and one-off inspection of heating installation with boilers older than 15 years), buildings that use energy to condition the indoor climate could be exempted from the requirements of Article 8 if they use no boiler of an effective rated output of more than 20 kW fired with non renewable.
Member States that choose option (b) of Article 8 (provision of advice to the users) could decide that some boilers or buildings are not covered by the measures that they implement, provided that they show to the Commission that the overall impact oftheir approach is broadly equivalent to that arising from the provisions set out in option (a).
Buildings in which energy is used to condition the indoor climate cannot be exempted from the requirements of Article 9 (inspection of air conditioning systems) except if they do not use an air conditioning system of an effective rated output of more than 12 kW.
Author: Francois DURIER (CETIAT)
Date: 16/12/08