On 22 June 2017, AIE, AREA and GCP Europe released the following joint position paper:
The AIE (European Association of electrical contracting companies), AREA (European association of refrigeration, air conditioning and heat pump contractors) and GCP Europe (Voice of the efficient building engineering services),3 main European associations representing the interest of the installers agreed jointly on 3 specific elements of the proposal of utmost importance for the installation sector:
1. Making inspections mandatory with adequate associated thresholds
Welcoming the fact that the provisions on periodic inspections of heating and cooling systems are maintained in the proposal, there is no mutual exclusivity between periodic inspections and the presence of building automation and control systems. The associations therefore advocate that the current framework on building automation and control systems and periodic inspections should be kept, rather than making it possible to replace the latter by the former.
Additionally, AIE, AREA and GCP Europe are concerned by the enormous increase of the thresholds under which no periodic inspection is necessary. The current thresholds should be maintained to make them purposeful in the spirit of the EPBD Directive and a concrete time frame of 5 years for frequency of inspections should be implemented.
2. Ensuring better Indoor Environment Quality
There is a delicate balance between the drive towards energy savings with increasingly energy-efficient buildings and Indoor Environment Quality (IEQ). Therefore, mandatory inspections should include ventilation and air quality checks in order to adequately support Indoor Environment Quality aspects.
3. Enabling a proper framework for the deployment of e-mobility infrastructure
The associations strongly support the obligation to include the pre-cabling / pre-tubing with sufficient capacity to allow increasing power needs that will enable the installation of a recharge infrastructure in all new residential buildings and those undergoing major renovation in line with the deployment of the electric vehicles market in each Member State.