The vast majority of AC systems in the commercial buildings have been in breach of the law for at least two years- and very few people seem to care. Apart from potential legal penalties, building owners and managers are also missing out on possible energy efficiency benefits. The country is also losing a key part of its strategy for meeting climate change targets.
Under the UK’s energy efficiency regulations, all air conditioning systems in buildings with a cooling capacity over 12kW must be inspected. This has been the case since January 2011, and before for larger systems.
But very few systems- of any size- have been inspected. The latest estimates suggest fewer than 10 percent of systems have. Local authorities, who are charged with enforcing this law, are clearly not doing a great job of it, and most building owners are not even aware of their legal responsibilities.
Mandatory air conditioning inspections were brought in as a part of the European Energy Performance of Buildings Directive (EPBD), but there was barely a flicker of reaction when the first deadline in 2009 passed. This prompt the government of the time to introduce “compulsory lodgement” of the inspectors, reports, through its non-domestic energy performance certificate register, in a bid to keep better track of which buildings were slipping through the net.
Compulsory lodgement has now been in place for two years, but has made very little difference; and the government has just made it less likely by doubling the actual cost of lodgement.
Also, as part of new requirements imposed by the Department of Energy & Climate Change on certification bodies, contractors are required to use a lodgement software system that is patently unfit for purpose. It is complex, time consuming and not at all user friendly. For example, if the assessor makes any spelling mistakes, the report will be rejected. Worse, it does not have the facility for decimal points when entering refrigerant charge, so creates inaccurate calculations and so on. The assessors are generally contractors trying to make a living in a tough economic environment- so they will hardly be encouraged to comply by being forced to use tricky glitch software.
Furthermore, fines for non-compliance are quite likely to be less than the amount paid for an inspection- the maximum penalty is just £300. To add insult to injury, some insurance companies even offer policies that cover building owners and operators for penalties if they are found to not have the right paperwork.
Under compulsory lodgement it should be easier to trace buildings that are failing to comply with their legal obligations, but there is little evidence that this happens in practise. Local authorities clearly don’t appear to have the expertise, resources, time or inclination to take the task on.
You can argue about practicality of such law with so many systems to check and so few people qualified to inspect them, but the point is that the DECC believed it was fit for purpose when it introduced it. Now inspections are in danger of becoming another victim of the coalition government’s war on what it sees as ‘red tape’.
This of course entirely misses the point that they should be a central pillar of the country’s strategy to cut energy use in buildings- and therefore the owners running costs. Energy prices are heading inexorably upwards so, if the legal argument is a bit of a turn off and the enforcement threat rather empty, surely the potential financial benefit should hit home.
An air conditioning report is produced as a result of the inspection and includes recommendations on how the systems could be run more efficiently. By implanting these recommendations, businesses can cut their energy bills and their carbon emissions.
B&E, in good faith, urged its members to join accreditation programs for air condition inspections and to become energy assessors, in order to help shape regulations that would support practical efforts to cut the cost of operating buildings and help the country meet its climate change targets, Many have done so, investing considerable time and money in the training, but have been confronted with general indifference from clients, who don’t see the value and don’t have the “push” from authorities.
An assessment is not just a tick box exercise; it should be carried out by a properly trained and accredited inspector with expertise in the cooling industry.
The inspection reports are useful working documents designed to help building operators improve the value of their built assets by giving them valuable energy efficiency advice and helpful practical steps.
Our industry is standing by with all of the accreditation processes all in place, It is time for local and central government to show whether they believe in energy efficiency or not.