Annex 6.C - Consideration of High-Efficiency Alternative Systems in New Buildings
On 9 January 2013, a new requirement within building regulations was introduced in response to Article 6 (new buildings) of Directive 2010/31/EU on the Energy Performance of Buildings -
Article 6 - New buildings
Member States shall take the necessary measures to ensure that new buildings meet the minimum energy performance requirements set in accordance with Article 4.
For new buildings, Member States shall ensure that, before construction starts, the technical, environmental and economic feasibility of high-efficiency alternative systems such as those listed below, if available, is considered and taken into account:
decentralised energy supply systems based on energy from renewable sources
district or block heating or cooling, particularly where it is based entirely or partially on energy from renewable sources
Member States shall ensure that the analysis of alternative systems referred to in paragraph 1 is documented and available for verification purposes.
That analysis of alternative systems may be carried out for individual buildings or for groups of similar buildings or for common typologies of buildings in the same area. As far as collective heating and cooling systems are concerned, the analysis may be carried out for all buildings connected to the system in the same area.
Accordingly, a statement on how these technologies were considered in arriving at the solution within a building warrant submission should accompany each application for building warrant for a new building made on or after 9 January 2013.
This is relevant to systems specified in relation to Standard 6.3 (heating systems) and, where mechanical cooling is proposed, Standard 6.6 (mechanical ventilation and air conditioning) and also to use of low or zero carbon generating technologies which contribute to meeting emissions targets set under Standard 6.1 (carbon dioxide emissions).
This requirement has no direct implications for the design, specification and construction of new buildings and the functional standards and guidance applicable to heating and cooling systems were unchanged within the Technical Handbooks.
Applicants are not required to use the described technologies. The purpose of this article of the Directive is to encourage awareness and consideration of such solutions.
Whilst new buildings do not have to incorporate such technologies, the challenging standards set under Standard 6.1 (carbon dioxide emissions) do mean that they are a more common part of design solutions in energy efficient, low carbon buildings. For example, elements such as photovoltaic (PV) panels and (in the electricity fuel package) an air to water heat pump is used in the specification to set the Target Emissions Rate for new homes.
This means that a range of ‘high-efficiency alternative systems’ will be considered as a matter of course as part of the design process for new homes. This process should not therefore generate a separate and detailed options analysis but will simply record the key outcomes of discussions on this topic during the design process.
When submitting a building warrant, applicants should include a short design statement identifying how the technologies identified in the Directive were discussed and considered as options during the design process and the outcome of that process as shown in submitted proposals.
These technologies include, but need not be limited to:
decentralised energy supply systems (technologies that do not rely directly on the high- voltage electricity transmission network or gas grid) based on energy from renewable sources
cogeneration - e.g. combined heat and power (CHP)
district or block heating or cooling - including partial or full use of renewable energy sources, and
heat pump technologies
There is no prescribed format or standard form for this exercise but the statement should include at least the following elements.
Applicant – name, address and contact details
Duly authorised Agent (if any) – name, address and contact details
Owner (only if different from applicant) – name, address and contact details
Location of building or site to which the application relates – address & post code (if known)
Proposed use of building
All the above information should be as recorded on the building warrant application form, plus
In providing solutions which meet Standards 6.1 (carbon dioxide emissions), 6.3 (heating system) and 6.6 (mechanical ventilation and air conditioning), is use of high-efficiency alternative systems specified? (if yes, list solutions used)
If such systems are present, main reasons influencing the decision to use?
If such systems not used, main reasons influencing the decision to not adopt options?
Analysis may be as concise or as comprehensive as the applicant or their agent consider to be appropriate to the level of discussion that occurred and type and complexity of the project.
A single assessment can be provided with each building warrant though the assessment may have to include separate analysis sections where buildings are different in form or use. Article 6(3) clearly notes that “analysis of alternative systems may be carried out for individual buildings or for groups of similar buildings or for common typologies of buildings in the same area”.
Once submitted, the statement is retained with other building warrant information as a document of record. The verifier is only required to record receipt of the statement and takes no action in respect of the content.