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Changes to the Energy Performance of Buildings Regulations

This consultation set out the Government‘s plans to meet the requirements for inspections of heating systems in England and Wales and options to revise requirements for the inspection of air-conditioning systems.

Objectives of the consultation

The EU Energy Performance of Buildings Directive (EPBD) was amended on 30 May 2018 to include the following changes:

  • the requirement to establish regular inspections of the accessible parts of heating systems was changed from systems with an effective rated output of over 20kW to over 70kW;
  • the requirement to establish regular inspections of the accessible parts of air conditioning systems was changed from systems with an effective rated output of over 12kW to an effective rated output of over 70kW;
  • inspections for combined heating and ventilation systems and combined air conditioning and ventilation systems.

The UK has left the EU but is required to transpose the Directive into domestic legislation as the transposition deadline falls within the Transition Period.

This consultation set out proposals to amend the existing Energy Performance of Buildings (England and Wales) Regulations 2012 for domestic and non-domestic buildings to meet the requirements under the EPBD directive.

There will be another consultation on the Energy Performance of Buildings Regulations later in the year to inform UK's future domestic policy after the end of the Transition Period, and to consider what flexibilities and improvements may be available when the UK is no longer bound by EU Directives.

This consultation closed on 14 July 2020.

Supporting papers

To download the consultation document, follow the link below.

CIBSE response

CIBSE is fully aware of the rationale for proposing to raise the threshold for inspections to 70kW. In reality we have evidence which we have submitted in the past that compliance with the current regime is weak and enforcement is weaker, due to the many other demands on the enforcement authority. The proposed change might not have huge real impact, although the impact assessment might suggest otherwise as it is based on unsubstantiated levels of compliance. In practice CIBSE suggests that many systems in the range 12-70kW are currently not inspected.

However, the current SARS CoV 2 outbreak changes many of the working assumptions behind the consultation. CIBSE published its view that airborne transmission is a risk and that it should be addressed as a precautionary measure at the end of April 2020. In early May we published more detailed guidance on the operation of ventilation systems in the current circumstances. In that guidance we explain that the need to provide higher levels of outside air and to avoid recirculation should for the time being take precedence over energy efficiency.

In the light of the outbreak, CIBSE does not recommend changing the inspection requirements. To read the CIBSE response, follow the link below.