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Notes from the edge of the minefield

Bob Cowlard highlights the Herculean task facing those drafting the new EU energy labelling laws

In the army, where dry humour is often used to convey uncomfortable truths, certain individuals can get a reputation as “bullet magnets”.

What this means is that, as a result of sheer size, a crop of bright orange hair or perhaps just bad luck, certain people are considered by their colleagues more likely to find themselves in the firing line than the average squaddie. The message, on active duty at least, is “keep clear”.

In much the same way, with each passing day our industry seems increasingly becoming a “legislation magnet”. It is perhaps because modern air conditioning and refrigeration systems touch a combination of some of the most sensitive and strategically important energy and environmental issues of the day.

For a start, they consume significant amounts of electricity (and sometimes gas); they are based on pressurised systems with volatile fluids, often with a global warming potential; and they are mechanical systems made from steel, copper and aluminium - raw materials in a world where these resources are in limited supply.

Looked at it like this, it perhaps should not come as too much of a surprise that we find ourselves at the epicentre of never-ending waves of legislative.

Now, after new laws and directives on pressurised systems, ozone depleting substances, hazardous waste materials, recycling, F-gases, the performance of buildings and so on, we have new requirements on the way for energy labelling of equipment. If you thought that trying to form a common position that would unite all member states within the enlarged EU was getting to be a tricky process, wait until you hear about the challenge posed by the new energy labelling scheme.

I had the opportunity of attending a recent EU energy legislation meeting held at BSRIA in December. Without drowning readers in a sea of scintillating detail, I thought it would be interesting to give a brief insight into the process now going on and some of the knotty problems being thrown up.

One caveat - this is a layman’s view of the subject; minds much greater than mine will no doubt spend hours, nay, days, weeks and months grappling with the issues thrown up.

The meeting involved presentations from representatives of most of the major European stakeholders. These gave a summary of the latest thinking on the subject of energy and energy labelling in their respective countries.

First, the German representative stood up and explained how they are completely against electricity as a power source for non-efficient systems, that electric storage heating is banned and that existing systems should be replaced by 2019.

Then the man from France stood up and talked about how great and clean electricity was, and that his government had introduced massive incentives to install electric products. This had resulted in something like 65 per cent of all homes across France now using electricity as their main power source. The strategy would help the country avoid being a net importer of power, and provide energy self-sufficiency - thanks to their highly successful nuclear power station building policy.

With two major players so far apart on a simple element of the energy issue, you begin to get a feel for the challenge and complexity involved in forming an acceptable European-wide policy in this area.

The consequence of such a fundamental difference of position is that, when evaluating carbon reduction in any calculations, each country will use completely different numbers when rating the ‘at source’ production. This is because electricity generated by nuclear power stations has a very low carbon dioxide emission rating; electricity produced by burning fossil fuels is obviously rated much higher.

Returning to the presentations, next up was Italy. The speaker explained that they had 17 different financial regions to co-ordinate when assessing the level of ‘green push’, or financial incentive, to provide. In addition, each of the regions had the right to apply or alter any directives locally.

The Spanish representative, when they finally got to speak, made the point that the country’s building industry was in such a sorry state that new energy legislation was not exactly the burning priority at the moment. Ladle into this mix the established though as yet unreconciled views of the UK industry, and you end up with a complete cocktail of opinion.

You should know that all this is part of a broader EU-wide process, aimed at formulating a new European Energy Label scheme based upon a number of ‘LOTS’ which cover all energy using products, to be linked in future to CE marking.

It appears that the new Energy Label scheme will be based on seasonal performance for equipment plus ‘benchmarks’ for best available, lowest life cycle costs and ‘poor’. It is at this point that we find ourselves standing at the edge of a minefield. How do you define a “benchmark” and life cycle costs when energy costs differ so much between countries?

I have great sympathy for the people whose task it is to reconcile all this. And we have not yet considered the issue of applied products and wider building services, spanning heating, cooling and ventilation. The combinations of products used within different system configurations and applications are endless.

We are not in the realm of a simple energy label for a domestic toaster here. Time to break out the flak jackets.