BNAC29: The UK Building Regulations as they apply to air conditioning

Version 1.2 This Briefing Note and referenced information is a public consultation document and will be used to inform Government decisions. The information and analysis form part of the Evidence Base created by Defras Market Transformation Programme.

Summary

This Briefing Note explains the provisions of the changes to Part L of the Building Regulations, in particular to Approved Documents L2A and L2B, that took effect in April 2006, in relation to air conditioning system performance. Minimum standards for the efficiency of air conditioning systems, and control provisions, are defined in a secondary DCLG publication, the Non-Domestic Heating, Cooling and Ventilation Compliance Guide, prepared with the assistance of industry bodies. Compliance for new buildings is based on an individually calculated carbon emissions target for the proposed building, and details of the air conditioning system are required as input to the calculation model. In existing buildings minimum efficiencies are specified for replacement systems. Further building efficiency improvements are likely to be required at subsequent revisions of Part L.

General

The principal objective of the Building Regulations is to protect the health and safety of people working in and around buildings. They also set minimum performance standards for a number of building energy issues, including several that relate to air conditioning. It is often cost-effective to go beyond these minimum standards, in which case the methodologies and indices within the Regulations can be helpful ways of assessing performance. Energy consumption is only one of many issues covered by the Regulations. Building Regulations are set by central government (separately for England and Wales, Scotland, and Northern Ireland, though in practice the energy requirements are usually similar or identical albeit with different introduction dates). References below are primarily to the Regulations and Approved Documents for England and Wales concerning the conservation of fuel and power contained in Part L and Approved Document L. Equivalent Regulations and guidance documents exist for
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Scotland (Scottish Building Standards, Technical Handbook Section 6) and Northern Ireland (Building Regulations for Northern Ireland, Technical Booklet F). Building control approval - an independent check on compliance - is a legal requirement. Inspection may be carried out by the local authority or by approved inspectors, but enforcement is the responsibility of the local authority. Building Regulations apply to new buildings and many building alterations, including significant changes to the building services. There are a number of special cases where deviations from the guidance may be acceptable, notably for alterations to historic buildings. The legal requirements of the Building Regulations are expressed in general terms, with practical means of compliance described in the Approved Documents (ADs). The basic legal requirement for energy is that "reasonable provision for the conservation of fuel and power" has been demonstrated. There is no obligation to follow the guidance of the Approved Documents and alternative means of complying are acceptable in principle. However, the Approved Documents are almost always used as the means of demonstrating compliance. For energy in non-domestic buildings the relevant Approved Documents are L2A for new buildings and L2B for existing buildings (revised 2006). L2A and L2B refer to a number of technical "second tier" publications from various sources for more detailed guidance.

Timing of changes

Revised energy efficiency provisions of the Building Regulations in England and Wales came into force on 6 April 2006, having been the subject of a consultation process begun in July 2004. The amendment had been brought forward from its envisaged date of 2008 in order to help achieve targets announced in the Energy White Paper of February 2003 and to form a major part of the introduction into UK law of the EU Energy Performance of Buildings Directive(EPBD). Revised energy efficiency provisions of the Building Regulations in Northern Ireland came into force on 30 November 2006, and revised Technical Standards in Scotland came into effect on 1 May 2007.

Demonstrating compliance for non-domestic buildings

Until 2006, there had been two basic ways in which the proposer of a new building could demonstrate compliance. One was to ensure that each element of the building and services complied with the minimum performance or efficiency standard set out in the Approved Document, termed the Elemental Method. This included an elemental provision for the efficiency of cooling systems, set out in a carbon performance rating (CPR) calculation. The other method considered whole building performance either as a whole building CPR calculation or using a carbon emissions calculation method (CECM). Using the CECM, the calculated emissions would be compared with, and should not exceed, those of an equivalent building that would have complied by using the Elemental Method.

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Approved Document L2A of April 2006 introduced a new single method for demonstrating compliance for new buildings. This is based on the calculation of a predicted rate of carbon dioxide emissions from the building, which must be no worse than a target emission rate calculated individually for the building proposed. The introduction of the target-based compliance method and the National Calculation Methodology that supports it satisfies the requirements of Article 3 (to adopt a calculation methodology) and Article 4 (to set energy performance requirements based on the methodology) of the EPBD. The compliance routes included in the previous (2002) Approved Document L2, including the Elemental Method, the CPR and the CECM, are no longer available. Together with the requirement to achieve a building emission rate (BER) no worse than the target emission rate (TER), a number of additional minimum performance criteria must also be satisfied. These relate to the worst acceptable properties of the building fabric, including limiting values for insulation, airtightness and solar gain, and the minimum acceptable efficiencies of building services equipment including that used for comfort cooling and ventilation. Complying with all of the minimum performance criteria is not sufficient to achieve compliance and the design will need to improve on one or more aspects of efficiency in order to meet the TER. However, within these overall constraints the designer has full flexibility in how to achieve a BER no worse than the TER. Approved Document L2B, for work in existing buildings, does not include the use of the calculation method, and comfort cooling systems can achieve compliance by satisfying certain minimum efficiency criteria. The minimum performance criteria for comfort cooling systems in new and existing buildings are described in detail in a second tier publication - the Non-Domestic Heating, Cooling and Ventilation Compliance Guide. This guide has been produced by the DCLG with the assistance of the relevant trade organisations, and is available to download or to purchase through the DCLG website at www.communities.gov.uk and the RIBA bookshop site www.thebuildingregs.com

Calculating the Target Emission Rate and Building Emission Rate

For simpler applications, the TER can be calculated using the Simplified Building Energy Model (SBEM). This is a monthly calculation procedure developed specifically for this purpose by BRE for the DCLG to conform as far as possible to emerging European Standards. However, more complex applications may require the use of dynamic modelling, and other more appropriate models may be used, provided they are specifically approved for the purpose by the DCLG. As these are approved they are included on lists on the DCLG website and the National Calculation Methodology website at www.ncm.bre.co.uk SBEM is currently used through a basic interface, iSBEM, which is freely available as part of the SBEM model from www.ncm.bre.co.uk although other software may become available as software developers incorporate SBEM into their own models
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and in more user-friendly formats. When approved by DCLG, such software will also be included on the list of approved software. The TER is calculated in two stages. Firstly, the emission rate is calculated for a notional building with similar properties to that being proposed, but designed to comply with the standards specified in the earlier Approved Document (ADL2, 2002). SBEM includes standard sets of data that help to define the properties and servicing elements of the notional building, and standard sets of data defining the occupancy and thermal gains to be associated with the various activities that spaces in the building will be used for. Secondly, an improvement factor is applied which, in the case of air conditioned buildings, involves a multiplier of 0.20 to reflect general improvement in efficiency, and a further multiplier of 0.10 to reflect a benchmark contribution of low and zero carbon (LZC) technologies (implementing Article 5 of the EPBD to give consideration to the incorporation of LZC energy supply systems): TER = Cnotional x (1 - improvement factor) x (1 - LZC benchmark) The resultant improvement factor for air conditioned space is then: TER = Cnotional x (1 - 0.20) x (1 - 0.10) = Cnotional x 0.72 The Approved Document includes a table of carbon dioxide emission factors to be used in the calculations associated with the use of each fuel type. The BER is calculated using the same software as the TER. Approved Document L2A notes that an initial calculation based on the design parameters would normally be presented as part of the initial submission to the building control body, and that this would be followed by a final calculation for the actual building as constructed.

Interaction with fabric and other services

The BER calculated using SBEM of other approved model will take into account the properties of the fabric of the building, and of the other designed services including heating and lighting, for which the Approved Documents also impose limiting standards. Some will interact directly or indirectly on the cooling load and hence the contribution to the BER made by the cooling system. It is therefore important that they are considered in total, so that realistic expectations are made for the contribution of each component. Provisions for building thermal insulation and minimum efficiency levels for lighting systems also impact on air conditioning by affecting the size of the cooling load that has to be dealt with. The general guidance is that naturally ventilated spaces should not overheat and that cooled spaces should not require excessive cooling plant capacity. The performance standards for the notional building specified in Approved Document L2A include glazing proportions of 40% or less, depending on the use of the building, so that high levels of glazing and heat gain are likely to need to be balanced by improvements in efficiency in other areas in order to achieve the TER.

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Compliance of comfort cooling systems

The minimum acceptable standards for the efficiencies of comfort cooling plant are specified in the Non-Domestic Heating, Cooling and Ventilation Compliance Guide. This describes the efficiency of cooling plant in terms of the full load energy efficiency ratio (EER) where EER is the ratio of the cooling energy delivered into the cooling system divided by the energy input to the cooling plant. The test method and conditions for obtaining are described in BS EN 14511 (2004) Air conditioners, liquid chilling packages and heat pumps with electrically driven compressors for heating and cooling: test conditions. The minimum full load EER for cooling systems in both new and existing buildings is specified as follows:
Minimum EER 1.8 2.2 2.4 3.4 2.25 3.2 0.5 1.0

Packaged air conditioners, single duct Packaged air conditioners, other types Split and multi-split, including variable refrigerant flow Water-cooled vapour compression chillers Air-cooled vapour compression chillers Water loop heat pump Absorption chiller Gas engine driven, variable refrigerant flow

Particular control functions are also specified - for the cooling plant: Multiple cooling modules should be provided with controls to provide the most efficient operating modes for the combined plant. For the cooling system: Each terminal unit capable of providing cooling must be capable of time and temperature control either by its own, or remote, controls. In any given zone simultaneous heating and cooling shall be prevented by a suitable interlock. These provisions add to the minimum specification of general building services controls set out in the Approved Document itself, that: Systems should be subdivided into separate control zones to correspond to each area of the building that has a significantly different solar exposure or pattern or type of use. Each control zone should be capable of independent timing and temperature control and, where appropriate, ventilation and air recirculation rate. The provision of the service should respond to the requirements of the space it serves. If both heating and cooling are provided, they should be controlled so as to not operate simultaneously. Central plant should only operate as and when the zone systems require it. The default condition should be off.
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In addition the Non-Domestic Heating, Cooling and Ventilation Compliance Guide specifies the maximum specific fan power (W/ls-1) acceptable for mechanical ventilation in both new and existing buildings:
Maximum specific fan power (W/ls ) Central systems including heating, cooling and heat recovery Central systems including heating and cooling All other central systems Local ventilation units within the local area Local ventilation units remote from the area Other local units* such as fan coil units *Rating weighted average
-1

New 2.5 2.0 1.8 0.5 1.2 0.8

Existing 3.0 2.5 2.0 0.5 1.5 0.8

The Approved Document also provides that air handling plant should be capable of achieving SFP at 25% of design flow rate no greater than that achieved at 100% design flow rate, and that reasonable provision where ventilation system fans are rated at over 1100 W would be to equip them with variable speed drives. Once installed, the Regulations require that building services are effectively commissioned, and that a notice is provided to the local authority confirming that the fixed building services have been properly commissioned in accordance with a procedure approved by the Secretary of State. The notice should include a declaration that all the systems have been inspected and commissioned, and that test results confirm that performance is reasonably in accordance with the proposed building designs. The Approved Document specifies that the approved procedure would be to commission according to the CIBSE Commissioning Code M Commissioning Management, and that suitable persons to sign the report would be members of the Commissioning Specialists' Association or the HVCA Commissioning Group.

Information provision: metering and logbooks

The Regulations require that the owner and/or occupier of the building be provided with sufficient information about the building and its services so that the building can be operated and maintained in such a manner as to use no more fuel and power than is reasonable in the circumstances. The Approved Document specifies that this information should include appropriate energy meters to facilitate effective monitoring of performance, and that metering should enable at least 90% of the estimated energy use of each fuel to be assigned to the various end-use categories. Appropriate guidance on metering is available in the Action Energy publication GIL 65 (2004) Metering energy use in non-domestic buildings. The information should also include a building logbook that contains, amongst other things, details of the fixed building services and their method of operation and maintenance, and details of the energy metering provided. A suitable model for the content of the building logbook would be that of the CIBSE TM31: Building Log-book Toolkit, which includes guidance on the content of the log-book, standard templates
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and examples, and supporting documents (the metering guide GIL 65, and the Good Practice Guide GPG 348 Building log-books - a user's guide).

Compliance modelling factors

In new buildings, systems should not only comply with the efficiency and information provisions outlined above, but their details must also be incorporated into the carbon dioxide emissions model so that their contribution to the building emission rate is included in SBEM or other approved software. The Non-Domestic Heating, Cooling and Ventilation Compliance Guide outlines the information that will be needed as input to the SBEM calculation. The carbon emission model takes as its input a seasonal energy efficiency ratio (SEER) for the cooling plant. SEER is thus the ratio of the total amount of cooling energy provided, divided by the total energy input to the cooling plant, summed over the year. This measure is intended to reflect that cooling plant will not operate at full load throughout the year and that for substantial proportions of time it will operate at reduced load, under part load conditions at which its performance may be appreciably better or worse than at full load. Part load performance information will not be available for some cooling plant, and there is not yet a suitable European Standard that includes a part load test procedure. Where only full load performance information is available, the SEER is taken to be the same as the full load EER. Where an industry approved test procedure for performance measurement at partial load exists, the SEER may be estimated from the EER measured at the partial load conditions, adjusted for the cooling load profile of the proposed building. For example, where a single chiller is well matched to the applied load and information is available at four steps of load control: SEER = a (EER25) + b (EER50) + c (EER75) + d (EER100) where EERx is the EER measure at the defined partial load conditions of 25%, 50%, 75% and 100% and a, b, c and d are the load profile weighting factors relevant to the proposed application. Where the application is for general office accommodation, the guide includes values of the factors a, b, c and d that can be taken as representative of the load profile: a = 0.20, b = 0.36, c = 0.32 and d = 0.12 Otherwise, where the load profile is not known, then the partial load EERs are equally weighted: a = b = c = d = 0.25 If the load profile is not known and the EER is known at 50% load and 100% load, then the SEER can be taken as the average of the two EER (ie the EER are equally weighted).
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The Non-Domestic Heating, Cooling and Ventilation Compliance Guide suggests suitable conditions at which the part load performance of air cooled and water cooled chillers should be tested.

10 Future thinking
The July 2004 consultation document on changes to Part L noted that future revisions of Part L could occur at five-yearly intervals, with the next revisions anticipated for 2010, 2015 and 2020. The consultation documentation indicated that whole building efficiency standards might be improved by 20-30% at each revision, although no specific measures have been proposed for particular technologies. It is possible that the DCLG might propose that the Non-Domestic Heating, Cooling and Ventilation Compliance Guide is updated to include more efficient minimum performance standards. The overall emissions target-based approach to compliance does not make such guidance essential for new buildings, and there would be added incentive for designers to include more efficient plant as a matter of course in order to achieve a suitable BER. However, the minimum plant efficiency guidance will remain of benefit for work in existing buildings.

11 Implications for MTP

The guidance associated with Building Regulations now imposes minimum performance requirements for comfort cooling systems. The performance requirements and the calculation methodology defined in the Building Regulations offer opportunities for benchmarking, energy labelling and certification of equipment, systems and buildings, which it may be possible to build upon in a consistent manner for other market transformation activities. The MTP Reference scenario is being updated to account for the April 2006 Part L changes, and the other scenarios need to be developed with stakeholders to consider future policy and technology options. The SBEM route to compliance, and most likely to certification for the EPBD, increases the need for reliable system and equipment performance information, including part-load performance information and seasonal performance measures. This emphasises the need to develop testing standards and estimation methods in these areas. Work in the EU EECCAC project, within Eurovent, and within CEN is moving towards filling this gap, but more needs to be done.

12 Further information
Scotland has also adopted the emissions target for compliance, including SBEM and other changes, and revised Technical Handbooks, Section 6 Energy, came into force on 1 May 2007. For Northern Ireland, the Building (Amendment) Regulations (NI) 2006 were made on 31 August 2006. The revised DFP Technical Booklet F1: 2006 - Conservation of fuel and power in dwellings, and Technical Booklet F2: 2006 - Conservation of fuel and power in buildings other than dwellings, in which the whole building approach is adopted, took effect from 30 November 2006.
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Approved Documents and information for England and Wales and the Non-Domestic Heating, Cooling and Ventilation Compliance Guide are available at www.dclg.gov.uk and at www.thebuildingregs.com Further information on the National Calculation Methodology and SBEM are available at www.communities.gov.uk and at www.ncm.bre.co.uk Scottish Building Standards and Technical Handbooks are available at www.sbsa.gov.uk Building Regulations Northern Ireland and Technical Booklets are available at www.dfpni.gov.uk

Related MTP information

Policy Brief: UK Energy Consumption of Air Conditioning Systems. http://www.mtprog.com/PolicyBriefs/pdf.aspx?intPolicyBriefID=152&strPolicyBriefTi tle=UK Energy Consumption of Air Conditioning systems&intPolicyBriefSector=14 Briefing Note BNAC02: The European Directive on energy labelling of household air conditioners. http://www.mtprog.com/ApprovedBriefingNotes/pdf.aspx?intBriefingNoteID=272 Briefing Note BNAC06: Energy efficiency test specification for air conditioners up to 100 kW. http://www.mtprog.com/ApprovedBriefingNotes/pdf.aspx?intBriefingNoteID=88 Briefing Note BNAC18: Modelling the energy consumption of air conditioning. http://www.mtprog.com/ApprovedBriefingNotes/pdf.aspx?intBriefingNoteID=142 Briefing Note BNAC27: Energy efficiency test specification for fan coil units. http://www.mtprog.com/ApprovedBriefingNotes/pdf.aspx?intBriefingNoteID=166 Briefing Note BNAC30: The UK Building Regulations as they apply to air conditioning. http://www.mtprog.com/ApprovedBriefingNotes/pdf.aspx?intBriefingNoteID=492

Changes from version BNCR29v1.1

This version (BNAC29 v1.2) updates the reference to Building Standards in Scotland.

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Consultation and further information

Stakeholders are encouraged to review this document and provide suggestions that may improve the quality of information provided, email info@mtprog.com quoting the document reference, or call the MTP enquiry line on +44 (0) 845 600 8951. For further information on related issues visit www.mtprog.com

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