Air conditioning & Refrigeration European Association

AREA

April 2006Newsletter

Items covered: - Environment - F-gas Regulation MEP Doyle Report to the Plenary and formal approval of the Conciliation Agreement in the European Parliament p.3 Presentation of the MINIREF project to DG Environment p.5 Discussion about extending the Regulation to refrigerated transport p.5 - Education & vocational training News on The Refrigeration Craftsman (Leonardo) project p.6 Opinions about the progress of the Lisbon Strategy p.7 - MINIREF project Recent presentation / project website p.8 - Standardisation TC 182 to consider revision of EN 13313 p.10 New documents available at the secretariat p.11 - European Parliament Report on Energy Efficiency p.11 - European Council Spring Summit p.12 - European Legislation WEEE p.13 Ecolabelling of renewable energy sources p.15 Ecolabelling of heat pumps p.16 EPBD (see special annex) p.16 - Member States UK on implementation of EPBD p.18 - News from our Members S CHKT p.20 - Sister association ECSLA, Renewable Energy House (new!) p.21

1- Events p.23

President : J. JACQUIN - SNEFCCA F - e-mail : contact@snefcca.com Past President : N. MITCHELL - RACG/HVCA UK - e-mail : ncm@normanmitchell.co.uk Vice-President : Ch. SCHOLZ - VDKF D – e-mail : info@vdkf.org Treasurer : J. HOOGKAMER - NVKL NL - e-mail : joh@fme.nl Director : A. ZOLTAN – HKVSZ HU - e-mail : zoltan.attila@hkvsz.hu General Secretary : R. BERCKMANS - AREA - e-mail : robert.berckmans@area-eur.be Beau Site Première avenue, 88 • B -1330 Rixensart • Belgium • Tel : +32 2 6538835 • Fax + 32 2 6523872

Editorial

Dear Members, This month, I give the floor to Mr. Jochen Winkler, President of ASERCOM, who recently expressed the following opinion to EPEE Members about the second European Climate Change Programme ECCP II. Yours sincerely,

Robert Berckmans Secretary General

“As participant of the two ECCP meetings sub group "Energy Demand", I am convinced that here the main EC focus is and will remain for 2006/2007: energy saving measures with regard to household appliances (and office equipment) as well as to buildings (now 1000 sqm up but lowering this level to 200 sqm up, e.g. including private sector, this for existing and new ones). My suggestion for the EPEE position paper is: - full support for e-saving measures and labeling schemes whenever products have built-in refrigeration circuits, we will assist - this is our business; - full support for measures with regard to buildings, again when refrigeration circuits are incorporated, e.g. air conditioning systems but predominantly heat pump systems (here: promotion of heating). If we consider the huge potential available here for energy savings, all the other areas will have only second priority for considerations. My recommendation is to address these segments (supermarket etc.) at a later stage. One of the "administrators" in DG TREN with responsibilities for energy in buildings said to me recently:"...with the exception of some regions in Southern Europe we really do not need air conditioning systems for only a few hot days in Europe during summer time, this is wasted energy". This person, however, is very much in favor of heat pump systems. Jochen Winkler”

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Environment F-Gas Regulation issue

Doyle report to the Plenary on the joint text approved by the Conciliation Committee for a Regulation of the European Parliament and of the Council

on certain fluorinated greenhouse gases Source : EPEE – 30 March It includes the final agreed text of the Regulation, more interestingly it contains an explanatory memorandum focused on the results of the conciliation. Key points in this report are: • The EP is happy with the conciliation outcome ‘as it goes far beyond what was possible during the first and second readings’ • The report highlights the provisions concerning stricter national measures and labelling as representing ‘a substantial improvement of the Common Position’. • The report confirms that the meeting on 31 January was limited to the issues of Stricter national measures/ the Revision clause/ and Labelling o On Stricter national measures the report highlights the agreement to the the general principle that Member States can maintain or introduce stricter national measures in accordance with the provisions of the Treaty. On the specific case of the existing national measures in Denmark and Austria, against which the Commission has been considering legal action, a safeguard clause was introduced, which will allow the two Member States to keep their legislation until 31 December 2012. o On Revision clause a clause allowing for revision of the provisions in the light of existing or future international commitments to combat climate change was introduced o On Labelling the compromise foresees that appliances containing fluorinated gases can be placed on the market only if they bear a label clearly indicating the names of the fluorinated gases and the quantity contained in the appliance. The instruction manuals accompanying the appliances must also indicate the potential environmental impact of the gases.

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Plenary voting session at the European Parliament delayed Source : EPEE – 5 April The conciliation agreement on the F-Gases Regulation and the Directive on Air-Conditioning Systems in Motor Vehicles provides that Members States can maintain or introduce stricter national measures (as is currently the case in Denmark and Austria). During the discussion on the two pieces of legislation on April 4th, the European Commission introduced a new declaration after the conciliation agreement of 31 January concerning the legal interpretation of this provision. The declaration is as follows:

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• The Commission notes the agreement between the European Parliament and the Council on the insertion, in the Regulation, of a provision allowing Member States to maintain, until 2012, more stringent national measures compared to those laid down in the Regulation, should these measures be adopted before 31 December 2005.

• It results from the Treaty that if, after the adoption of a harmonised measure, a Member State

considers it necessary to maintain national measures that are justified by important requirements specified in Article 30 of the EC Treaty or relating to the protection of the environment or of the working environment, this Member State notifies them to the Commission, indicating the reasons for their maintenance. Additionally, the Treaty specifies the rules for the acceptance or rejection of these measures by the Commission.

• The Commission is therefore obliged to reserve its position on this issue including any right it may have under the Treaty.

As this text had not been introduced during conciliation, Mrs Doyle requested clarifications from the Commission and a postponement of the vote of the two reports: "In the light of a declaration put on the record by the Commission during last night's plenary debate on the regulation on certain fluorinated gases, the text of which was not introduced during conciliation and which compromises the spirit of the conciliation agreement and shows great disrespect and disregard for the clear will of Parliament and Council, I would like to request a postponement of the vote on the two reports on fluorinated gases at least until tomorrow." Her request was put to a vote and approved. While most of the MEPs mentioned above spoke in favour of the conciliation agreement, the majority criticized the Commission’s statement and many called for its withdrawal. They said that the Commission’s attempt to repeat the Treaty provisions that would force Denmark and Austria to notify their measures and get approval from the Commission goes against the spirit of the conciliation agreement reached between the Council and the EP. Many MEPs also raised the subject of the Commission’s infringement proceedings against Austria and Denmark, calling on them to be dropped immediately. They added that industry in these countries has shown that it was flexible enough and could adapt to the new environmental legislation, promoting green innovation.

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Final approval at the European Parliament Source : EPEE – 6 April The European Parliament finally approved both the F-Gases Regulation and the Directive on Air-Conditioning Systems in Motor Vehicles as agreed in conciliation. It was a roll-call vote, with 476 voting for, 46 against, and 25 abstaining. Prior to the votes, Rapporteur Avril Doyle reiterated her belief that the Commission’s Tuesday declaration was disrespectful to the EP and the Council and that it constituted “abuse of the EP because of turf wars between two DGs.” She stated that this was expressed to the Commission in a letter signed by Professor Trakatellis MEP and herself. Mrs Doyle also said that she had a personal reassurance from Commissioner Verheugen that, should the legislation enter into force, he will propose the withdrawal of infringement proceedings against Austria and Denmark in this matter. Speaking for the Commission, Commissioner Kyprianou confirmed that the Commission will re-evaluate its infringement proceedings, in the spirit of the conciliation agreement.

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Next steps · The Council will examine the agreement at deputy-ambassador level this Friday, 7 April. · Ministers are expected to formally approve the text on 27 April.

*** Meeting at DG Enterprise on March 21 : Present :

DG Environment : Laurence Graff (Deputy Head of Unit), Peter Horrocks (Ozone Layer/Climate Change Officer), Kalina Lewanska (Assistant Officer)

DG Enterprise : Nicolas Imbert (National Expert Chemicals) Miniref project : Ronald Vermeeren (TNO), Carole Prier (ECSLA), Robert Berckmans

Mr. Vermeeren made an excellent presentation (some slides are reproduced in the Miniref section, further in this letter). He repeated the (too?) ambitious project objectives : -95% in refrigerant charge, -30% in energy savings. He further explained the progress of R&D that will widen the scope of the applications where natural refrigerants (mainly CO² and NH3) can be used. DG Environment was quite interested and was pleased to hear that retrofitting existing installations was also an option that will be studied (e.g. excluding some vessels, adapting control systems). Coming back on the F-gas Regulation, Secretary Berckmans took advantage of the meeting to inform that the AREA position on standard leak checking requirements and on minimum requirements for RAC personnel and companies would be forwarded after the Berlin General Meetings. DG Environment still considers shortening the timing for phasing out HCFC : the reason being that Member States and companies are always late in complying with the stated deadlines. AREA Secretary repeated and explained the TEC opinion to leave the dates of EC 2037 unchanged. He asked about the implementation of WEEE and the situation of fixed RAC installations / assemblies : nobody could answer. (but in the meantime, a new DG ENV Officer in charge of this Directive, was contacted by the AREA secretariat)

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Discussion to extend the F-gases Regulation to refrigerated transport A report received from Ms. C. Prier, Secretary General of ECSLA “The European Commission studies the possibility to extend the F-gases Regulation to refrigerated transport. A report from a consultancy firm named RPA was circulated recently. This report proposed to ban HFCs by 2015. A meeting was organized in the European Commission on March 22nd. The aim of this meeting was to explain to EU functionaries that no efficient alternatives to replace HFCs might exist within 9 years. Moreover any ban of HFCs should be put in place further to an impact

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assessment study. Even if some research is made to explore the possibility to use CO2, nobody can predict today that this research will become effective within 8-9 years. Therefore ECSLA and Transfrigoroute International obtained from EU functionaries that the future EC Regulation focuses only on a containment policy instead of a ban of HFCs by 2015. A Regulation focusing on handling and maintenance

The leakage control should be focused on the refrigeration unit. According to the estimation included in the report, the average costs per vehicle would be € 192.60. This would include: - Annual inspection by certified personnel: € 125 per vehicle - Records of refrigerant use: € 55 per vehicle - Certification: € 12.60 per vehicle The new EC Regulation might enter into force within 3-4 years. All companies will have to organize a leakage control per vehicle. It should be done once a year. A log book with leakage rates and repairs should be kept for each vehicle. This control will have to be done by certified personnel in special control centres. Next steps

The consultancy firm RPA will amend its report. The European Commission will look into individual sectors and come back with a proposal. No deadline is settled.”

Education & vocational training

Leonardo da Vinci

The Refrigeration Craftsman project

AREA/Leonardo Project EUR/02/C/F/NT- 84604

Agreement N° 2002-4549/001-001LE2X The project website is currently being further developed. You can view the work in progress by visiting http://www.monitorgroep.nl/area_marcplus

The Final Report has been submitted in early January. Since then, the Leonardo examiners have been asking numerous questions, not all relevant. It is very time consuming and a somewhat unpleasant experience because the examiners are new officers who did not know anything

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about the project and assume that all technical and financial decisions taken during the project might not have been the optimum ones! Moreover they do not communicate with the officers in charge during the project and who are very positive about the results. The “verdict” about the Final Report is now expected any time. It may be possible that some money is deducted from the grant : for instance, the travelling expenses of partners or competitors in the skills competitions are sometimes considered as “not the less expensive ways of travelling”. One has to think about this Leonardo treatment when committing ourselves in a new Leonardo project.

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Lisbon strategy: two reports name good and bad “pupils” One week before the EU Spring Summit, two think tanks have presented an assessment of the progress of the Lisbon reforms strategy. Both studies do not hesitate to “name and shame” the good and bad member states.

Two European think tanks have prepared evaluation reports on the progress of reform in the Member States and have come to slightly different conclusions. But both think tanks also dare to do what the Commission has avoided: to pinpoint the “heroes” and “villains” of the Lisbon reforms process. The Brussels-based think tank Bruegel presented its assessment of the relaunched Lisbon agenda on 14 March. In a policy brief, Jean Pisani-Ferry and André Sapir warn the EU not to miss the “last exit to Lisbon”. They evaluated the National Reform Programmes and the Commission’s evaluation of those programmes. On a scale from 1 to 12, most countries score below 6 when it comes to ownership of the Lisbon agenda. “Ownership” in this context refers to the involvement of national parliaments, social partners and civil society in the criteria of the National Reform Programmes . In the Bruegel ranking, Estonia has the best “ownership” (11 out of 12), followed by 9 other countries (Austria, Denmark, Poland, Spain and others) with 7 out of 12. The countries, where these stakeholders were least involved, were Belgium (3), Germany (2) and the UK (2). The London-based think tank Centre for European Reform (CER) is more positive about the progress. “Many underlying trends are positive”, the CER says in its press release. “Slowly, but steadily, the EU is moving forward in most of the areas covered by the Lisbon agenda.” In the CER ranking of top performers (“heroes) and laggards (“villains”), Denmark is number one, with Sweden and Austria following close behind. The UK, the Netherlands and Finland also get high marks. The Mediterranean countries Italy, Greece and Portugal score poorly, but the report’s number one “villain” is Poland. Positions: In a press conference during the European Business Summit on 17 March, Commission Vice-President Verheugen lambasted the Bruegel report, when asked for a reaction by EurActiv. ‘It is premature to judge the new strategy when the National Reform Programmes are only out for a few weeks”, the Enterprise Commissioner stated. He also said that there was no evidence at all that in international affairs a “naming and shaming” strategy had ever had any success. “This report is more about ideology than about science”, Mr Verheugen concluded. In the same press conference, Philippe de Buck, head of the European employers’ federation UNICE, supported the Commissioner in his rejection of the “naming and shaming” approach.

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This was in clear contradiction to UNICE President Sellière a few months ago, who, during another UNICE press conference, indicated that his organization would not shy away from shaming those countries that would not deliver. Technical matters The MINIREF Project

Extract of the presentation delivered to DG Environment by Mr. Ronald Vermeeren, Project Leader, on March 21 :

Brussels March 21st 2006Meeting DG ENVI

MINIREF: The objective

Refrigerant charge reduction• Reduction of refrigerant charge of industrial

refrigeration systems up to 95%

Reduction energy consumption • Energy savings up to 30%

Synthetic en natural refrigerants• Minimization for:

• HFC refrigerants ? decrease emissions• Natural refrigerants ? increase application

New and exisiting installations• Minimization for new and existing systems

(retrofit options)

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Brussels March 21st 2006Meeting DG ENVI

MINIREF: Functions of the refrigerant

Refrigerant charge required for

• Primary function• Cooling

• Secondary functions (buffering)• Control stability• Performance components

• Heat exchangers• Separator• Compressor (lubrication)

9%

30%4%

20%

37%

Standard refrigeration system

Brussels March 21st 2006Meeting DG ENVI

MINIREF: The minimization (1)

Primary function

Increase the degree of utility• Capacity

• = amount of refrigerant that evaporates every second

• Capacity can be increased by:• Increasing refrigerant charge• Increasing circulation frequency

Conclusion:• Charges can be minimized by

increasing the circulation

Brussels March 21st 2006Meeting DG ENVI

MINIREF: The minimization (2)

Secondary function:

• Eliminate buffers in equipment• Replace functionality using new

technologies• Micro channel heat exchangers• Quick control actions• New component designs

Defrosting micro-channels heat exchangers is an issue that will have to be studied.

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Brussels March 21st 2006Meeting DG ENVI

MINIREF: Future research

Current project:• Focus on industrial refrigeration (app. 20% of H(C)FC emissions)

Future projects:• Adaptation to other sectors:

• Supermarkets: natural refrigerants become a option• Residential and mobile air condition: very big grow market

and therefore high emission contribution for future• Marine sector: high (uncontrolled) emission contribution

TNO and NVKL have developed a very well organized project website. The document 'MINIREF simulation model' has been newly created or updated by Mr. Anton Wemmers. This document is an internal document open for comments. To have access, please visit : http://www.midoc.nl/Contents/Document.asp?ID=14390 You can use the AREA’s access : Log in : RB12 Pass : R Standardisation Mail sent on March 31 to Mr. B. Schrempf and Ms B. Alke, Chairman and Secretary of TC 182 “We give you the following information with a view to the TC 182 meeting to be held in May. It is related to the revision of EN 13313. In fact we were encouraged to do so after visiting the CMC in Brussels in the scope of a meeting on the Integrated Fishbone Approach. Mr. André Pirlet, CMC NOD New Standardization Opportunities explained to us the possibility of defining competence criteria in a TS Technical Specification. AREA is the European federation representing the National Associations (21 today) representing themselves the RAC contractors. We have just completed a Leonardo da Vinci project to define standard qualifications of a basic European Refrigeration Craftsman. It was a 3 year- process and we attach a summary about the project.

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You can find more detailed information by going on our website www.area-eur.be and clicking on the tab "refrigeration craftsman". You will find the questionnaire used in a wide EU survey, the final research report and other dissemination materials. The main result of our project, namely a portfolio of activities that the standard EU refrigeration technician has to be able to perform, has been positively accepted by several National vocational education bodies : we attach, as an example, a letter of the Dutch VET Body Kenteq. You are aware that the coming F-gas Regulation that is expected to be published during this Summer, will set in its article 5, minimum requirements for certifying the competence of RAC personnel and companies. Therefore AREA is working on the subject. We have enclosed a third document which is a FIRST DRAFT of our position about those requirements. Please do not consider it as an AREA position yet : it is only a draft at this stage and it has to go through an internal review in April and be finally voted on on May 19 in the next AREA General Assembly. We believed that it was useful to inform you as the link with EN 13313 could be relevant. Staying at your disposal and thanking you for considering our input, We remain, Yours sincerely,

Robert Berckmans Secretary General AREA

*** Available at the secretariat : proposed revision of EN 378-1/2/3/4 – by TC 182 – working documents dated 27-03-2006 Available at the secretariat : proposed revision of EN 12693 – Positive displacement refrigerant compressors – by TC 182 – working document dated 14-03-2006 Available at the secretariat : recent draft (20/3/2006) of prEN Refrigerating systems and heat pumps – Qualification of tightness of static components – Part 1 : Static components (fittings, bursting disks, flanged or fitted assemblies)

European Parliament European Parliament’s Industry, Research & Energy (ITRE) Committee Draft report by Mr. Alejo Vidal-Quadras Roca (Conservative, Spain) on the Commission’s Green Paper on Energy Efficiency or Doing More With Less.

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As you will recall, the Green Paper was adopted by the Commission in June 2005. The main aim of the Commission is to reverse the trend of rapidly increasing energy consumption, and thus the Green Paper suggests some measures designed to achieve a 20% saving in energy consumption in a “cost-effective manner” by 2020. The Green Paper devotes separate sections to buildings and to domestic appliances. Rapporteur Vidal-Quadras Roca’s Draft Report The Draft Report calls for a number of measures of interest : • Urges full implementation and transposition of European Directives in the field of energy efficiency, notably those on the energy performance of buildings and energy end-use efficiency and energy services; • Asks the Commission to evaluate its impact on energy consumption as well as on the economy and, in the case of positive results, to consider the possibility of extending the scope of the EPBD Directive to new buildings with smaller surfaces, • Calls on the Commission to set realistic targets for the reduction of the energy intensity of the EU economy, following impact assessments of the administrative costs of introducing a system to control energy efficiency gains; • Considers that fiscal measures would be more effective as an incentive than a deterrent and should only be used as a significant part of a package of technical and regulatory measures; points out that voluntary agreements with industry are a useful model of what can be done; • Points out that energy service companies, through energy savings performance contracts, can provide the services required for building renovations relating to energy efficiency improvements without the need for initial investments by the contractor; • Calls for an increased effort in facilitating the provision of information to citizens and the private sector, including information on the availability of existing and cost-effective technology; and • Calls on Member States to promote market transformation programmes that accelerate the diffusion of cutting-edge technologies, such as efficient “A+/A++” class appliances, into the market. European Council Conclusions of the Spring European Council Source : EPEE (28 March) The summit, which took place in Brussels on March 23-24, had energy issues on the top of its agenda as a new element, along with its traditional economic and social agenda. Discussions focused around three main issues, namely the Lisbon Agenda, maintaining economic/social momentum, and an Energy Policy for Europe. Based on the Commission’s suggestions presented in the March 8th Green Paper on Energy Efficiency, discussions around an Energy Policy for Europe (EPE) came up with three objectives, namely: 1. Increasing security of supply; 2. Economic competitiveness; and 3. Promoting environmental sustainability.

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As far as the latter point is concerned, Annex III of the Council Conclusions includes an indicative list of actions that are to contribute to the objectives, enabling the adoption of a prioritised Action Plan on Energy Efficiency by the European Council in Spring 2007 (one year from now). Actions relevant for EPEE include o Adoption of an “ambitious but realistic” Action Plan on Energy Efficiency which would bear in mind the EU energy saving potential of 20% by 2020; o Full implementation of the legislation on Energy Performance in Buildings and end-user efficiency and energy services; o Continuation of an EU-wide development of renewable energies; o Completion of the review of the EU Emissions Trading Scheme (ETS) as an instrument to achieve climate change objectives; and o Provision of adequate support for RD&D measures for energy efficiency, sustainable energies and low emission technologies Finally, as far as maintaining the economic/social momentum is concerned, the Council outlined maintaining environmentally sustainable growth as one of its goals and endorsed, among others, the following lines for action: • Promoting of eco-innovations and environmental technologies, through the Environmental Technology Action Plan and the setting of performance targets; • Following up the Montreal Climate Action flan under UNFCCC, including preparation of options for a post-2012 arrangement consistent with meeting the 2˚C objective; • Promoting more sustainable consumption and production patterns, including the development of an EU SCP Action Plan and fostering green public procurement; and • Exploring further incentives/disincentives and reform subsidies that have considerable negative effects on the environmental are incompatible with sustainable development.

European legislation 1. WEEE Waste Electrical & Electronic Equipment Letter from our Member FETA / BRA 20 March 2006 Mr Andrew Lunnon Department of Trade & Industry 151 Buckingham Palace Road London SW1W 9SS Dear Andrew,

WEEE AND RoHS (Restriction of Use of Hazardous Substances) DIRECTIVES - FIXED INSTALLATIONS

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We have noted Minute 9 on the “exchange of views on the term Fixed Installations” in the DTI notes of the TAC meeting in Brussels on 15 February 2006. Further, a member has advised us

that the Dutch proposal that the exemption to the WEEE and the RoHS directives that applies to “installed equipment” should only be allowed for tools. Like the DTI, FETA has held the view that equipment such as room air conditioners that are fixed to the wall or floor and are not simply “plugged in” are correctly part of “fixed installations” and so are exempt from the scope of the directives. We were surprised at the Dutch intervention. That it only applies to large industrial tools is a very restrictive view. We are equally surprised that other Member States question the UK view at this point and appear to be opposing it. The reason we are surprised is that several European trade organisations, not just Orgalime, have supported the UK interpretation. Examples include the European Partnership for Energy and the Environment (EPEE), EUROVENT-CECOMAF and the Air Conditioning and Refrigeration Contractors European Association (AREA). They represent industries in those nations that are supporting with the contrary view. We trust the UK has no intention of altering its position on this and that you will object strongly to this new interpretation by other representatives. Yours sincerely, M G Duggan Technical Manager

The AREA secretariat has again, officially questioned the Commission, end of March, in order to receive an answer about the applicability to installations /

assemblies.

Orgalime has just published a guide entitled, "Guide to contractual options for producers selling business-to-business equipment: Contract Clauses for WEEE Obligations (Directive 2002/96/EC on Waste Electrical and Electronic Equipment)" This guide was drafted by a special working group set up by Orgalime and it aims to provide guidance and clarifications for producers in the field of business-to-business (B-2-B) contracts to respect the provisions of the WEEE Directive. The guide provides information and suggestions for contract clauses for 4 possible options available to producers when dealing with their customers: 1) retaining all obligations; 2) transferring all obligations; 3) transferring the obligation of financing only or 4) transferring the obligation collection only. The guide also outlines which option can be used in which country. To order, please go on http://www.orgalime.org/publications/order.htm

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*** 2. Ecolabelling of renewable energy sources A note from the European Heat Pump Association :

A discussion note

Whereas • renewable energy heating systems (REHS) or systems which heat and cool have a huge potential in replacing fossil fuel systems as the resource base is so large • such systems are characterised by low environmental impact and so can reduce global warming • the greatest benefits accrue to the system rather than the individual heating or heating/cooling appliance • such systems may produce their heating directly such as solar water heaters or indirectly by combustion (biomass) or concentration of low grade heat (heat pumps) • consumers will wish to identify and installers to advise on systems with high efficiency and low environmental impact • a common set of core criteria will help to make a comparison between different types of systems • the European Parliament has passed a resolution requesting that ecolabels for renewable heating and cooling systems should be developed therefore the following group of products should be eco-labelled • systems which can provide renewable heating or heating and cooling • provide space and /or water heating • the system may be stand alone or combined with another system to provide additional heating when the renewable system is unable to meet the system demand • a size limit or limits taking into account whether the system is to be applied to single or multifamily housing or district heating • the criteria to divided into mandatory all of which should be complied with and optional criteria only a number of which need to be complied with based on a points score • the mandatory criteria should be system independent whilst the optional criteria could be system specific

Possible core criteria • fitness for use in terms of provision of renewable energy heat or heating/cooling • significant energy savings by a high ratio of heat (or cold) out to energy in • ability to mitigate climate change by minimising emissions of environmental pollutants • degree of recyclability of some or all of the principal components Possible optional criteria • calculation of heat loss of dwelling with current insulation level • level of insulation which is cost effective at current energy prices • calculation of cooling demand of dwelling

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• passive solar insulation which is cost effective at current energy prices • primary heating system to be sized to provide at least …… % heating or cooling demand • any secondary system is also renewable • use of qualified installer • heating or cooling output in line with predictions • maintenance and servicing available • guarantee on parts • parts availability • users instructions • audible noise • water heating equivalent to energy efficiency class A or B of EU labelled hot water heaters • use of renewable energy electricity • use of natural refrigerants (heat pumps) Rayner Mayer European Heat Pump Association

*** 3. Ecolabelling of heat pumps Taking into account the length of the EPEE argumentation about this proposal, the EPEE position is copied as the annex to this letter. (The draft proposal of the Commission is available at the secretariat)

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4. Energy Performance of Buildings The Commission has set up a Concerted Action Group with the Member States to help the implementation of the Directive.

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European Building Performance Directive Concerted Action: an instrument to improve the good implementation of the Directive

The European Directive on the Energy Performance of Buildings poses significant challenges for EU Members States in term of the practical details of the transposition. The European Commission has consequently established a series of initiatives to try to overcome these difficulties and move towards a certain degree of harmonisation on a voluntary basis. One of the main initiatives towards promoting the dialogue between the Members States is the Concerted Action (CA), funded by the 'Intelligent Energy-Europe' Program of DG TREN.

OBJECTIVES Within the global objective consisting in sharing the information and experiences between countries, the program has the following specific objectives:

To discuss and to prepare a structure for the energy certification of buildings to maximize similarities and reduce the range of different options selected by the MS;

To discuss and prepare a coherent basis for the methodologies for inspection of heating boilers and air-conditioning equipment;

To discuss and prepare ways to implement adequate schemes for accreditation of energy audit and inspection experts in Member States;

To discuss criteria for the implementation of common methodologies for calculation of the energy performance of buildings.

To reach this goal, the CA is structured on 4 working groups, related to these 4 core themes: Theme 1: Certification of buildings Theme 2: Inspection of boilers and air-conditioning systems Theme 3: Procedural aspects for energy performance characterisation Theme 4: Specifications and training requirements for experts and inspectors

Moreover, special attention is given to promote formal and informal contacts between the Concerted Action and all the relevant groups that are working towards the transposition of the EPBD in the MS. More particulary:

The CEN working group in charge of preparing the new standards required for implementation of the EPBD;

The SAVE projects financed by the EIE program to develop and demonstrate various issues related to the EPBD implementation.

PARTICIPANTS

The CA working plan is organized around a series of 8 meetings (from January 2005 to June 2007), bringing together the participants of 25 countries (23 Member States + Bulgaria and Norway - Missing: Czech Republic, Luxemburg, Malta).

The CA-participants are the representatives of national governmental ministries or governmental affiliated institutions that are in charge of preparing the technical, legal and administrative framework for the transposition of the EPBD in their own country.

Please visit : http://www.epbd-ca.org/

5th CA meeting is coming soon (Budapest, 8-9 May 2006), followed by an EPBD international conference (10-12 May)

The programme for the next CA meeting, May 8-9, in Budapest, is ready and the core-team leaders are organising the technical contents of each session (please cooperate by registering quickly with Vitor Leal):

There will be a poster session, as usual, with relevant information from each country about implementation of various parts of the EPBD. Summaries shall be prepared by the core-team leaders and presented during the meeting;

The second day of the CA meeting shall be partially devoted to a strong interaction with relevant SAVE projects. Please do not forget to reserve your hotel: booking is still possible. Please do not delay till the last minute!

This 5th Concerted Action meeting will be followed by an international conference on the EPBD on 10-11 May. The conference will concentrate on the transposition of EPBD and its consequences: new requirements, first experiences, work going on, etc. Several presentations from CA members are planned.

Member States UK Revised building regulations to tackle climate change laid in parliament

ODPM News Release (ODPM = Office of the Deputy Prime Minister) 15 March 2006 Revised building regulations that increase energy efficiency standards for new buildings were laid in Parliament today. The new measures taken together with changes to strengthen Building Regulations in 2002 will improve standards by 40 per cent.

The tough new standards which come into effect on 6 April apply to all new buildings and when building work is carried out in existing buildings. The improved standards mean that developers will need to make greater use of energy saving insulation, more efficient boilers and consider using Low or Zero Carbon Systems such a solar panels and mini-wind turbines to demonstrate compliance.

Housing and Planning Minister Yvette Cooper said:

“By increasing energy efficiency standards by 40 per cent our changes to building regulations make a significant

contribution to the Government’s effort to tackle climate change and offer householders reduced fuel bills too.

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“Alongside making new homes more sustainable we are also looking at further measures to improve the

sustainability of existing homes and new planning guidance to further promote micro-generation and tackle climate

change.”

The new regulations will also improve compliance by requiring air pressure testing for new buildings, simplifying the process for calculating energy performance and establishing new competent persons self-certification schemes.

To help builders and building control bodies adapt to these changes ODPM has launched the largest ever training programme for new building regulations including train the trainer events, regional road shows and an e-learning pack to be issued to every Building Control Surveyor.

A review of building regulations was announced last December to make them simpler, more transparent and less piecemeal. The review aims to reduce regulatory burdens, make the regulations easier to understand and comply with, and align them with the new Code for Sustainable Homes which will point the way for future uplifts in mandatory standards.

Last week Yvette Cooper announced proposals to strengthen the Code for Sustainable Homes, which sets higher standards in order to increase environmental sustainability and gives home owners better information about the running costs of their homes.

ODPM is also leading a review to identify measures to increase the sustainability of existing homes. In addition ministers are considering new planning guidance to further promote micro-renewable technology and tackle climate change. Notes to editors 1. An Order enacting changes to Part L (Conservation of Fuel and Power) of the building regulations was laid in Parliament today and comes into effect on 6 April 2006. The Order can be viewed at: http://www.opsi.gov.uk/si/si2006/20060652.htm

2. Updated guidance documents accompanying the new regulations including a new edition of the Approved Document F (Ventilation) have also been published today and can be viewed at: http://www.odpm.gov.uk/index.asp?id=1130474

3. The guidance was published in draft form in September 2005. There are no changes to the technical requirements in the final documents.

4. The revised Part L implements parts of the Energy Performance of Buildings Directive including a requirement that when existing buildings with a floor area over 1000 m2 undergo major renovation, their energy efficiency should be upgraded in so far as is feasible.

5. Last month ODPM announced a two thirds cut from the usual transitional arrangements for the implementation of the revised Part L in order to maximise the impact on climate change. All major building work without full plans approval by 6 April must comply with the 2006 regulations, and work with approval must begin within 12 months in order to comply with the existing 2002 regulations.

6. The revised regulations set overall performance standards for new building but do not prescribe particular methods for meeting them in order to allow flexibility in design. However the requirement to meet these standards provides a strong incentive for developers to make much greater use of low and zero carbon technology.

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News from our Members S CHKT A recent skills competition took place in Prague. The competitors were students (18 years old). The competition included a written test on knowledge and practical test sessions.

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Sister Associations ECSLA ATEX and ammonia Mail sent by the secretariat to ECSLA on March 31 : “The ECSLA Circular N. 7/2006 about ATEX was brought to our attention today ... through the secretariat of TC 182. The problem is that there is a misunderstanding. ECSLA wrote : "Lobbying actions AREA (Air conditioning and Refrigeration European Association) which represents contractors will take action to lobby to consider ammonia as explosive substances. AREA members prepared already studies to prove that ammonia can be explosive under certain temperature in certain areas. Cold stores would be included." These statements are simply not true. As you could read in our last newsletter (03/06), Swedish authorities apparently intend to follow the Dutch position stating that NH3 is considered as a flammable refrigerant. This is all we said. AREA was not involved and is presently inactive on this issue. We have our next general meetings on May 18-19 and we shall discuss this subject at that time. We would appreciate a correction of the Circular also forwarded to TC 182.” Answer of ECSLA secretariat : “I am very surprised to see that a circular sent to our members is forwarded to TC 182.

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My members have explained to me that some AREA members such as the Dutch or the Swedish association were in favour of this classification; it is what I mean by AREA members. Thereafter I can't verify myself if it is true or not but at least your newsletter mentioned some discussions held in AREA WG. I admit to have interpreted things very quickly further to the reading and our phone discussions. However may be it is not an AREA position but it is the position of some AREA members. Well, yesterday I met Joop Hoogkamer who told me that things would be quiet now in NL. Wait and see what will happen in Sweden. In any case, ECSLA and CIAA members are fully against any implementation of the ATEX directive to the use of ammonia in refrigeration plants. Carole Prier”

*** RENEWABLE ENERGY HOUSE Inauguration The inauguration of the Renewable Energy House, which hosts for the first time all European renewable energy associations which currently employ 45 staff, took place on 22nd March 2006 in the presence of Belgian Prime Minister Guy Verhofstadt, Commission President José Manuel Barroso, Vice-President of the European Commission, Commissioner Margot Wallström, Commissioner Stavros Dimas as well as HRH Prince Laurent of Belgium together with 250 high-level invitees. The following European renewable energy associations are located in the Renewable Energy House: EREC – European Renewable Energy Council (www.erec-renewables.org) AEBIOM – European Biomass Association (www.aebiom.org) EGEC – European Geothermal Energy Council (www.egec.org) EPIA – European Photovoltaic Industry Association (www.epia.org) ESHA – European Small Hydropower Association (www.esha.be) ESTIF – European Solar Thermal Industry Federation (www.estif.org) EUBIA – European Biomass Industry Association (www.eubia.org) EUFORES – European Forum for Renewable Energy Sources (www.eufores.org) EUREC Agency – European Renewable Energy Centres Agency (www.eurec.be) EWEA – European Wind Energy Association (www.ewea.org) GWEC – Global Wind Energy Council (www.gwec.net) The Renewable Energy House is a living showcase for renewable energy and energy efficiency technologies, 100 % of heating and cooling coming from renewable energy sources (80 kW wood pellet heating system, four 115 m deep geothermal boreholes, 60 m² solar thermal collectors) as well as featuring different PV technologies producing a part of the electricity required. It is the intention to buy the remaining part of electricity from a green producer in order to make the Renewable Energy House a 100 % renewable energy building, thereby showcasing how renewables contribute to securing the energy supply of a building. EREC

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European Renewable Energy Council Renewable Energy House 63-65, rue d'Arlon B-1040 Brussels T: +32 2 546 1933 F: +32 2 546 1934 E: erec@erec-renewables.org I: www.erec-renewables.org Events ISK-SODEX Istanbul 2006 HVAC & R Exhibition of the Eurasian Region May 4-7, 2006 CNR Expo Center For information, please visit www.sodex.com.tr Or contact : Hannover-Messe Sodeks Fuarcılık A.Ş. Beybi Giz Plaza, Dereboyu Cad. Meydan Sok. No:28 Kat:2 Daire:3 Maslak - Istanbul / Türkiye Tel: + 90 (212) 290 33 33 Fax: + 90 (212) 290 33 32 E-mail: baygun@hmsf.com

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INTER SOLAR 2006 Trade fair for solar technology June 22-24, 2006 Freiburg im Breisgau, Germany For information : Tel: + 49 7231 585980 Fax: + 49 7231 5859828 info@intersolar.de www.intersolar.de

*** ANNEX

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EPEE position on Eco-labelling of heat pumps Kerstin Sahlén and Marianne Pettersson SIS Miljömärkning AB / SIS Ecolabelling S-118 80 Stockholm, Sweden Brussels, 21 March, 2006 Dear Ms Sahlén and Ms Pettersson, The European Partnership for Energy and the Environment (EPEE) is pleased to be involved in the ad-hoc working group preparing the work for the possible establishment of an eco-label for heat pumps. We welcome this opportunity to share our views on the work to-date of the group and in particular the latest proposal for criteria. Our comments are set out below EPEE represents a broad based group of responsible companies, national associations and European associations active in the European refrigeration, air-conditioning and heat-pump industry. It was formed in September 2000 in order to contribute to the development of effective European policies to limit greenhouse gas emissions from the use of refrigerants. A. Scope and methodology EPEE fully supports the principle of an eco-labelling for heat pumps. Ahead of making detailed comments on the preparatory work done so far, we wish comment on the scope and methodology of the overall work. According to the principles of the Regulation 1980/2000, eco-label criteria shall be established according to product groups. According to article 2.1 “product group” means any goods or services which serve similar purposes and are equivalent in terms of use and consumer perception. A product group may be subdivided into sub-groups with the corresponding adaptation of eco-label criteria. Consumers perceive heat pumps as only one type of heating systems (some with optional cooling) and therefore compare them with other heating systems such as fossil fuel burners, district heating or CHP (cogeneration of heat and power). EPEE therefore supports the idea raised in the previous meeting to include other heating systems in the eco-labelling scheme. As a consequence, the general product group should be “heating appliances”, of which the heat pumps are a subgroup. EPEE would therefore suggest to set-up general eco-label criteria for heating appliances and to this add some specific requirements for heat pumps. Moreover, in order to reach a set of criteria which remains workable for the coming years, it is EPEE’s belief that such criteria should be “target based” and not “methodology based”. The current proposal contains too many technological prescriptions which will limit the possibilities for future innovations. We will give concrete examples of this below. B. Specific Comments

i) On article 1 (scope)

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We have questions on the limits which are set in the definition of a “heat pump system”.

- The definition should start from the heat output, not from the compressor motor rating. The current definition would exclude heat pumps with 3 kW heating output and a compressor motor rating of less than 1 kW. It cannot be the intention to exclude such products.

- Why should an upper limit of 30 kW heating be set? Larger heat pumps in tertiary buildings may also create a greater potential for energy savings and the eco-label criteria for household and non-household heat pumps may be similar.

ii) On article 2 (applicants) The definition of “applicants” should be in line with the Regulation for eco-labelling as follows: The eligible applicants for the subgroup “heat pumps” include manufacturers, importers, traders and retailers. The two last-named may submit applications only in respect of products placed on the market under their own brand names. Note: In line with other environmental legislation such as WEEE or RoHS, traders and retailers placing products under their own brand names are in fact also “producers”. It would be recommendable to bring the definition of “producer” in line for all environmental legislation (but this goes beyond the scope of this document).

iii) On article 3 (code number) There should be a code number for the product group “heating appliances” and a number for the subgroup “heat pumps”. This relates to argument made in the scope and methodology section above.

iv) On the Annex (ecological criteria)

a) Framework In line with our above remarks, the framework for criteria for heat pumps could start from general criteria for heating systems and add some specific adaptations for heat pumps (for example the evaluation of the refrigerant gases in the Total Equivalent Warming Impact (TEWI) calculation). The current wording may give the impression that all refrigerants and cooling media are “hazardous substances” which is not the case.

b) Key criteria Items 2& 4 & 5. Refrigerant and efficiency In terms of global warming potential, the proposal to evaluate the refrigerant as separate criteria is not according to the internationally recognised methodology. The GWP value of the refrigerant gas does not give a correct indication on the global warming effect of the total system. The quantity of gas which is used should be assessed together with the estimated leakage rate, but also the impact on energy efficiency which is the dominating cause of CO2 emissions. As global warming effect will be a key environmental aspect, the Regulation stipulates that criteria need to be defined through life cycle considerations in accordance with internationally

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recognised methods and standards. We therefore propose to use the TEWI calculation method as specified in the European Standard EN378. It is essential to avoid contradictions between the eco-label programme and recognised methodologies. By using TEWI, systems using refrigerants with a high GWP value are automatically penalised in function of the GWP value, the contained quantity, the leakage and recovery rate. But this does not mean that e.g. systems using HFC gases are always worse than systems using alternative gases. For example, the IPCC- TEAP study (∗) has revealed that in many cases, heat pumps using HFCs have a lower global warming effect compared to systems using gases with a lower GWP value. Limiting the choice of refrigerants would be a prescriptive method which will hamper the development of more environmental friendly innovations. We therefore propose to work with criteria which are “target based”, especially in function of the global warming effect. Our proposal is as follows: The criteria for heat pumps (and even for heating systems in general) could be made in comparison with the mainstream heating boilers in Europe. Such target based criteria could be: - xxx % lower in CO2 emissions (based on TEWI calculation) - xxx % lower in primary energy consumption Annex II of the Eco label Regulation requires that the target values should be based on market study and technical feasibility and take into account the market structure in the Member States. Such an in depth study has been done already in view of the Energy use in Product (EuP) Directive, so the required benchmark data can be taken from there: (∗).

∗ IPCC/TEAP special report “Safeguarding the ozone layer and the global climate system – issues related to HFCs and PFCs”. Website

http://www.ipcc.ch

∗ Methodology Study Eco-design of Energy-using products – Final Report – MEEUP – Product cases report. See http://europa.eu.int/comm/enterprise/eco_design/relactiv.htm

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As an example: A gas boiler, 90% atmospheric = 61.43 kg CO2 per GJ = 0.221 kgCO2 per kWh An oil boiler, 85% atmospheric = 87.76 kg CO2 per GJ = 0.316 kg CO2 per kWh Average = (0.221+0.316)/2 = 0.269 kg CO2 per kWh If eco-label criterion for heat pumps is set at e.g. 20% lower CO2 emissions, this means the target value = maximum 0.269 x 80% = 0.215 kg CO2 emissions per kWh. This shall include all used heating techniques and energy sources. The same can be done for primary energy use, using the agreed conversion factor of 2.5 for electricity. The classification of heat pumps could also be based on different climate zones. Furthermore, it is necessary to specify if the heat pump is intended for space heating, hot water production or both as this will affect its operating conditions and seasonal efficiency. Finally, for the reasons as stated above (TEWI) but also for safety reasons, it is not appropriate that the classification of refrigerant is not needed for indirect systems. The 5th paragraph under item 2 should therefore be eliminated. Item 3 – cooling medium / secondary refrigerant In some cases, leakage of refrigerant into the secondary fluid may result in environmental or health hazards. For this reason, we recommend to add following requirement: “if the refrigerant is environmentally hazardous or toxic, care shall be taken to prevent pollution from refrigerant leakage into the secondary fluid”. Item 6 - Design and materials The document prescribes that heat pumps with a GWP value > 10 must be constructed as an indirect system. Again this is a technology prescriptive method, not a target based method. The proposal would also eliminate the possibility to use split type air-to-water heat pumps, which can be an energy efficient alternative in gas/oil boiler retrofit.

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In TEWI, the significant parameters are used in a correct relationship; therefore there is no need to impose additional criteria on the construction of the system. This criterion should therefore be omitted. Operation monitoring Connecting an operating hour meter to the compressor motor has no meaning for modulated (inverter) compressors. The annual energy use is already included in the TEWI calculation (see further below – comments on article 9).

v) Proposal for additional items Article 6. According to the Eco-label Regulation, the life cycle assessment should also look at the pre-production stage and the end of life stage, if technically feasible. For the production stage, we would like to suggest that the eco-label criteria include the same requirements as in the RoHS Directive 2002/95/EC for large household appliances. This can in fact be a general eco-label criterion for the product group “heating appliances”, not only for the subgroup heat pumps. For the waste stage, the design criteria as stipulated in the WEEE Directive 2002/96/EC could be applied, for example the target recovery rates.

vi) The degree of coverage The proposal implies that a heat pump should be designed to cover 95% of the heating demand including production of sanitary water. However, not the degree of coverage, but the “total annual energy use” is important. The “annual energy use” is already calculated in the TEWI evaluation, so there is no reason to set an upper limit to the degree of coverage (again the assessment should be “target based”, not “methodology based”). Of course the question remains how the “annual energy use” should be calculated. It is indeed important that all “energy consuming and all energy saving” parts of a heat pump system are evaluated to determine the “annual energy use”.

- From the “energy consuming” side, it is correct that the extra energy used from other energy sources must be taken into account, as there may be periods where the heat pump cannot fulfil or only partially fulfil its task. But also other energy consuming factors should not be forgotten, such as the energy consumed by extra circulating pumps or fans.

- From the “energy saving” side, solar panels are only one example of a factor which can be included, but there may also be others. For example, reversible heat pumps which can recover heat from a cooling cycle (the so-called “heat recovery” systems) have an important energy saving bonus, as they reclaim heat which would otherwise be wasted. Also ambient factors (climate zone, soil type) greatly influence the energy efficiency of heat pumps. For this reason, the manufacturer should indicate in which conditions the eco-label applies (which climate zones, soil type, necessary depth of drilling etc.)

vii) Installation and instruction manual

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Mentioning whether a system is direct or indirect is neither relevant for the environment nor for the consumer. The amount of refrigerant should be indicated in compliance with the requirements of EN378. We attach at the bottom of this letter a brief summary of the key elements in this lengthy paper. We remain at your disposition to further explain or discuss any aspect covered in this letter. Yours sincerely

Friedrich P Busch Director General EPEE CC: Christopher Maxwell, DG Environment, European Commission

Summary The current draft does not use the correct criteria. Moreover, the parameters are too technological prescriptive, which would limit future innovations. We therefore recommend to start with general “target based” criteria for the product group of “heating systems”, using the methodology and benchmarking of the EuP Directive. The additional criteria for the subgroup “heat pumps” are mainly related to the use of the refrigerant. For this purpose, the TEWI calculation is the internationally recognized evaluation method.

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