Environmental Legal Updates

Please find an update on environmental legal updates on F Gas rules and The Heat Network (Metering and Billing) Regulations 2014, which may impact on the operation of your buildings.

Changes to F Gas rules

Introduced in the UK on 1st January 2015, EU Regulation 517/2014 has replaced previous regulations dealing with maintenance and inspection of fluorinated gases (F-gases). Previously, inspection requirements were based on the charge, in Kilogrammes, of the refrigerant in the system. As a result of the new legislation, requirements are now based on the global warming potential (GWP) measured as the Carbon Dioxide weight equivalent of the F-Gas.

Table 1 below outlines the new maintenance frequency requirements

System Charge Leak Test Frequency
<5 tonnes CO2 Equivalent Leak tests not required
5 to <50 tonnes CO2 equivalent Annually (Once every two years if leak detection system fitted)
50 to < 500 tonnes CO2 equivalent 6-Monthly (Once a year if leak detection system fitted)
>500 tonnes CO2 equivalent Quarterly (Twice a year if leak detection system is fitted)

As a result, two different systems containing the same amount of F-Gas may now require different maintenance frequencies.

The new regulations also introduce a requirement to fit a leak detection system if your equipment contains F gas equivalent to more than 500 tonnes of CO2.

Why have the changes been implemented?

F-Gases have a high GWP, if they are released to the atmosphere they can cause significant emissions. Introducing a system which takes the type of F-Gas into account provides a risk-based approach to maintenance. Systems with F-Gases which can cause higher emissions are therefore inline to be tested more frequently. This will reduce the potential likelihood of a release occurring.

What do you need to do?

Checks need to be made on the type and amount of F-Gas held in your air conditioning systems to determine if the regulations impact upon maintenance regimes. Once the type and amount of F-Gas is confirmed it needs to be converted into CO2 equivalent tonnes.

Annexes within the regulations provide conversion factors to calculate GWP using the type and weight of refrigerant in the system.

Please don’t hesitate to call EVORA if you have any questions.

The Heat Network (Metering and Billing) Regulations 2014

The above regulations came into force in December 2014 and introduced notification, metering and billing requirements for operators of District Heat Networks and Communal Heating.

Multi-let buildings where heating and cooling is provided to tenants may be classed as communal heat networks. Steps will need to be taken to meet regulation requirements, if this is the case, andif the landlord is deemed to be a heating supplier (a person who supplies and charges for the supply of heating, cooling or hot water to a final customer).

EVORA has written to the National Measurement Office (the Government Department responsible for the legislation) to seek clarification on interpretation of the requirements in relation to operation of multi-let properties. We will provide an update when received, however, in the meantime, we recommend that Landlords take steps to prepare for the legislation. It is expected that landlords will need to consider heating supply set-ups in multi let buildings on a case-by-case basis to consider whether the legislation is applicable.

Key requirements and associated deadlines are set out below.

Step 1: Notification

Heat Suppliers must notify the national measurement office of the existence of heat networks by 30 April 2015. This is a data collection and information provision exercise. Information to be provided includes location and size of the network and the number of customers supplied. Notification should be updated every four years.

Step 2: Analysis and, where feasible, Installation

Consideration must then be given to the installation of heat and hot water meters, to final customers (TRV radiator controls and heat cost allocators must also be considered). Cost benefit analysis and subsequent installation (where feasible) must then be completed by 31 December 2016. Feasibility analysis should be reviewed every four years.

There are also requirements to ensure that adequate metering is installed on new builds going forwards.

Paul’s Predictions For 2015

Around this time of year, many organisations and individuals publish or communicate predictions for the coming year. I’ve decided to have a go.

Here are my top five predictions, good, bad and in no particular order, for 2015.

1. There will be widespread recognition that sustainability extends beyond environmental performance

In 2014, the World Green Building Council published Health, Wellbeing & Productivity in Offices – The next chapter for green building. (http://www.worldgbc.org/activities/health-wellbeing-productivity-offices/) This excellent piece of work highlights that employees account for 90% of business costs and that efforts to improve employee health and productivity through green buildings can have a huge financial implication. The report goes on to propose a high level framework for measuring organisational performance outcomes and relating these back to physical features of buildings. However, it also recognises that further work is needed in this area.

Long term – the way we work will continue to evolve – the influence of sustainability on building design and refurbishment will continue to grow!

2. 2015 will be a positive year for change – the Sustainability Agenda will progress

In 2015 business will continue to take the lead, pushing innovation and improvement (certainly on environmental performance), whilst the regulatory piece of the jigsaw gets stuck down the back of the sofa only to be found (hopefully) after the general election. Continued dithering over proposed MEES regulations, for example.

In the business world, further work will be needed to address the social aspects of sustainability (see 5).

3. However, Energy market uncertainty will have a negative impact on the pace of change

At the time of writing, the price of Brent crude oil had fallen to a new five-and-a-half year low of $50 per barrel, its lowest level since May 2009. Scholarly articles state that a combination of oversupply and weak demand will cause prices to fall further. This may be great for prices at the pump, however, it may have a negative impact on progressive sustainability initiatives. Falling fuel prices will (at least temporarily) slow the uptake of renewables. Furthermore, closer to home, it will impact on the ability of consultants accurately complete Life Cycle Cost Assessments of Sustainability Improvements.

4. Technological solutions and innovation will gather pace. The desirability of innovative and sustainable technology will continue to grow

Whilst in a post-Christmas dinner daze, slumped in front of the TV, this advert woke me up: BMW i8 Curiosity Advert

5. Ethical policies of large corporates and high profile organisations will come under increasing scrutiny – at home as well as abroad

In the latter part of 2014, several high profile businesses faced criticism for employment and supply chain policies.

In December, poor treatment of workers in Chinese factories which make Apple products was discovered by an undercover BBC Panorama investigation.

Closer to home, it was interesting to read that not all staff at premier league football clubs are well paid. So far, only one club in the top flight of English football (Chelsea) has agreed to pay all staff the living wage. A cross party group of MPs has signed an early day motion calling on all Premier League clubs to sign up to the minimum wage. It is perhaps ironic that whilst 1000 companies are now committed to paying the living wage, only three government departments (Department for Energy and Climate Change, Department for Work and Pensions and Department for Culture Media and Sport) have pledged to ensure that contractors working on their behalf are paid the living wage.

Media criticism will drive positive change, slowly!

And finally, one for good luck. My daughter is 15 months old now. I’m going to stick my neck out and say that I will get more sleep in 2015 (please Tilly)!!!

I will review at the end of 2015 to see how close I got!

 

Paul Sutcliffe
Operations Director

Stanford encouraged to rid itself of fossil fuel investments

Three hundred professors at Stanford, including Nobel laureates and this year’s Fields medal winner, are calling on the university to rid itself of all fossil fuel investments, in a sign that the campus divestment movement is gathering force.

In a letter to Stanford’s president, John Hennessy, and the board of trustees, made available exclusively to the Guardian, the faculty members call on the university to recognise the urgency of climate change and divest from all oil, coal and gas companies.

Stanford, which controls a $21.4bn (£14.2bn) endowment, eliminated direct investments in coalmining companies last May, making it the most prominent university to cut its ties to the industries that cause climate change. Months later, however, the university invested in three oil and gas companies.

Read the full story here.

Paris climate talks – our most significant task for 2015

 

 

This year’s almost mythic, defining task is to roll the boulder of a new climate agreement uphill to Paris

 

The USA and China present a united front on tackling climate change

Why the bilateral agreement between China and the USA to reducing greenhouse gas emissions is more significant than their individual commitments

Read the full article on The Guardian here

Sir Ian Cheshire explains why a commitment to sustainability is driven by a strong commercial logic

Can joined-up long-term policy-making prevail over partisan politics for the benefit of our planet and economy

Read the full article on The Independent here

How a return to core values can deliver long term profits

Can putting the common good of all stakeholders ahead of the narrow needs of the shareholders deliver greater profitability in the long term?

Read the full article on The Guardian here

EVORA support Collier & Madge to develop company-wide environmental management system

EVORA has supported commercial property manager, Collier & Madge plc to develop a successful environmental management system. The system was designed to meet ISO 14001 requirements. In December 2014 the company passed its external certification assessment with flying colours.

Fantastic feedback was received from the external auditor “It was a pleasure to audit such a well-designed, comprehensive and understandable management system. It is a rare occurrence for an environmental assessment to take place without non-conformities being raised and I would like to congratulate everyone.”

“We are delighted to have passed our ISO 14001 audit. The system will further enable Collier & Madge to deliver a top class sustainability service to our clients. The support provided by EVORA was excellent and ensured that the EMS implementation project ran smoothly to time and budget. We would not hesitate in recommending EVORA.”
Christopher Carrick, Director, Collier and Madge

Public want global action to tackle climate change

Great to see the huge public appetite for climate change action, but are we really willing and ready to change our lifestyles to accommodate this?

Read the full article on Gov UK

EU leaders agree to cut greenhouse gas emissions by 40% by 2030

A climate change pact agreed by EU leaders to significantly cut CO2 emissions is great news but key aspects of the deal have been left vague or voluntary, raising questions as to how the targets will be realised.

Read the full article on The Guardian here