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.