Last July the kick-off of the follow-up to the study 'Building Automation and Control Systems (BACS)' took place. This study is the second part of the exploratory path towards the establishment of Ecodesign and energy labelling regulations for BACS. This article provides an overview of the most important points of discussion.
A short recap of the regulatory situation
Currently there is no separate Ecodesign or energy labelling regulation for the product group ‘building automation and control systems’ (BACS). It is one of the product groups that has been identified in the Ecodesign Work Programme 2016-2019 as having a high energy savings potential. Therefore a study was initiated to determine the appropriate scope for the regulations. This study can be seen as the first part of the 'prepatory study' in figure 1. After completion of this study, a follow-up study as part of the 'prepatory study' was announced to investigate a concrete proposal for energy performance requirements. If the conclusion of the full 'prepatory study' finds it useful to establish Ecodesign and energy labelling requirements for BACS products, all steps in the process will be followed in order to establish the regulations (see figure 1). The European federations will take the lead in giving feedback at the moments marked with an asterisk. Agoria will be able to provide advice on the position of the Belgian industry to Member States once they have to decide on approval of the regulation (steps marked with a blue asterisk).
Figure 1: Overview of the stakeholder consultations (asterisk) in the Ecodesign and Energy labelling review or preparation process (Source: European Commission, DG Energy)
Results of the first study
The first BACS study looked at the possible justifications for the introduction of regulation and includes already a proposal on what the Ecodesign and energy labelling requirements could be. A number of the mentioned reasons are mentioned; the limited visibility of the energy performance of BACS, the limited knowledge about their savings potential and implementation options and the limited application by the government. The study includes an inventory of the available definitions and product categories in the BACS specific standards and regulations, European standards and a screening of the existing Ecodesign product groups. However, a reference is also made to a number of existing policy measures in the Energy Performance of Buildings Directive (EPBD) and the Energy Efficiency Directive (EED) and possible (installation) requirements at a system level, which could, as an alternative to Ecodesign and energy labelling regulations, increase the visibility and awareness of BACS. Requirements for the functionality, compatibility, accuracy and interoperability of BACS are specifically mentioned in the context of Ecodesign.
Recommendations for the follow-up study
The study concludes that the greatest potential for Ecodesign and energy labelling products lies in the functionality, accuracy and self-consumption of the BACS. In addition, it is proposed to review the bonus system applied in existing lots as ENER lot 1 (space heaters) and ENER lot 2 (water heaters). The reason is that the applied bonuses are supposed to not be in line with the standard EN 15232. The report only refers to ENER lot 1 and 2 as product group regulations that make use of this system, but it is actually also proposed in a number of ongoing revision, such as ENER lot 20. Finally, it is recommended for the follow-up study to also look at the interoperability of BACS, the resolution of issues from ENER lot 33 (smart appliances), and the repairability requirements. Finally, the study also proposes the possible development of a 'Smart BACS energy savings calculator' on the basis of which the energy performance of BACS can be determined. A concrete proposal for the scope of the product group is not really clear from the report. An analysis of the different options for defining the scope and corresponding energy saving potential seems to be missing as well.
Discussion point 1: Scope of the regulation
An important point of discussion in this dossier is the definition of the scope of the new regulations. Control systems are already part of the scope of a number of existing product groups such as ENER lot 1 (room heating) and air conditioners (ENER lot 10). In a number of ongoing revisions of Ecodesign and energy labelling regulations, such as local space heating (ENER lot 20) and lighting (ENER lot 8, 9 and 19), control systems are being added to the scope. When it is decided that the BACS product group will include all control systems, the questions is how the provisions in the existing product groups regulations can be 'moved' to the new product group. As the regulations have a legal status, this will likely have to be done with a (new) revision procedure for all the lots concerned (see figure 1). In this review process, all experts from the various existing product groups will have to be involved in order to provide the necessary expertise.
Possible consequences of all control systems in one group
The proposal to include all control systems in a separate product group raises the question of how this affects the valuation of control systems in the energy performance of a product. For example, in the revision of ENER lot 20, there is currently talk of awarding bonus points for the application of certain control systems, which will enable a better energy performance of the product to be achieved. A formula has been proposed to be included in the regulations including an allocation of points specifically for the control system. It is not clear how, in the case of a relocation of the control system requirements to the BACS product group, this formula can be split between regulatory frameworks for two different product groups. The inclusion of requirements in two different regulations aimed at the same product can lead to confusion as a result of cascading regulation. The non-inclusion of control systems is also not an option, as this would neglect part of the energy performance potential of the product that is likely to have an increasing impact as product are required to become more energy efficient. It is also questionable whether it is practically possible to determine the energy performance of control systems independently of the product; this will certainly not be the case for all product groups.
Options for a possible solution
The discussion shows that a clearly defined scope is essential for the further implementation of the preparatory study. However, it is not yet clear from the conclusion of the report of the first study whether all options to come to a clear scope have been investigated. One way forward could be to define horizontal regulation containing general guidelines for the assessment of the control systems in the individual product groups as is done for material efficiency (CEN-CLC/JTC 10) for example. In practice this means the development of a number of standards to guide the development of the specific requirements per product group. Another option is to define a separate product group for the building automation and control systems excluding products that are already included in an existing product group. A combination of the two options is also possible. Given the objective of the scoping study , the main question in deciding on the best option is the extent to which the selected track will contribute to an increased energy efficiency of the products.
In September 2018, Agoria submitted a position to raise the above mentioned points as a result of the publication of the first 'scoping' report. Agoria has also brought this issue to the attention of European federations.
Discussion point 2: Energy savings calculator
A second point of discussion in the first study was the suggestion to investigate the possibilities of introducing an online "smart BACS energy savings calculator" in the follow-up study, which has now started. Such a calculator could provide support in determining the energy efficiency index. With an online calculator it is said it could also be possible to model the interaction of technologies and prevent any double counting. This may be too complex for a conventional calculation method as the interactions between buildings and parts of the building may need to be taken into account in order to determine the energy efficiency of BACS.
Determination of energy efficiency of BACS products
This raises the question on how the energy efficiency of building automation products is to be determined. The difficulty in determining the energy efficiency of building automation systems is that the potential is highly dependent on their application; the interaction between the BACS (the building system), the installation and (indirectly) the impact on the composition of the energy demand. These aspects are difficult to trace back to a stand-alone product. This issue is currently dealt with in existing product groups by providing the option to assign bonus points in determination of the energy performance of a product when a control system is available or supplied. These bonus points are determined per product group. However, such a system might be less suitable for the application to stand-alone building automation systems as there seems to be little distinction among the control systems. This argues in favour of the separate treatment of control systems in the specific product group defined for this purpose. The report of the first study argues for a review of bonus points design with the aim of standardising them.
Interaction with ongoing smart technology files
There appear to be strong similarities between the proposal for the calculator, the developments around the Smart Readiness Indicator (SRI) and the Energy Labelling Database (EPREL). The calculator is presented in the first report with the possible options to generate an energy label and as a potential support for the market monitoring activities of the authorities. This has strong similarities with the way in which the Energy labelling database (EPREL) currently operates. A connection to the EPREL database is also proposed in the chapter on policy options. The path currently being investigated within the European Smart Readiness Indicator (SRI) study to make the SRI data available in a database also has common ground with the aforementioned initiatives. Ultimately, it is better to invest in one well-functioning database than to set up several separate databases in order to limit the administrative burden and to be able to guarantee the a level of quality of the content. Given the strong similarities in the different proposals, there is therefore a strong opportunity to explore possible integration options.
Now that the follow-up study has started, the next step is to see how the scope will eventually be defined for the remaining study work. Agoria is working with the European federations to see if further clarifications on the scope and the requirements of the first study can be achieved. The first results of the follow-up study will be presented at the next stakeholder meeting, scheduled for February 2020. Direct follow-up of the study is possible by registering on the study website for ENER lot 38. If you have any feedback or questions about the issues discussed in this article, please contact Charlotte van de Water (see contact details below).
- Website for the prepatory study on BACS (ENER lot 38)
- Information on the Ecodesign or Energy labelling review procedures
- Overview of ongoing files on smart technology