The EPBD requires (article 9) that “Member States shall lay down the necessary measures to establish a regular inspection of air-conditioning systems of an effective rated output of more than 12 kW.”
The text in the first paragraph is ambiguous as it allows several interpretations: whether the effective rated (thermal) output of 12 kW (above which inspection is required) relates to one air-conditioning unit or to the sum of all units in one building, or even to the sum of all units in one building that are owned by the same owner.
It is possible to find Member States who have adopted any one of these different interpretations in the transposition, and they all seem to be strictly correct from a legal point of view. Each interpretation has its own advantages, and MS adopted the alternative that they considered most applicable to the local market conditions.
Limiting inspections to individual units above 12 kW reduces the number of inspections to be carried out. The cost of inspecting smaller units is usually large compared to the expected energy savings, and the cost-effectiveness of these inspections may be questionable. Moreover, fewer inspections mean the need for fewer inspectors, and their lack of availability is one of the main bottlenecks for implementing this EPBD requirement.
Requiring inspections for all units in a building (or owned by the same owner in a building) when the total installed AC capacity is above 12 kW cuts the loop-hole whereby an owner needing, e.g., 20 kW of AC opts to install two smaller, but less efficient, 10 kW units just to avoid inspections. This approach promotes installation of larger more efficient units, avoiding the proliferation of smaller units which also potentially have a non-negligible visual impact.
However, the same article 9 goes on to specify that “This inspection shall include an assessment of the air-conditioning efficiency and the sizing compared to the cooling requirements of the building”. So, if one space is served by more than one AC unit, the EPBD seems to indicate that the inspection must really cover all the units simultaneously, as otherwise it will be impossible to give advice about the sizing of any individual unit without carrying out a global analysis.
Author: Eduardo MALDONADO (University of Porto, Portugal)