Although it is not yet time, to introduce the subject of Energy Efficiency Certification for existing buildings, or to define techniques or methods to be used, given its nature of Draft Royal Decree, of basic procedure, without definitive approval,….
Idealist news … HERE. (see also related news)
(This link from ARQUIREHAB, offers in a simple way a wide information on the subject, including the direct link to the MINETUR page for the download of, among others, the integral documents of the PRD and the computerized methodologies CE3 and CE3X of the Simplified Options. Basically what remains pending, without expecting surprises in the final approval, is what will be the modifications of the CALENER program within the General Option, to adapt it to existing buildings)
… .If there is a whole series of controversies and open debates, which deserve some attention. Let us also remember that this Certification model will be mandatory as of January 1, 2013, for those properties that are going to be sold or leased, and some “well” informed sources, and given the requirements of the European Commission, they assure that its final approval will take place throughout this month of June. (2012)
Energy Efficiency for Existing Buildings is part of this group of "positive" a priori Decrees,
… For example, him Royal Decree 1699/2011, of November 18, which regulates the connection to the grid of small power production facilities, or Decree of Net Balance, distributed generation and self-consumption in renewables, mini-wind, photovoltaic, cogeneration, … which starts with unbeatable efficiency intentions, to favor small consumers / producers and above all for the creation of jobs, but with certain initial obstacles in what which refers to the limitation of power (100 Kw) and the definition of the "tolls" to be paid to the electricity companies, which should not be increased by the tariff deficit. With an even more uncertain future, which is also without approval and running out of terms.
along with other movements, which make us have a certain optimism and think that all is not lost, not only because of energy savings, climate change, comfort, well-being, the observance of European Directives,….
Royal Decree 47/2007 on Energy Efficiency Certification partially transposes Directive 2002/91 / CE and I say "partially", because it was resolved without defining the procedures for Existing Buildings, which is what concerns us now, after the pull of ears of the European Commission.
Curiously, this Directive was repealed or extended at the time by Directive 2010/31 / CE, or 20-20-20, a fact that forces us to review the revision of many things, among others of the Royal Decree Project itself. Existing Buildings and CTE HE
… .But for the creation of employment with high added value, or at least to expand, renew and diversify work alternatives. Precisely a few days ago, a somewhat alarming news was published, both because of the compulsory membership or not, and because of the possible change that it may produce in professional attributions:
"The objective set by the Executive is" to strengthen the principle of freedom of access and exercise in all professional activities. " It is intended to remove "unjustified and disproportionate barriers in the provision of professional services", which will favor competition and the provision of services at a better price. "
Who will be the qualified professionals to carry out the Energy Efficiency Certificates for Existing Buildings?
It is very difficult to assess this question. Energy Efficiency is a "Startup", that is, an emerging science that is being seen - and given the crisis - more as a business model, than as a real responsibility with sustainability aspects. We see every day, the appearance of new participants, experts in everything - architects too - who try to jump on the bandwagon, and create a bad image about the concepts of sustainability and efficiency. Everything comes standard, ecological, efficient, sustainable and feng shui: everything is "green".
As a relative innovation, there are no official qualifications. What we do find is a huge amount of masters, courses, "short courses", (most of the available resources are being used for training, often as just another business.) Web pages, blogs, forums, energy agencies and sustainability, very difficult to catalog; without naming the proliferation of systems, materials and even concepts, of various kinds, some of high quality and others not, but in any case they do not "enable" competition in Energy Efficiency. For this, we would have to be qualified experts in ecological construction, in Bioclimatic architecture and its techniques, Renewable Energies and Digital Home, -and many other things-, materials, bio-construction, lighting, facilities, carbon footprint (CO2 emissions), modification behavior habits, health … and learn about the process proposed by other certification models.
And this would allow us to know what really matters in the analysis of CEEx, regardless of norms, laws and decrees: How is the necessary data collection done when doing an energy study? What are the real measures and modifications that we can take, saving and energy efficiency, without reducing performance or comfort? And in the practical case What can we do to increase the energy rating scale of a property?
Being in possession of a higher degree, Engineer - Architect, does not guarantee the knowledge for the elaboration of a CEEx, nor can it exclude other technicians, even more so considering that it is a document that will be reviewed and even corrected by a Control Body . (We see later the art. 6.3) No group has the right to claim the Certification exclusively. However, a "priori" this knowledge is not guaranteed by anyone, and perhaps the least bad solution is the one we will see below, in relation to the LOE. (We can imagine banks or real estate agents including free, the certificate, in the purchase-sale or lease contract.)
What matters now is to try to define what the current situation of the issue is based on the modifications proposed for RD 47/2007:
We consult articles 5.6 and 6 of the Draft Royal Decree itself:
Article 5. Energy efficiency certification of a building.
6. The energy efficiency certificate will be signed by technicians who are in possession of the qualifying academic and professional qualifications for carrying out building projects or their thermal installations, freely chosen by the property of the building.
Article 6. External control.
1. The competent body of the Autonomous Community * It shall establish the scope of the external control of the process established in article 5 and the procedure to be followed to carry it out. This control may be carried out by the Administration itself or through the collaboration of authorized agents for this purpose.
* Contact bodies for the energy certification of buildings
2. Authorized agents will be control bodies or entities that meet the technical requirements established in Royal Decree 410/2010, of March 31, for the exercise of their activity in the regulatory field of building, as well as control entities qualified for the regulatory field of thermal installations, or qualified independent technicians in accordance with the procedure and thequalification requirements, experience, specific training in energy efficiency certification and means established by the competent body of the Autonomous Community.
3. When the energy efficiency rating resulting from this external control is different from the one initially obtained, as a result of differences with the expected specifications, the property will be informed of the reasons that motivate it and a specified period for its correction or presentation of allegations in case of discrepancy, before proceeding, where appropriate, to modify the grade obtained.
To define the "Technicians who are in possession of the qualifying academic and professional qualification for carrying out building projects or their thermal installations" It is necessary to refer to Law 38/1999 on Building Planning, specifically articles 2 and 10, "Scope of application" and "The designer", so that the qualifying professional will depend directly on what they are certifying. Architect, Technical Architect, Engineer and Technical Engineer.
And what is certified corresponds to the Basic Procedure for Certification of Energy Efficiency of Existing BuildingsArticle 2. Scope of application of the PRD CEEx:
1. This Basic Procedure is applicable to all existing buildings, which do not have an energy efficiency certificate when they come into force, when they are the subject of a contract of sale or lease.
2. Existing buildings that are the object of a sale contract (See how to calculate the price of a house) or a lease must have an energy efficiency certificate obtained in accordance with the Basic Procedure that is approved in the sole article.
3. The following are excluded from the scope of application:
- Those buildings that due to their characteristics of use must remain open.
- Officially protected buildings and monuments because they are part of a declared environment or because of their particular architectural or historical value, when compliance with such requirements could unacceptably alter their character or appearance.
- Buildings used as places of worship and for religious activities.
- Provisional constructions with an expected period of use equal to or less than two years.
- Industrial and agricultural buildings, in the part destined to workshops, industrial and non-residential agricultural processes.
- Isolated buildings with a total useful area of less than 50 m2.
- Buildings of technical simplicity and little constructive entity that are not residential or public, either temporarily or permanently, are developed on a single floor and do not affect the safety of people
- Buildings to be purchased for demolition
- Residential buildings that are the subject of a lease for a period of less than four months a year.
1.- It seems curious to think that summer areas with lease contracts of less than 4 months are going to be left without their corresponding Energy Efficiency Certification for existing ones.
2.- The RD 47/2007 will consist, after the definitive approval of the PRD CEEx, of two parts: Finished buildings and Existing buildings. The definition of which is which does not seem clear.
According to a Technical Note from CAT COAC, which, in part, reads as follows:
… .
"Royal Decree 47/2007 was published on January 31, 2007, entered into force on April 30, 2007, but was not mandatory until October 30, 2007."
“Therefore, if a project obtained a visa from the corresponding official College and the application date for the building license with said project is prior to October 30, 2007, the project does not need to justify Royal Decree 47/2007 and therefore For this reason, the completion of the energy efficiency certificate for the finished building is not applicable either. "
It seems obvious that the finished building is the one whose license request date is after October 30, 2007 and it would also seem obvious that the existing ones are those of the previous license request date, (that have not taken advantage of the April-October 2007 period of “voluntariness”) given point 1 of the scope of the PRD CEEx. Among this group of Existing Buildings, and based on the classification by periods of the "Energy Rating Scale for Existing Buildings" (2.1) will be those that do not comply with the CTE HE (prior to 2006 and a wave of projects approved for not complying with it) and between September 2006 and April 2007 and later, those that do comply, with which we will have to use different valuation indices (C1 and C2).
Given that RD CEEx will come into force 20 days after its publication in the BOE, we will also have those "existing" buildings that are not affected by RD 47/2007, which currently and given the prolonged crisis, they are still under construction and that if they are not completed before January 2013 (forecast of the CEEx coming into force) it seems that they will not exist for either RD CEEx or RD 47/2007.
A formal modification of the texts will be necessary to clarify this situation, something like: "RD CEEx is applicable to all buildings that, when sold or rented, do not have an energy efficiency certificate."
It seems even more complex to determine the interpretations that each Autonomous Community makes of Article 6, in reference to External Control. (Department responsible for the Energy chapter) They will be able to validate the results of the certificate, even with modification proposals, and they will grant the final energy rating. (6.3) (Except for Buildings that depend on the Ministry of Defense)
In the case of the participation of authorized Control Entities, its regulation will also come from the LOE (Article 14. The entities and laboratories of quality control of the building and its modification, through article 15 of Law 25/2009) The body responsible for external Control must ensure compliance with the requirements of control entities and laboratories, as well as verify and investigate the results of technical assistance, by virtue of the Royal Decree 410/2010, of March 31, which develops the requirements of building quality control entities and testing laboratories for building quality control, for the exercise of their activity. (6.2)
It is expected that the processes that make up the External Control will be very similar or the same in all the Autonomous Communities and that certain conditions will be established for the professionals who carry out the certification AND for the control,"… qualified independent technicians in accordance with the procedure and requirements for qualifications, experience, specific training in energy efficiency certification and means established by the competent body of the Autonomous Community." That the specific training does not fall on academies or online courses as business models and also that there are no referrals to professionals or consultants highly specialized in communication and information, processing and management of grants and subsidies; but not in Energy Efficiency.
Definitely the only important objective in both certification and control is: advise building or home owners to find professionals versed in energy efficiency and encourage them to take the necessary measures to obtain a certificate with the highest possible qualification, with the necessary aid.
Article prepared byLuis Ruiz de la Fuente Perera (Energy Management Architect) collaborator of OVACEN
