Energy Ratings: comments before submission deadline on October 16th

[Jeff Colley]

The proposed scale of energy ratings for homes is set to be finalised on Monday October 14th. The repercussions of how the scale of ratings are set are enormous. Given that the main focus of the energy ratings are to stimulate the construction industry to stop producing less energy efficient homes and to upgrade existing homes, it's critical that the ratings give a fair impression of how energy efficient Irish buildings are.

Alarmingly, it has been proposed that homes which are designed to meet minimum compliance with building regulations--in other words the worst homes which can be legally built--will get a B rating, on a scale of A to G. But what do you think? Does this give a fair impression of our building standards? Will it encourage the construction industry to deliver genuinely low energy buildings?

All comments posted here, along with the results of the above poll, will be forwarded to Paula Rice, who is heading up the implementation of the directive in Sustainable Energy Ireland.

The following text is taken from a discussion document on the proposed energy rating scale:


6.0 BER Rating Scale

It is proposed to use an “A to G” building energy rating scale, as the scale
A-G is widely recognised for efficiency rating of domestic appliances (e.g.
fridges), including the familiar coloured seven bar method of presentation.
As the rating system must ultimately apply to all newly constructed
dwellings and to all existing dwellings for sale or rent, the scale must cover
dwellings of widely different energy efficiencies and calculated energy
uses– from modern low energy houses to older, poorly insulated dwellings
using inefficient heating systems. This is different to domestic appliances
where the efficiency rating is only applied to new appliances.

Accordingly, each of the A – G ratings on the scale is sub-divided in to 3
categories; A1, A2, A3; B1, B2, B3 etc. This is done to ensure that each
point on scale does not represent too wide a bandwidth and thus to ensure that
improvement measures undertaken are reflected in a clear
improvement of position on the scale.

The scale is constructed so that dwellings designed to achieve
compliance with minimum standards prescribed by Part L of the
Building Regulations (2002/2003) are generally expected to be given a
“B Rating”. This approach is preferred to that recommended in Draft
European Standard (pr EN 15217) which deals with energy rating i.e. that a
building code compliant dwelling should be placed on the boundary
between B and C (as in UK). It is considered that a scale so constructed
could give a confusing message as it would then be largely chance whether
an individual Part L compliant dwelling would be rated B or C.

The scale proposed provides adequate “headroom” for;
• future improvements in Part L thermal performance standards. (A review of Part L standards for New Dwellings must be completed by 2008.) and

• innovative low-energy dwellings to achieve higher ratings than those which are “compliant” with the current Building Regulations.

[heinbloed]

That's typical.
Not ruining the business of those who are ruining our future, i.e. the dodgy builders and speculators. Is it not logic that the consumer wants a number, i.e. kWh/m2 of habitable space/a ?
A pill that isn't bitter to swallow won't cure......
And with the building regulations currently in place this energy demand number is not even specified......
There a reasons why all goods bearing an energylabel have to show their energy demand. In Watts.
We're now in the trouble with A+ and A++ fridges and freezers. How many "plusses" would an "energy plus building" receive, one that generates more energy then it consumes? For each kwh one " + "symbol? And a boiler house? A powerplant? Or would that be then " - " symbols?! Weird.
On the EU continent factory/office/barn roofs are rented out to investors of photovoltaic powerplants, the going rate is 1€/a/m2. How would such a building be classified under the proposed "idea" , when the energy produced within or on top of the building is sold on and not consumed within, i.e. not available to the actual habitant? As would be the energy derived from a windgenerator, a PV plant or a (gas)fired combined heat and powerplant selling electricity to the grit employed by the occupier?

This must be an Irish idea, wall papering a building with "+" symbols to show how efficient it is. How would I advertise a power plant that is for sale, let's say a 500 MW plant? Order an entire own issue of a daily paper from the printer to show all the plusses in the advertising? Funny.

We need numbers, not symbols. The ESB and the fueltraders don't show their bill in symbols either, they want hard currency for metered goods.
The entire idea is ill prepared, creating a job for the future for the one who messed it up in the first place. A waste of taxpayer's money. And not leading to any usable information for the consumer.

And for those consumers who are not fit to shop around when going on a shoping spree:
When the € was introduced the gouvernment handed out little calculators. Only two functions where allowed on these: IRP versus € and vice versa.
The gouvernment did not demand shop keepers to put little plus symbols on the goods......
A small mutifunctional calculator is already available with every auctioneer. This would allow everyone who puts a building up for sale to tell the would-be-buyer in laymen terms how many liters of oil per year would come on top of the mortgage. This number could be shown in the contract of sale/lease/rent. With absolutly no cost to the taxpayer.
But that's not what is anticipated - saving.

[Patrick Daly]

I have a number of criticisms of the scale.

1. The rating of Building Regulations at B supports the mis-conception that Building Regulations are ‘advanced’ or ‘high quality’ which in my opinion is misleading. Building Regulations are a MINIMAL standard, which should be reflected in any rating. A D Rating would be more suitable.

2. The positioning of Building Regulations at ‘B’, with a typical house coming at B2 (approx 125kwh/sqm/y) means that developers can get into the ‘A’ class (A3) just under 90 kwh/sqm/yr, with relatively modest improvements.

3. The grouping of the ‘classes’ into what is effectively a 90kwh/sqm/yr band will blurr differentiation within the band, which is especially critical within the A band. Meaning that if you have a house at 89 kwh/sqm/yr you will be A rated and if you have a Zero Energy house at 0 kwh/sqm/yr you will also be A – albeit A1.

4. The fact that the increments are in equal portions, especially at the higher bands fails to differentiate between the ‘scale of task’ required to reduce energy as you go up the bands. The additional and specialist design input to get from 50 to 25 kwh/sqm/yr (A2 to A1) is in no way comparable to the simplier task of getting from 250 to 125 kwh/sqm/yr.

5. CEN have drafted a proposed standard prEN 15217 which includes a proposed method of calculation and classification of a member states rating scale based on thresholds between classes relating to the average of the existing housing stock. It would be interesting to know if this proposed rating is based on the prSEN 15217 standard or if SEI have examined a classification based on this method and what it would look like? And if not why not?


In summary, given that the EPBD is principally intended to be a market stimulator, the proposed rating scale is, in my opinion’ not acceptable and will be a missed opportunity to promote advanced energy housing, in that the proposed rating scale lacks sufficient differentiation of banding, is not reflective of increased challenges to move up the scale, strongly promotes Building Regulations as an advanced rating, which it is not, and facilitates an easy move to the A band for developers.

Patrick Daly
Lecturer in Environmental Design DIT School of Architecture.
Environmental Consultant BESRaC

[Tobler]

Not being directly involved in the trade and renting a house at the moment that complies with minimal standards it seems incredible that such a house should be rated B. A B rating conveys to the consumer that it is well insulated and has good ratings, after all it is the second highest grade. If a grade B is given to houses with minimum standards it completly misses the point of the grading system and is a joke. There are so many items that could be imporoved upon in this two year old house we are living in at the moment that a D or low C rating would be appropriate.

[Niall Leahy]

I agree with the previous thrust in general that this scale is inadequate.

Patrick's point that the increments being in equal proportions is not reflecting the effort required to improve the rating the further up you go is hugely significant, yet SEI, when acknowledging this fact in a public talk, replied that the colour scale looks nice and curved when done this way, and that it would look better to the general public. It makes it sound like a cosmetic marketing exercise for them rather than any real commitment to encourage sustainability.

If the current minimum standard Building Reg house were to get a D rating, as the poll would propose, then a D2 (middle D) rating might ensure some consistency rather than a borderline B / C in the UK.

[carbonnet]

We're lossing the plot here guys -

What's you main concern
Reducing CO2 as a goal? or are you being evangelical in architectural design?
I honestly think that we should accept the EPBD & DEAP for what it is - design tools only.

The rating system has been enforced on us by the EU - thank God - a great idea.

But the directive recognizes THAT THE GREATEST POTENTIAL FOR CO2 SAVING COMES FROM EXISTING BUILDINGS - not new ones. New ones (Built in accordance with the design off course - thats a different and more important argument!) will perform vastly better that what we've been used - a 'B' for example creating around 2 tonne of CO2.

An A rating will save around 1/2 to 1 tonne extra -which I must stress - we should strive for - but the real goal is to bring existing stock up to these levels to make any impact on emissions.

We've improve the DESIGN PERFORMANCE greatly from the early 90's with the changes to the building regs - but in the samer period we're creating far more CO2 in the way we use the buildings - plasmas ipods etc have increased co2 by over 20%!

The differnce in CO2 from an to A to a B is very little in CO2 terms - by concentrating on the this debate the rest of the story is forgotten - real savings! - let look at how the dwelling is used (and car/flights etc)

[carbonnet]

Just as an after thought,

Which would be of greater benefit?

Giving developers grants to put in renewables (thru' SEI schemes etc) and relying on these limited life technolgies to save the extra 1/2 tonne of CO2 and achieve the A. (B to A?)

Or

Granting the developer to upgrade the existing houses around the corner from his site with condensing boilers, better glaing) extra insulation and better heating controls and draught stripping?

(4 to 5 tonne savings? G to C?)

[johnkilgannon]

Using such a high rating for the existing housing stock does not allow innovative energy saving developments to have an impact on the market. Buildings built to the current building code on thermal insulation should only be given a D rating at best.

[carbonnet]

Using such a high rating for the existing housing stock does not allow innovative energy saving developments to have an impact on the market. Buildings built to the current building code on thermal insulation should only be given a D rating at best.

Existing housing stock will not have a high rating if they are not energy efficient - thats the point bring them up to the new build standard and lets concentrate on getting the new build standard delivered on site.

We all, those that make comments on this site, agree that much more can be done to deliver BETTER than current new build standards- lets do it, but CO2 emssions will be cut only if industry not individuals take the correct path - the energy labels allow for this. The rest of use (a small minority can come up with our own labels if we want to)

[heinbloed]

Sorry, Carbonnete, but you propably have not understood the issue(smiley).
First: Not the energy rating SYSTEM had been "enforced" by the EU-with the Irish comissioner's and parliamentarians aid- but the energy rating as such. Not the way the rating is systemised. With obsolete stickers like the proposed one.
Second: The greatest potential for CO2 savings come from increased prices for "the stuff" carbon. From nothing else.
Third:The building regulations existing or planned for the future won't be the last ones. There will be building regulations for the rest of our civilisation. The existing ones would look in 50 years like a 50 year old joke. Our existing carbon saving efforts in the existing buildings with our existing building regulations will be useless for our children. We and them will turn every available molecule of carbon into carbondioxide-as long as it is worth it.
Therefore it makes sense to let those suffer who have speculated on cheap carbon burning . Suffering by loosing parts of their ill-thought after, badly invested capital-the value of their building. This capital is the badly constructed building, the building that is hooked to the boiler as a junky is hooked to the needle. As is it's ownwer.

Let the financial sufferer be a sample for others-that is the intention of the energy labeling of buildings. Nothing else.
Zero energy buildings and energy plus buildings are no future phantasys of some designers, they're being build every day. Without coloured energylabels-simply by logic decisions made by the consumers, the purchasers.
20 years ago a zero energy building was considered as the fantasy of some Star Treckys. But none of these building ever stood empty. They're most thought after. And if(!) they're up for sale then an advertising in the papers or a fee for an auctioneer is simply not neccessary. That saves even more.
These zero energy buildings and their designers deserved to be admired. The standard crap still legally allowed to be build deserves the financial sledge hammer. Which would be a clear pricing label. Which is legal standard in the Republic of Ireland since the 19th century.

[carbonnet]

It's Ireland we're talking about here - all the regulations that are signed up to just isn't going to happen on site. So it is up to the likes of those that believe in what we're discussing to come up with an alternative - perhaps independent way - of labelling our builds.

Throwing consumer must have's 'the ipods of green architecture' GSHP wind turbines etc isn't going to get the result we need - a substantial reduction in CO2 for Ireland - BUT IT'S BEING PERCEIVED AS HAPPENING.

Ratings will encourage those who build 3000 units a year to improve things (Slightly I'm sure) which is good - because sure as hell enforcemnt of building regulations doesn't work in Ireland (The big question here is who will calculate the labels!)

Increase in prices for carbon - will be the driver - but we're rich in this wee country - will still have the towel rails, plasmas and outside lights what ever the price (It's the well to do that are buying the GSHPs)

Buildiong Regulations 50 years from now will be treated as they are now - ignored.

Zero carbon buildings can be built but saving that 2 tonne whilst having a second home in Budapest and flying there 3 times a year is bit of a waste of time.

it's like changing from ordinary bulbs to EE - whilst you're neigbours boasts that he puts up 200,000 light bulbs at Christmas - kind of depressing.

Lets not get caught up in the Label categories - welcome it as a good sarting point - and take a voluntary code further?

I didn't mention carbon rationing - any body up for it?

[Century Homes]

The proposed rating scheme which would designate houses built to the current Building Regulations as B rated is in appropriate, and not in the spirit of the Energy Performance of Builings Directive for the following reasons.

1. A B Rating for current regulation compliance implies that current standards are of a "HIGH" standard and will mislead the general house buyer

2. A B rating does not provide sufficient incentive for developers/builders to improve the Energy Performance of their buildings

3. I agree with a previous contributor that the existing housing stocks performance is a major issue, however in the case of Ireland we have the most prolific new house building market in the western world and will continue to have for the forseeable future with over 500,000 new dwellings lilely to be built over the next 10 years. Despite the fact that we missed the boat on the last ten years it is incumbent on everyone in the industry but particularly on the Government to ensure that those 500,000 houses are built to the highest standards possible for a number of reasons,

a. millions of tonnes of co2 could be saved,

b. reliance on imported fuels could be reduced

c. thousands of Euros could be saved by each house owner

e. and the value of these houses cou;d be protected

4. We have already had a situation over the previous 5 years where the Government willfully delayed improved erergy efficiency standards to protect the hollow block construction method. It is time we lived up to our commitment under the Kyoto Protocol and The EPBD and set a fair and approriate standard for current houses which in school exam terms is only a pass standard a "D" standard and encourage the construction industry to use energy efficeincy as a marketing tool as intended by the EU with the EPBD.

In conclusion it is time "Sustanable Energy" Ireland lived up to its name and made a bold statement that energy efficiency matters and call a spade a spade. A house built to the current standards does not deserve to calssified in the B1, B2, B3, standard. It is a pass standard, quite clearly a "D". Encourage people to save energy energy, after all the most "sustainable energy" is saved energy.

Yours truly,

Gerard McCaughey
Chief Executive
Kingspan Century

[heinbloed]

I fully agree with the critics of the proposed rating standards.
But compare like with like: a Tungsten bulb-the most frequently sold, legally offered "standard" bulb - is classified as an "F" in the energy rating label.
Why not so the most frequently legally offered "standard" building?......
And who cares?
Most people know that it pays to get an energy saving bulb installed instead of an CFL bulb.
But they don't buy it.
That is because a colourfull sticker is not a discouragement to act ignorantly. Any marketing specialist will tell us the same.
Putting facts first - money in numbers - will make a difference.
To save on CO2 - on energy - it has a consumption discouraging effect when one knows how much difference it makes between Buy A and Buy B. In €s.
So saying on an energy certificate: "This building will cost you 1000 litres of heating oil per year on top of your mortgage" makes a difference. Hardly anyone in our population will make a calculation containing square meters, kilowatts and percentage on heating efficiency to get a total sum.
Our average homebuyers are kept in ignorance from early days on.
But most of them know what a hole in the pocket a thousand liters of oil can cause.
And that will give them the choice for the smaller hole. Eventually to the smaller house, the smaller car etc.. . To the smaller CO2 output.
But that would hurt vested interests..... those of the political donators. For whom is SEI working? The SEI building is made from concrete, see http://www.sei.ie/index.asp?locID=22&docID=-1 . Is the SEI willing to classify their own building, making public the energy demand of it? Or would that make some decision makers involved in it's construction/planning look incompetent? Would the concrete not have been suitable for that? I take it that the proposed energy label is a hedge to hide behind......

[carbonnet]

96m2 Semi Detached B - 2 tonnes CO2
96m2 Semi Detached A - a 0.4 tonne saving the difference isn't that much

300m2 A rated house in Galway - Construct Ireland Current issue - 4 tonne - and it's an A

If its the CO2 we're concerned about lets tackle it - where it will make a difference - its not the difference between A's & B's