Specifiers Journal 2015-2016

Another area of uncertainty is the
status of the regulations for gas and
oil boilers between 400kW and 1MW,
and solid fuel boilers between 500kW
and 1MW (the latter being covered
under Lot 15).
This is because larger boilers (1MW
to 50MW) have to comply with the
Medium Combustion Plant (MCP)
Directive – so there is a large gap
between the 400kW gas and oil
boilers covered by Lot 1 and the 1 MW
boilers covered by the MCP Directive.
There is a similarly large gap between
the solid fuel boilers up to 500 kW
covered by Lot 15 and the MCP
Directive. In fact, the original draft
document for Lot 15 had a scope up
to 1,000kW but this was reduced to
500kW in a subsequent draft, to fall
in line with the current standard –
EN303.
Implications
Clearly these areas of uncertainty
represent a major headache for the
manufacturers as a lack of clarity
makes it difficult to reach informed
decisions about where best to make
future investment in production.
However, it is not just manufacturers
that are affected as the absence of
a clear policy potentially creates
issues for specifiers and installers
as well. For example, it could
potentially encourage the use of
less efficient boilers in the range
between 400kW and 1000kW
as these will only have to meet
existing regulations. Similarly, if the
specification is for a 1.2 MW boiler
it would fall within the remit of the
Medium Combustion Plant Directive,
whereas 2 x 600kW boilers would
not necessarily be covered by the
new regulations.
Moreover, a specifier selecting
separate boilers and burners under
400 kW has no meaningful guidance
as to what performance criteria
will ensure compliance. This could
lead to specifications as vague as
‘in accordance with the Ecodesign
Directive’.
As well as relating to efficiency, the
Ecodesign requirements also set
limits for emissions. In the case of
solid fuel boilers that come under
Lot 15, emissions levels are at such
a low level that current designs will
find it very difficult to comply. For
example, to ensure that biomass
boilers meet particulate matter
(PM) levels the most effective
solution will be to add filters in the
flue outlet on the boiler. These will
require more plant room space and
will add to overall costs.
Looking to the future
Whilst this article focuses on areas
of uncertainty the situation isn’t all
doom and gloom. Progress is being
made in these areas and there is
good reason to believe these issues
will be resolved in the near future. To
help achieve this, associations such as
ICOM continue to work with regulatory
bodies throughout Europe to steer the
regulations in a direction that works
well for all stakeholders.
Further information: www.icom.org.uk
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