Revision of Building Regulations Part J

EPA Submission to the Department of the Environment, Community and Local Government's public consultation.

Summary: EPA Submission to the consultation by the Department of the Environment, Community and Local Government on the Revision of Part J of the Building Regulations. The submission was prepared by the EPA Air Cross Office Team and considers options to reduce and prevent air pollution from domestic heating. This includes energy efficiency measures.

Published: 2012

ISBN:

Pages: 14

Filesize: 434KB

Format: pdf

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Summary of recommendations

  • Decreased particulate levels result in positive health effects with policy measures to reduce particulates typically found to have a positive health benefit from a costs/benefit analysis viewpoint;
  • Combustion of fuel in open fires is very inefficient and results in significant emissions of pollutants to the atmosphere as well as indoor air pollution issues. Where domestic combustion of solid fuel is being carried out in open fires, policy measures should be considered to incentivise a switch to more environmentally and energy efficient systems, including enclosed solid fuel appliances.  Strictly from an air quality viewpoint, increasing the penetration of natural gas supply across the country should also be considered as a preferred option as emissions from natural gas combustion are lower than from solid fuel stoves;
  • Measures should to be taken to reduce the nuisance associated with the locations and heights of solid fuel appliance flues. In cases where houses are located adjacent to each other (i.e. terraced, semi-detached or detached houses within close proximity to each other) the minimum height should be specified at a height greater than the roof ridge height of the adjacent house and in compliance with the requirements in the building regulations with regard to separation distance from combustible materials;
  • The requirements of the building regulations need to be robustly enforced to ensure that installed heating appliances meet all required standards;
  • The requirements of the building regulations in relation to heating appliances needs to be publicised to increase public awareness of the minimum standards;
  • The applicability of using the Building Energy Rating Sytem (S.I. 666 of 2006) for the purpose of solid fuel heating sytem enforcement should be investigated (e.g. not issuing certificates where installed stoves fail to meet minimum specified standards);
  • Given the significant increase in usage of stoves in Ireland for space heating it is critical that minimum efficiency standards should be specified in the building regulations for solid fuel heating appliances (and also for other appliances operating on gases and liquids). Such standards for solid fuel appliances include (see full references below): 
    • EN 13229 (Inset appliances)
    • EN 13240 (closed fire)
    • EN 14785 (pellets)
    • EN 15250 (slow heat release)
    • EN 12815 (cookers)
    • EN 12809 (Space heaters with indirect heating functionality)
  • There is significant ongoing discussions at a European level in relation to specification of design and performance standards for solid fuel stoves. This work should be considered carefully by the DECLG as part of the Part J review process.
  • There is ongoing research in the area of emissions from small scale combustion sources and the relevant regulations and guidance should be reviewed and updated regularly to reflect advances being made in the performance of domestic heating technology. The EPA will submit any outputs from these research projects to the DECLG to assist in informing policy decisions.
  • Other complimentary measures to improve air quality should also be considered, such as increasing public awareness of the health and economic benefits of efficient use of solid fuels (including maintenance and flue cleaning), better regulation of solid fuel burning appliances and their emissions and the continuation and development of the grant scheme for home energy efficiency.