Opinion: Regulations do your meters fit the bill? New regulations covering metering and billing for distributed heating, cooling, hot and chilled water will be enforced from April. Hywel Davies explains what needs to be done in a short time Hywel Davies, technical director of CIBSE www.cibse.org now kW today kWh Most multi-apartment buildings will have meters by the end of 2016 New regulations that make it mandatory for meters to be installed in a large number of building types have been introduced. The Heat Network (Metering and Billing) Regulations 2014 were made in December 2014 to implement various requirements of Articles 9 to 12 of the Energy Efficiency Directive. These cover the supply of distributed heat, cooling, hot and chilled water from most district heat networks and communal heating systems throughout the UK. The regulations apply to most networks, in the residential, commercial, industrial and public sectors (see panel What is in the scope of the regulations below). The Energy Efficiency Directive (EED), which is also the reason for the introduction of the Energy Savings Opportunity Scheme (ESOS) in the UK, was adopted to promote energy efficiency in the EU further, and to contribute to the achievement of the EU 20:20:20 targets for energy savings and carbon emissions reduction. In the introductory sections of the EED, the recitals, it is noted that provisions for metering and billing in several earlier directives on energy saving have had limited impact. It suggests that in many parts of the EU these provisions have not led to customers receiving up-to-date information about their energy consumption, or regular billing based on actual consumption, to enable customers to regulate their energy use. For space heating and hot water in multi-apartment buildings the lack of clarity of these provisions has led to numerous complaints. Under the Metering and Billing Regulations, from 18 December 2014, any person supplying and charging for the supply of heating, cooling or hot or chilled water (a heat supplier) to a final customer has had to comply with the regulations, if they are supplying through a central source, in a building occupied by more than one final customer (known as communal heating), or through a district heat network (DHN) to multiple buildings or sites. The obligations come into force in stages until 2016, and the Department for Business, Innovation & Skills (BIS) has indicated that the National Measurement Office, which has responsibility for enforcing the regulations, will not take enforcement action before April 2015. The initial requirements compel anyone operating a DHN to notify its location, the buildings supplied and the number of final customers supplied. Where only one final customer occupies a building served by a DHN, meters must be installed to measure the consumption of heating, cooling or hot water by that customer, unless it is not cost-effective or technically feasible to do so. The regulation states that where existing meters that are part of a DHN or communal heating system are replaced, they must be exchanged for a meter that accurately measures, records and displays consumption by the final customer, unless it is technically impossible to do so, or the cost is unreasonable. If a newly constructed building is connected to a DHN, or a building on such a system, undergoes major renovations that include the building services equipment, then a sufficient number of meters must be installed to measure the consumption of heat, cooling or hot and chilled water by each final customer. From 31 December 2014, operators of DHNs have had to provide accurate bills and billing information based on actual consumption, and be compliant with the requirements in Schedule 2 of the regulations. Annually, at least, customers must be issued with a bill based on a meter reading not an estimate and, if opting to receive electronic billing information, this must be provided quarterly. Where the estimated reasonable cost of issuing such information exceeds 70 per final customer, per calendar year, the heat supplier is relieved of this obligation. From 31 December 2016, DHN operators must install meters in buildings where they supply more than one final customer, unless this is not technically or economically feasible. In this case, they must install a hot water meter, as well as heat-cost allocators and thermostatic valves at each room-heating radiator, in order to determine and enable each final customer to control their consumption of heating. Once again, the heat supplier does not have to do this if it not cost-effective and technically feasible. In this case alternative methods may be used to determine charges for the supply. It is perhaps unfortunate that when developing the implementation of this aspect of the directive, government did not emulate the Department of Energy and Climate Change in its engagement and consultation with industry over Article 8 and the ESOS regulations. The consequence is that industry has just discovered the requirements under the metering and billing regulations, with implementation deadlines that will be applied almost immediately. So, in summary, most multi-apartment and multi-purpose buildings with central heating or cooling, which are supplied from a district heating network or a central source serving multiple buildings, will be affected. They will have to have individual meters installed by 31 December 2016, to measure the consumption of heat or cooling, or hot water, for each unit where technically feasible and cost-efficient. It is perhaps very timely that CIBSE is revising its guidance on sub-metering for buildings; it may well be in demand over the next two years. what is in the scope of the regulations? Guidance from the National Measurement Office (NMO) suggests that the regulations will apply to a wide range of buildings, including: Rented accommodation with a single heat source supplying multiple dwellings Houses converted into flats/bedsits relying on the original heating system Shopping centres Sub-let space such as fitness centres or restaurants in hotels or third-party vendors in supermarkets Industrial sites where a contract exists for the supply of heat, for example to an adjoining plant. The NMO also suggest that the regulations apply to: University halls of residence Sheltered and social housing Residential care homes Shared offices. It is not yet entirely clear whether these are only in scope where there is an explicit charge for heating or cooling, or whether the existence of a service charge that includes heating and cooling falls in scope.