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www.heatingandventilating.net


Water heating


Water heaters join air quality battle


New emissions limits for water heaters could make a significant contribution to cleaning up urban air pollution, according to David Pepper, managing director of boiler, water heater and heat pump company Lochinvar


T


he High Court has once again ruled that the government’s plans for cleaning up air pollution in our cities are unlawful. This is the


third time the environmental law firm ClientEarth has taken legal action over air quality and the third time judges have ruled against the government by deciding that current policy does not go far enough. This is despite a £3bn programme being put in place last year to tackle emissions from vehicles and create ‘clean air zones’ around the UK. Air pollution remains a highly emotive issue, which is not surprising as it is linked by health experts to 40,000 premature deaths every year in the UK. Most British towns and cities are in breach of World Health Organisation (WHO) air quality guidelines. Emissions from transport tend to take the brunt of negative publicity and most of the political heat, but concentrations of NOx – nitric oxide (NO) and nitrogen dioxide (NO2) – created by heating products are also in the spotlight. According to the City of London Corporation, non-domestic gas consumption is responsible for 33% of NOx emissions in central London – so our industry does have a significant role to play in improving urban air quality. NOx is a by-product of combustion – created by


both transport and heating sources. The WHO says there is no safe limit for this type of airborne particulate, which has been linked to a range of respiratory and cardiac conditions.


Limits


Growing concern about NOx is reflected in planned legislation with this September seeing the introduction of the next phase of the EU’s Energy Related Products (ErP) Directive, which imposes NOx emission limits on water heaters for the first time. The ErP has been in force since September 2015 and is being introduced in stages. The next phase, from September 27 this year, will require all water heaters to meet or beat a new NOx emission maximum of 56mg/kWh. However, as often happens in our industry, there seems to be some confusion about this. It is true that the new regulations increase the current minimum efficiency levels, but these are still low and most current products on the market will meet them. This phase of ErP is more about NOx emissions and the new maximum levels


www.heatingandventilating.net


David Pepper, managing director of boiler, water heater and heat pump company Lochinvar


could have particularly significant implications for the UK water heater market. Currently, around 50% of storage water heaters sold in the UK are atmospheric models, which do not currently meet the new NOx limit. Unlike the non- domestic boiler market, which is now almost totally condensing, there is still a high demand for replacement atmospheric water heaters. Most of these replacements are distress purchases, which means that the primary, and sometimes only, concern for many end users is to get the building’s hot water supply up and running again. However, the new ErP regulations may mean that some building owners or occupiers will run into problems. All newly manufactured products will have to meet the new emissions standard after 27 September 2018. It will still be allowable to sell existing stock, which could create some breathing space, but after that some end users may find it


more difficult to replace an atmospheric water heater than they may currently imagine. To owners of restaurants, hotels, leisure centres,


care homes etc. having no hot water available is an alarming prospect, which is why the quickest fix is often the preferred solution. From an efficiency and emissions viewpoint, a better solution will be to switch from an atmospheric model to a higher efficiency condensing alternative. However, making that switch is not always straightforward. For example, a complete new flue system might be needed, which can be practically and technically challenging as well as adding substantial cost. Some end users are aware of the many benefits of installing modern high efficiency water heaters and are already in the process of switching over to condensing systems across their estates, but many are not – and a large number of smaller organisations will not have budgeted for this. Many may be shocked to learn that they can no longer simply have a like-for-like replacement.


Choice


So, while it is important the industry continues to steer people towards higher efficiency systems wherever possible, we also have a responsibility to give clients a choice so their businesses are not undermined in the short-term. It is often argued that small businesses have greater difficulty in dealing with the economic impact of complying with legislation. We, therefore, should bear in mind the


practicalities of any major technological shift like the one prompted by the ErP Directive and its impact on the day-to-day operation of thousands of businesses around the UK – and we don’t want to see the situation arise where some end users feel so desperate they resort to sourcing a product from an unregulated supplier. However, in offering this choice we must also


make sure we don’t undermine the laudable ambition of the legislation to reduce energy use and air pollution. Therefore, it is important that we continue to improve and enhance existing atmospheric technology, while encouraging longer term switching to higher efficiency condensing alternatives as we manage the transition to a new generation of lower emission products.


April 2018 37


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