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The CIBSE Code of Practice was designed to improve standards in community heating provision, but to do so it must be implemented as widely and consistently as possible.
At the moment it is only compulsory for CIBSE members, and even then there are questions over how the standards outlined in the Code should be enforced. Without some form of monitoring and compliance oversight, adherence could be patchy, undermining the purpose of the Code.
There are already a number of benefits in membership of the CIBSE and complying with the Code, including reputational, financial and around customer satisfaction. The Code helps get the right sized plant and network installed for variable usage, to achieve high operational efficiency through low heat network heat losses, and consistently low return temperatures and flow temperatures. It sets standards across the energy centre, heat network, building connections and building heating.
In the longer term, the Code is likely to become intertwined with building regulations, and heat networks that comply with the Code could be treated more favourably under Standard Investment Procedure (SAP) – a government organisation which measures the energy rating of residential dwellings.
However, without some form of systematic enforcement of the Code, no scheme can be guaranteed to be Code-compliant, and so cannot be referenced by SAP.
There are various options available to persuade heat network operators to stick by the Code, including both penalties and incentives. Non-directed intervention such as education can be used as a pull factor to encourage adherence, while at the other end of the scale, directed intervention including sanctioning can be used to push heat developers into line.
Proportionate action can be taken using rising levels of severity, beginning with formal warning, enforcement undertaking and compliance notice. At the other end of the scale, this can move on to non-compliance penalties, formal caution, followed by court action and publicity.
Within this context, implementation needs to be monitored on a regular basis, with minimum requirements assessed and at the end of each project stage. This could involve self-certification, where project teams give assurance that they’ve followed the Code at each stage, accompanied by evidence. Alternatively, third party assessors might inspect statements and evidence packs and provide independent assurance that a project complies.
To make this all work, the compliance regime will need to be focused on clear performance targets - against which measured data can be compared - along with some softer requirements such as the Heat Trust principles of customer protection.
As the scheme proceeds the targets must be checked. If they pass, the client gets a good network, and the project is guaranteed to be Code-compliant so can be used in SAP scores, building regulations compliance, financial guarantees and elsewhere. If they don’t pass, the team should put it right or fail to comply, which could also be linked to practical completion and payment.
To assure adherence, heat providers must be measured against the Code, penalised for poor performance and forced to remedy failings. Whatever compliance regime is chosen, it must include the key ingredients that result in better networks, and must be strict enough to stop poor projects achieving compliance.
Without a strong, demonstrable commitment to quality - with the right carrots and sticks to support this - the industry runs the risk of losing credibility and developing a poor reputation requiring ever more stringent regulation.
Takeaways
- The CIBSE Code of Practice will only achieve its purpose if it is implemented across the industry
- Following the Code already brings benefits, but ensuring compliance would bring many more
- Both incentives and penalties are available to encourage adherence to the Code
- Monitoring and assessment needs to be carried out against clear measurable targets
- Schemes not achieving compliance should be obliged to correct problems, and poor schemes cannot be allowed to slip through the net
- If the Code is not implemented effectively, tougher regulation may be imposed
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