ᐅ Air-to-water heat pump without buffer tank | Heating contractor refers to building energy regulation requirement
Created on: 8 Feb 2022 11:48
S
Stravanzer
Hello everyone,
I have used the search function but couldn't find any information on my issue.
Our current building project is still in the planning phase. We are constructing a single-family home (KFW 55 EE) through a general contractor. Everything is arranged so far, the KfW funding is approved and confirmed. So far, so good! The trades are currently being discussed, and I am in a dispute with the heating engineer commissioned by the general contractor.
Content of the scope of work:
Air-to-water heat pump with electronic radiator thermostats (ERT) and buffer tank, etc.
My execution request:
An air-to-water heat pump without ERTs and buffer tank, as I want to use the “self-regulating effect” (calculation of the hydraulic balancing or the minimum/total volume flow to avoid using a buffer tank and bypass valve in the hydraulic system, in order to heat the house more energy efficiently).
Also, the ERTs in the individual rooms should not be connected or only installed as visual elements.
The heating engineer says that, due to the current applicable energy saving regulations, he is not allowed to install the air-to-water heat pump without a buffer tank. If the inspection by the energy consultant has yet to be completed, it would not be approved because of the missing equipment (buffer tank + ERTs). He insists on a buffer tank!
What options do I have as the client to still receive an air-to-water heat pump without a buffer tank and ERTs? Is there actually an inspection by the energy consultant? Is this common?
Maybe the community here has some tips or possibly even a solution? Thanks in advance for any help.
Best regards,
Tom
I have used the search function but couldn't find any information on my issue.
Our current building project is still in the planning phase. We are constructing a single-family home (KFW 55 EE) through a general contractor. Everything is arranged so far, the KfW funding is approved and confirmed. So far, so good! The trades are currently being discussed, and I am in a dispute with the heating engineer commissioned by the general contractor.
Content of the scope of work:
Air-to-water heat pump with electronic radiator thermostats (ERT) and buffer tank, etc.
My execution request:
An air-to-water heat pump without ERTs and buffer tank, as I want to use the “self-regulating effect” (calculation of the hydraulic balancing or the minimum/total volume flow to avoid using a buffer tank and bypass valve in the hydraulic system, in order to heat the house more energy efficiently).
Also, the ERTs in the individual rooms should not be connected or only installed as visual elements.
The heating engineer says that, due to the current applicable energy saving regulations, he is not allowed to install the air-to-water heat pump without a buffer tank. If the inspection by the energy consultant has yet to be completed, it would not be approved because of the missing equipment (buffer tank + ERTs). He insists on a buffer tank!
What options do I have as the client to still receive an air-to-water heat pump without a buffer tank and ERTs? Is there actually an inspection by the energy consultant? Is this common?
Maybe the community here has some tips or possibly even a solution? Thanks in advance for any help.
Best regards,
Tom
Stravanzer25 Apr 2022 11:57Hello everyone,
I’m giving you an update and a brief summary in case any of you are also considering applying for an exemption from the ERR.
Also, the title of this thread isn’t quite accurate. Since 2020, the Energy Saving Ordinance no longer applies; instead, the requirements of the Building Energy Act have been in effect. This means that our construction project is subject to this new legislation... and this law has made the ERR exemption process even stricter. So, applying for the exemption involves additional effort!
A brief timeline of our experience:
- We commissioned the well-known engineering firm "H******n" to perform the heating load calculation (including a standard letter). It took about 4 weeks to receive the complete documentation. They are currently very busy, so expect longer waiting times.
- Once we received the documents from the engineering firm, we informed the responsible district office about the situation and submitted our application for the ERR exemption. I should mention that the authority initially did not understand the request at all, and we were likely the first to submit such an application.
- After about 10 days (following our inquiry), we were informed that the case was now known internally and they understood how to handle it. At that point, we also received a file number, meaning the application was officially activated.
- We then sent the heating load calculation including the standard letter to the district office. Receipt of these documents was confirmed... and then nothing happened for some time. When we asked about the status, we received the following information:
"You have applied for an exemption from room-specific temperature regulation, regulated by § 63 para. 1 of the Building Energy Act; the legal basis for the exemption is § 102 para. 1 of the Building Energy Act. The district office XXX is responsible for enforcing the Building Energy Act as the lower building supervisory authority (§ 2 para. 1 sentence 1 AVEn). § 7 para. 1 sentence 1 AVEn specifies that the fulfillment of the requirements for an exemption according to § 102 para. 1 sentence 1 no. 1 or no. 2 alternative 1 AVEn must be certified by an expert as defined in § 3 para. 1 AVEn."
Specifically, the following is now required:
Possibly, the heating load calculation from engineering firm H******n, signed by Mr. XXX, could be accepted as such a certificate. However, the prerequisite is that Mr. XXX provides the district office XXX with the appropriate proof of qualification. If Mr. XXX is not an expert as defined by § 3 para. 1 AVEn, you would need to submit a corresponding certificate from an expert, including proof of their qualification.
- After inquiring with the engineering firm whether the calculation can be signed as requested by the district office, the answer was no. (Presumably because the required qualification as an expert according to § 3 para. 1 AVEn is possibly not available within the company.)
- We then started searching for an "expert according to § 3 para. 1 AVEn." That was an adventure, I can tell you. Most of the so-called "experts" didn’t even understand what we wanted when we explained the matter. "...that’s the story with 'experts'..." We had to try several times before we found someone who immediately understood the issue and could provide the required certificate.
- We then submitted the outstanding confirmation to the district office. Within 3 days, we received the official ERR exemption by mail (stamped and everything).
Conclusion:
It is doable, but it definitely requires a lot of persistence and time. If you are already under time pressure, it’s hardly worth it! So, start dealing with this topic early!
My personal opinion: --- Bureaucracy at its finest! ---
First, an independent expert has to issue a certificate prepared by a specialist in this field! So, the specialist is not trusted initially... It somewhat reminds me of "Asterix conquers Rome" and the "Passierschein A38" task.
Not to forget that besides the time involved, there are also monetary costs!
This process ultimately cost us around €950.
Good luck to all future homeowners considering applying for an ERR exemption.
I’m giving you an update and a brief summary in case any of you are also considering applying for an exemption from the ERR.
Also, the title of this thread isn’t quite accurate. Since 2020, the Energy Saving Ordinance no longer applies; instead, the requirements of the Building Energy Act have been in effect. This means that our construction project is subject to this new legislation... and this law has made the ERR exemption process even stricter. So, applying for the exemption involves additional effort!
A brief timeline of our experience:
- We commissioned the well-known engineering firm "H******n" to perform the heating load calculation (including a standard letter). It took about 4 weeks to receive the complete documentation. They are currently very busy, so expect longer waiting times.
- Once we received the documents from the engineering firm, we informed the responsible district office about the situation and submitted our application for the ERR exemption. I should mention that the authority initially did not understand the request at all, and we were likely the first to submit such an application.
- After about 10 days (following our inquiry), we were informed that the case was now known internally and they understood how to handle it. At that point, we also received a file number, meaning the application was officially activated.
- We then sent the heating load calculation including the standard letter to the district office. Receipt of these documents was confirmed... and then nothing happened for some time. When we asked about the status, we received the following information:
"You have applied for an exemption from room-specific temperature regulation, regulated by § 63 para. 1 of the Building Energy Act; the legal basis for the exemption is § 102 para. 1 of the Building Energy Act. The district office XXX is responsible for enforcing the Building Energy Act as the lower building supervisory authority (§ 2 para. 1 sentence 1 AVEn). § 7 para. 1 sentence 1 AVEn specifies that the fulfillment of the requirements for an exemption according to § 102 para. 1 sentence 1 no. 1 or no. 2 alternative 1 AVEn must be certified by an expert as defined in § 3 para. 1 AVEn."
Specifically, the following is now required:
Possibly, the heating load calculation from engineering firm H******n, signed by Mr. XXX, could be accepted as such a certificate. However, the prerequisite is that Mr. XXX provides the district office XXX with the appropriate proof of qualification. If Mr. XXX is not an expert as defined by § 3 para. 1 AVEn, you would need to submit a corresponding certificate from an expert, including proof of their qualification.
- After inquiring with the engineering firm whether the calculation can be signed as requested by the district office, the answer was no. (Presumably because the required qualification as an expert according to § 3 para. 1 AVEn is possibly not available within the company.)
- We then started searching for an "expert according to § 3 para. 1 AVEn." That was an adventure, I can tell you. Most of the so-called "experts" didn’t even understand what we wanted when we explained the matter. "...that’s the story with 'experts'..." We had to try several times before we found someone who immediately understood the issue and could provide the required certificate.
- We then submitted the outstanding confirmation to the district office. Within 3 days, we received the official ERR exemption by mail (stamped and everything).
Conclusion:
It is doable, but it definitely requires a lot of persistence and time. If you are already under time pressure, it’s hardly worth it! So, start dealing with this topic early!
My personal opinion: --- Bureaucracy at its finest! ---
First, an independent expert has to issue a certificate prepared by a specialist in this field! So, the specialist is not trusted initially... It somewhat reminds me of "Asterix conquers Rome" and the "Passierschein A38" task.
Not to forget that besides the time involved, there are also monetary costs!
This process ultimately cost us around €950.
Good luck to all future homeowners considering applying for an ERR exemption.
B
Benutzer20025 Apr 2022 12:29Stravanzer schrieb:
Conclusion:
Everything is doable, but it definitely requires a lot of patience and time.
If you are already under time pressure, it doesn’t make much sense! So start addressing the topic early! Congratulations that it worked out for you as well. However, not every authority is as bureaucratic as yours. Regardless, the 950€ are well spent money and you are formally in order 😀
Stravanzer25 Apr 2022 12:57Benutzer200 schrieb:
Congratulations on your success as well.
However, not every authority is as bureaucratic as yours. Anyway, the €950 is well invested money and you are officially in the clear 😀Thanks 😎 ...although I doubt that authorities here could act so differently in terms of bureaucracy. Since this has been mandated by the legislator through the Building Energy Act, an authority can’t just ignore it, right? Authorities also have to operate in compliance with the law and ensure audit-proof processes, don’t they?...anyway, we’re glad to have the exemption in hand. :p
Stravanzer25 Apr 2022 13:01Tolentino schrieb:
But for 950 EUR, couldn't he have simply installed the ERRs and just not used them? Wasn't that more of a Pyrrhic victory? It’s not just the thermostats... There are also the actuators, the buffer tank, and other materials involved.
Overall, it’s worthwhile since the heating load calculation is tailored to the house, rather than doing a generic “off-the-shelf” installation.
Let’s not be negative about it... it’s fine as it is... 😎
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