The 1 July ha RD 178/2021 has entered into force published in the BOE on 24 March last. which introduces certain updates and modifications to the Thermal Installations Regulation (RITE) of 2007. Since the Heat Generator and Heat Emitter Manufacturers Association (Fegeca), the first thing they want to make clear is that "it's about a modification of the standard and not a new RITE. In other words, they still the RITE of 2007 with the successive modifications is in force that have been introduced. To make a correct reading and to clearly understand the modifications introduced in the regulation, it is best to read the consolidated regulation updated by the ministry".
The intention of the Administration is to make a in-depth revision of the 2007 RITE in two phases. This first (Phase I) it is a adaptation of the standard to the European directives in force and to the commitments made for our country. The deeper reform is the one that is being carried out in Phase II. For months now, the ministry has been working together with sectoral expert roundtables on this second amendmentwhich will be deeper and which, in Fegeca's view, "will certainly will be significant enough to publish a new Regulation. of Thermal Installations".
As indicated in the preamble, RD 178/2021 introduces modifications to RITE in order to adapt to European standards such as:
- Directive (EU) 2018/844amending Directive 2010/31/EU on the energy performance of buildings and Directive 2012/27/EU on energy efficiency.
- Directive (EU) 2018/2002amending Directive 2012/27/EU on energy efficiency.
- Directive (EU) 2018/2001 of the European Parliament and of the Council on the promotion of the use of energy from renewable sources.
- Directive 2009/125/ECestablishing a framework for the setting of ecodesign requirements for energy-related products.
- Regulation (EU) 2017/1369establishing a framework for energy labelling.
From Fegeca's point of view, this adaptation implies the following most relevant changes:
- Minimum equipment performance and efficiency requirements are removed. All equipment (boilers, heat pumps, heaters, water heaters, air-conditioning, solar energy, biomass, ventilation) shall comply with the regulations European countries in force on eco-design and energy labelling.
- The regulation increases the obligation to design installations with high energy efficiencyby extending it so that it can also include renewables and waste energies.
- The concept of thermal installation is extended to include district heating and cooling networks (District Heating and Cooling).
- According to the above, the following are also added to the definition of a thermal installation automation systems and control (to improve the performance and facilitate the efficient inspection of installations).
- The text of the rule is amended to make it clear that type B heaters may be installed in areas where outside. This was not entirely clear in the previous regulation and led to clarifications from some autonomous communities.
- Modification of the burner regulation sectionThe new legislation requires all gas burners to be modulating. In the case of oil, only those above 70 kW must be modulating.
- In relation to the minimum energy performance requirements for heat generators the control of the system shall be based on an external temperature compensation probe or modulating thermostat, so that it modifies the flow temperature to emitters adapting them to the demand.
Undoubtedly, for manufacturers of generator and emitter equipment, the most important thing about this update, according to Fegeca, is the adaptation to European eco-design (ErP) and labelling regulations energy (ELD)All equipment manufactured and marketed in the European Union complies with European manufacturing regulations since their entry into force. So this unification of RITE with the ErP and ELD regulations was long awaited and necessary," they say.
All teams identified shall comply with their Ecodesign and energy labelling standards:
? Boilers, solar energy and heat pumps.
? Heaters, water heaters and accumulators.
? Biomass cookers (ErP for Lot20 comes into force on 1/1/2022, until then they must have an instantaneous efficiency of 65%).
? Air conditioning.
? Ventilation.
For Fegeca, no less necessary was the clarification that has been introduced regarding the installation of type B gas heaters in outdoor locations: "This modification clarifies that this type of heaters can be installed on verandas, balconies and terraces that have a permanent opening of more than 1.5 m2 (definition according to the UNE 60670-6 standard), something that was already being done in many autonomous communities where the same interpretation was made. This clarification introduced in the RITE will extend the same interpretation to all regions".
With regard to the changes made to the modulation of the burners, in the case of the gas burners is obliged to are modulating, irrespective of the power who have.
For the liquid fuel (gas oil) burners the following criteria have been established:
- Burners P ≤ 70 kW: 1 or 2 stages
- P>70 kW Burners: Modulating
As the Association of Heat Generator and Heat Emitter Manufacturers points out, "this is a exchange very important and that leaves the oil burner market in a worrying situation. The state of the art of oil burner technology is not yet adapted to this requirement. Currently oil burners are not available on the market. modulating for power ratings below 200 kW. This requirement does not exist for other European countries, so adaptation will be even more complicated. In this respect, Fegeca has requested measures to adapt technology to this new requirement.
The paragraph has also been amended with regard to the hot water preparation for sanitary purposes (IT 1.2.4.1.2.4), allowing the incorporation of conventional auxiliary generation systems into the storage tanks of renewable installations. "In other words, it finally allows combining a renewable energy system in a single reservoir (e.g. solar thermal energy) with a conventional system (e.g. gas boiler). In other words, the use of the two heat exchangers of the double coil storage tanks is allowed, and thus the possibility to avoid the installation of double storage tanks in renewable energy systems", they point out. Of course, these accumulators should always be designed and installed to maximise the renewable source utilisation.
Finally, an amendment is made to the limitation of consumption of solid fossil fuels (coal). It is indicated that the ban on the use of these fuels applies not only to newly constructed buildings, but also to existing buildings at the time of any renovation of their thermal installation.
