Sterling Accreditation Energy Assessor Guidance QA Auditing of EPCs

Transcription

1 Sterling Accreditation Energy Assessor Guidance QA Auditing of EPCs Practices and Procedures Manual Version 1.1

2 The Sterling Accreditation quality auditing manual has been created to support Energy Assessors (EAs) with reasonable guidance on their obligations from a scheme perspective and what information is required to complete an EPC audit and what the critical areas a scheme should review when auditing. When an audit is called for; the EA will need to provide the Sterling Audit team with evidence to verify if the EPC is true and accurate, this should include the items highlighted in Bold below:- REQUIRED EVIDENCE EXISTING BUILDINGS Data file, and or software data collection forms, relating to information used by an EA to calculate and EPC, which allows Scheme QAA to assess the accuracy of the EPC against each stage of data entry associated with SBEM Site Notes. Design Floor Plan, elevations, sections, building log book etc which allows the EPC to be recalculated. Evidence of zoning. Schedule of what is in every zone. Ariel view of building. COMMENTRY The EA shall provide within the site notes (or design commentary notes) anything used in support of: Confirming data input or decision making that cannot be substantiated by other sources of evidence Reflective thought, hand calculations, or amendments to recommendations (identifying building age, construction, assessing primary heating system etc), which is not provided through other sources of evidence. Where these documents are not available photographic evidence shall be required which can demonstrate missing elements eg photographs which demonstrate construction type, Evidence of zoning shall be by way of an annotated drawing of the building identifying the zones. In buildings with many zones, photographic evidence shall be provided to support zone classification. from Google maps or similar that clearly identifies the building and site layout to confirm orientation, or a hyperlink to the satellite view of the building. Individual assessors are responsible for ensuring that they comply with any terms and conditions attached to the use of such material. Photographs Photographs of all external elevations: front, rear and side(s) Photographs demonstrating all construction types (eg cavity or solid wall) with a demonstration of, where possible, the presence or not of insulation Photographs of glazing types, including sufficient information, where necessary supported by site notes, of the g-value selected (g-value (EN ISO 410). Photographs of shading types Photographs of roof construction including any rooflights. Photographs which demonstrate the full range of HVAC & lighting systems used in the building For HVAC, lighting, controls and fabric the evidence needs to demonstrate the data entered into SBEM. For each HVAC & lighting system this shall include the requirement to provide appropriate evidence, including photographs, manufacturers make and model for example: Chiller and generator type, Heat recovery system, Presence of fans and pumps along with pump power and/or SFP, Fuel type and controls. Page 2 of 12

3 (including HVAC manufacturer/make/model numbers and any third party evidence of calculations). Heat emitters and cooling terminal units within zone/areas Controls within zone/areas DHW type, efficiency, fuel, volume and/or storage losses, pump power, secondary circulation Lighting within zones and controls Evidence of LZC technologies and relevant data Sub-metering Power factor correction if no photograph or other compelling evidence then the QAA shall select 0.9 or worse. Any other key feature of the building or limitation whose presence or absence may affect the EPC rating or which would be required to support any claim made in the report that could be subsequently queried or be the subject of a complaint. Any unusual feature which leads to an adjustment in the floor area from a simple calculation based on plan areas. Where the Energy Assessor believes that photographs are not practically achievable, but a particular element / energy using device is present, site notes shall explain why the photographic evidence is not available. The QAA shall form a view as to whether the claim is reasonable. In this regard the QA assessor needs to record reasons why the absence of photographic evidence have been accepted to allow a review by DCLG. Photographs shall be dated within the image to avoid the use of stock images. Electronic files will only be acceptable if there is a secure means of dating the file. If there is a particular reason for a failure to provide evidence which is outside of the control of the Energy Assessor, the Scheme can apply to the DCLG to implement a revised set of requirements. Supplementary calculations undertaken by the assessor Lighting and controls. Evidence shall be photos of lamp types, combined with numbers of lights and the lighting schedule from site notes. Where lux measurements and hand calculations are provided supporting evidence (photographs) shall be required. Daylight linked controls requires photos of sensors on ceilings. Examples of these might be: Overshading calculations Common values CoP /SEER / EER SFP Extraction rates. Accredited details Can only be used with existing buildings if evidence that they were accepted at the time of design can be provided. Page 3 of 12

4 Any other evidence required to justify the suppression or inclusion of additional recommendations Ventilation rates Example of this might be: a guarantee or a building control notice for improvements evidence of a building s age Evidence for the ventilation rate selected shall be provided When auditing an EPC Sterling QA Assessors will check all Critical Inputs (CI) and accompanying supporting evidence. 1. General information NOS Level, Weather location, Orientation, Metering, Power factor, Air permeability, Accredited Details. 2. Construction types/elements U and Km values for opaque constructions. Glazed fittings and openings: Area, U-value, and g-value (where applicable) of windows, roof lights, and doors. Exposed thermal elements: Area and U-values of external walls, floors, roofs. 3. HVAC systems efficiencies and fuel type for heating, cooling, and DHW systems (including storage, losses and secondary circulation data where required), air distribution system efficiency parameters. 4. Ventilation system local mechanical exhaust, extraction or supply only and extraction and supply systems, SFP and heat exchanger type and efficiency. 5. Lighting and lighting controls 6. Zoning including total zone area and building area along with assigned activities. 7. Inclination of roof element for any EPC using compliance with 2010 Building Regulations onwards. 8. Flat roof assignment. 9. Record keeping including: notes, drawings, and photographs. Page 4 of 12

5 Calculating the sum of absolute errors The QA Assessor works through the assessment in accordance to Sterling s QA procedure, when the QAA finds an error a correction is made and the changes in values are noted. The assessment is then returned to the original state and the QAA moves on until the next error. Buildings with 20 or Fewer Zones The QAA shall assess the accuracy of the BER calculation and EPC rating as follows: 1. The QAA shall work through the EA s assessment using the evidence provided by the EA for each data entry field required by the software 2. For each data field where the QAA believes that there is a need to change the data, the QAA shall list the data fields considered to be incorrect, and shall then change the input data for each data field in all relevant elements and for all zones and then recalculate the BER rating. 3. The QAA shall note the variance in the BER arising from any change, and shall record the variance as a positive value in each case whether the variance is negative or positive, as well as the reason for the change. 4. The QAA shall then reset the field(s) in question to the EA s original value. 5. The QAA shall then move to the next entry field and repeat testing from step b) above. 6. When all entry fields have been checked the QAA shall add all the differences obtained by step c) to arrive at the cumulative error in the BER rating. 7. Schemes shall not make use of truncation or rounding within their calculation processes, eg 4.4 cannot become 4, where software provides a more accurate outcome. 8. In addition to these checks, if errors in data entry by the EA result in a material change of recommendations as to energy efficiency measures, the audit shall be marked as a fail, and the EPC shall be judged as being defective. Buildings with More than 20 Zones Where a building has more than 20 zones, the QAA shall review all global values plus a sample of 20 zones, plus at least 10% of the remaining zones once the first 20 have been reviewed. These zones shall be selected by the QAA to be the most critical in the buildings when it comes to BER calculations and recommendations, depending on the servicing strategy. For each HVAC plant type present a selection of zones that HVAC plant services shall be checked. Zones shall be representative of the building as a whole, and shall include the major functional areas. The following are acceptable means of reviewing BER and EPC errors: 1. Check all zones in the building 2. Check all global values Then check the 20 most important zones plus 10% of the remaining zones Calculate n = % of total number of zones. Cumulate the total floor area of all n sampled zones (TFA of sampled zones = TFA of Zone 1 + TFA of Zone TFA of Zone n). Calculate the escalation factor (F) by dividing the total floor area of the EPC by the total floor area of sampled zones: F = TFA of EPC / TFA of sampled zones. Multiply the cumulative error in the BER associated with all zones sampled with F. If this error plus any error associated with global zones is outside acceptable accuracy limits, the EPC is defective. If the recommendations associated with the EPC changes due to differences between the QAA and the EA data entry, the EPC is defective. The EPC shall be calculated by the EA when all differences between the EA and QAA are entered into SBEM. 3. The sampling requirements specified above are minimum requirements. QAAs may apply additional sampling, of anything up to 100% of zones, to establish whether an error that is Page 5 of 12

6 identified in one zone is a single occurrence or whether it is likely to have been repeated in other zones. Where additional zones are checked and the error is found to be repeated in 45% or more of the zones in which a similar error might occur, then the escalation factor above shall be applied. Where the error is found to be repeated in less than 45% of the zones in which a similar error might occur, then the QAA may make a judgment that the escalation factor described above shall not be applied. However, any zones in which the error is repeated shall be treated as cumulative errors for the purposes of determining the outcome of the audit. Certificates are deemed to be defective and should be replaced when any one of the following conditions is met: The BER rating shall be judged to be correct if the EA s assessment is within either 5 kgco2/m² of the rating calculated by the QAA, or 10 per cent of the BER rating calculated by the QAA. In all other instances the BER rating, and hence the EPC, shall be judged to be defective, and the audit marked as a fail. If the error plus any error associated with global zones or the application of the escalation factor is outside acceptable accuracy limits given the EPC shall be classed as defective, and the EA required to replace it. If the recommendations associated with the EPC change due to differences between the QAA and the EA data entry, the EPC shall be classed as defective and the EA required to replace it. If the QA assessor believes that recommendations have been incorrectly added or removed. If errors in the building s description would result in a change in the recommendations made. The building s description is sufficiently inaccurate that it brings into question the accuracy of the rating by the seller. Sufficiently inaccurate is taken to mean information on the EPC which is demonstrably incorrect subject to an ability to change the description in the software to account for what the assessor has seen. If the evidence provided to justify the EPC is deemed insufficient by the Scheme (i.e. does not allow the EPC to be recreated by the QA Assessor). Please note it is the EA s responsibility to correct and re-lodge any incorrect EPC s identified by the Sterling QA team. It is also the responsibility of the EA to back check their catalogue of EPC s that have been completed in between audits to ensure correct lodgement. Page 6 of 12

7 All schemes have a minimum requirement for auditing purposes. See below for audit timeline to understand the process and what you should expect. Audit escalation process 1. The audit process starts with recognising an audit requirement in line with the current Scheme operating requirements (SOR) which came into force on the 1st July As soon as the Sterling audit team request evidence from the assessor, the countdown process starts for the assessor to provide the complete evidence pack. (Unless individual arrangements are made with the Sterling Audit Team, the maximum period for supply of information from the Energy Assessor is fifteen days. 3. If evidence is not provided within the required period, the Sterling audit team will contact the assessor and advise that failure to supply information could result in membership suspension. If the Energy Assessor is able to provide mitigating circumstance as to the delay in sending data through the Audit Team may offer an extension to this period. The extension period is a maximum of 5 days 4. If evidence is not provided the Sterling Audit team then the EA will be suspended immediately. The suspension can only be lifted if the EA provides a reasonable and compelling reason case as to why the information is not available. Where suspension is lifted the Scheme shall undertake two further audits from the subsequent 30 days following the date of the initial call for audit, or the next 3 EPC s lodged if this time period is exceeded 5. The Sterling audit team will complete the audit within 15 days from receipt of the evidence pack 6. The Sterling Audit team will provide feedback to the EA within 5 days from completion of the audit 7. If the audit is a pass the Sterling audit team write out to the assessor with a full audit report including comments where applicable. All QA audit reports are held online in the members reporting area for your reference. 8. In the event the Audit fails, the Sterling audit team write out to the assessor with a full audit report detailing the reasons behind the failure.. The EA will correct the certificate and relodge it on the database within 10 days of receipt of notification from the Sterling Audit team unless the EA appeals formally then the appeals mechanism will be implemented. 9. If an audit fails the Sterling audit team write out to the assessor to request further two evidence packs for QA in accordance with the SOR 10. If evidence is not provided within the required period the EA will be suspended immediately. The suspension can only be lifted if the EA provides a reasonable and compelling reason case as to why the information is not available. Where suspension is lifted the Scheme shall undertake two further audits from the subsequent 30 days following the date of the initial call for audit, or the next 3 EPC s lodged if this time period is exceeded 11. If both additional QA audit s pass, no further action will be taken by the audit team, until required by the SOR. The Sterling audit team write out to the assessor with audit pass reports, including comments where applicable. All QA audit reports are held online in the members reporting area for your reference. 12. If the assessor fails one of the two additional audits triggered by the initial audit failure the audit team will have to make a judgement as to the appropriate remedial action based on Page 7 of 12

8 the seriousness of the fail, the Sterling audit team write out to the assessor to confirm next actions in accordance with the SOR. 13. If the assessor fails both audits triggered by the initial failure then the assessors is automatically suspended until it is clear what remedial action is needed to be taken to correct the lack of knowledge. Membership to Sterling will only be reinstated following evidence from the EA that remedial actions have been completed. 14. In the event a QA Assessor can demonstrate that the two consecutive failures in the follow on audits were minor in nature and knowledge can be easily rectified by the EA undertaking self learning, the EA will be released from suspension. On return from suspension the Audit Team will subject the assessor to whichever is the greater of: a. 10% clear auditing regime for a period of 6 months subject to at least 5 EPC s being assessed during the period; or an audit of 5 clear EPC s within the 6 month period following a return to lodgement. Should 6 months be insufficient to generate 5 EPC s then the scheme should select the first available EPC s. b. The next 5 EPC s lodged 15. All incorrect EPC s must be corrected and re-lodged within 10 days of receipt of the Sterling failed audit letter. Failure to re-lodge a failed EPC within 10 days from initial notice will mean immediate suspension of membership. All schemes will be notified in-line with CLG Guidance and the EA will be subject to a disciplinary committee 16. Following re-lodgement of the failed EPC the EA will provide the audit team with the evidence required to complete a full audit on the re-lodged certificate. All the requirements and timescales will apply to re-lodged certificates Member Appeal Procedure If the Scheme Member wishes to appeal against one or more elements of the Sterling Accreditation audit process; they may, within 28 days seek to appeal any such decision by giving written notice (See form below ) that they wish to refer the matter to the Sterling Accreditation appeals committee and to state the reasons for the appeal and providing any relevant documentation. The Sterling Accreditation appeals committee will consist of three members of the Sterling auditing team, at least one of whom is a senior member and one who will be an accredited Energy Assessor qualified to the relevant strand to the enquiry. The Appeals Committee will duly consider the Appeal and reach a decision based on evidence / interviews as appropriate. The Appeals Committee will respond within 14 days of the receipt of the Notice of Appeal. If the Scheme Member wishes to appeal against one or more elements of the Sterling Accreditation Appeals Committee s hearing; or Sterling Accreditation s decision under the audit Procedure they may, within 28 days of that decision seek to appeal any such decision by giving written notice that they wish to refer the matter to the Sterling Accreditation independent Appeals Committee and to state the reasons for the appeal and providing any relevant documentation on the Sterling member appeals form. The Sterling Accreditation Appeals Committee consists of three members of the Institute of Civil Engineers mediation committee, at least one of whom is a senior member The three members Page 8 of 12

9 should not have any working relationship with the Scheme Member and should not have been involved in the original decision in any way. If, for whatever reason, it is not possible to construct a Committee based on these criteria, the matter will be referred to the Chartered Institute of Arbitrators, for the appointment of a single arbitrator for final resolution. The Appeals Committee will duly consider the Appeal and reach a decision based on evidence / interviews as appropriate The Appeals Committee will respond within four weeks of the receipt of the Notice of Appeal. All decisions made by either the Disciplinary Committee or the Appeal Committee is held securely and centrally, together with any relevant documentation, for fifteen years for future audit purposes. Page 9 of 12

10 Member Appeal Form 1. Introduction Each Member has the opportunity to appeal against the decision within four weeks of the original notification. All Appeals will be received and vetted by the Sterling Audit Team and passed to the Senior Quality Auditor for further appraisal. For further details, please see the Sterling Disciplinary and Appeal Procedure document. The following template should be used for Member Appeals:- Question Response Date of Appeal Name and ID of Appealing Member Contact Details Of Appealing Member Address Postcode Telephone No Home: Mobile: Address(es) Page 10 of 12

11 Availability for feedback : Preferred Means of Contact ( /phone/letter): If phone, preferred Time: Brief description of Nature of Appeal Full details of the Appeal Please be as detailed as possible, giving the reasons for Appeal and any facts which might assist your appeal. Attach any evidence which is relevant to this appeal. (Continue on extra paper if required) Page 11 of 12

12 Sterling Office Use Only Date Appeal Form Received Sterling Appeal Handler Current Status Escalation Resolution Resolution Date Response Date Page 12 of 12