Obligation to install individual meters that allow measuring the consumption of heating and cooling
On August 6, 2020, the BOE published the Royal Decree 736/2020, of August 4, which regulates the accounting of individual consumption in thermal installations of buildings (hereinafter, RD 736/2020), with entry into force the day after its publication, and through which it has been intended to comply (although belatedly) with the obligation to transpose the Directives 2012/27/UE and (UE) 2018/2002 (partially transposed), on energy efficiency.
With the publication of RD 736/2020, it is imposed on the “owners of existing centralized thermal installations in new and existing buildings”, that is, final consumers of heating and cooling services, the legal obligation to install individual meters that allow measuring the individual consumption of thermal energy in each home, all in order to allow consumers to optimize their consumption of energy and know the amounts actually consumed.
Exceptions to the obligation
This obligation is, however, conditional on the installation being “technically viable and economically profitable” (art. 3.1 RD 736/2020), according to so that there will be an obligation to install individualized accounting systems in the following buildings:
A) Those in which it is technically unfeasible, both due to the installation itself and the impossibility of its adjustment, leaving exempted from this obligation are heating systems equipped with heat emitters connected in series (monotubes in series) when they serve more than one user in the same ring.
Likewise, buildings that have (i) heating systems equipped with heat emitters are exempted from the obligation to install heating cost allocators connected in series (monotubes in series), as long as they constitute a column installation (more than one user per column); (ii) fan coil systems or (iii) aerothermal systems.
Likewise, systems that do not allow individualizing both consumption and system management from user to user will be exempted from such obligation due to technical infeasibility.
Exceptionally for heating installations, when the use of individual meters is not technically feasible, the obligation to install heating cost allocators is established, also subject to it being technically viable and economically profitable.
B) Additionally, there will be no obligation to install individual meters if it is not economically profitable, which will happen when the installation It is located in certain climatic zones that will be determined based on the altitude of the plot on which the building is located and the capital of the province in which it is located.
Requirements to qualify for the exceptions provided for in RD 736/2020
Although a building is excluded from the obligation to install individualized accounting equipment, either due to technical infeasibility or its geographical location, the owners of such facilities must carry out any of the following two actions under penalty of being penalized in accordance with the provisions contained in the provisions of articles 77, 78, 80 and 82 to 86 of Law 18/2014, of October 15, on the approval of urgent measures for the growth, competitiveness and efficiency:
- Obtain from the company that maintains your heating and cooling installations the corresponding certificate accrediting such exclusion (which must be issued free of charge by the same) and, subsequently, present it to the competent body of your community together with the responsible declaration model that is attached as annex II of RD 736/2020, all within a maximum period of two months from the date of signing the aforementioned annex II, for which the maximum terms provided in the Unique DT RD 736/2020.
- Request, at least, a standardized budget according to the model in annex III of RD 736/2020 from one of the authorized installation companies (which must issue it free of charge), and present it together with the responsible declaration provided in annex V before the competent body of your autonomous community within a maximum period of two months from the date of signing of the aforementioned annex III, for which the maximum periods provided for in the Single DT RD 736/2020 are available.
Execution of installations
According to the provisions of art. 4.3 RD 736/2020, it will be considered that an installation of individualized accounting systems is economically profitable if the period calculated in the budget for the recovery of the information is equal to or less than four (4) years and, in such case, the owner must proceed to the installation of the individualized accounting systems within a maximum period of fifteen (15) months from the following dates (DT Única RD 736/2020):
- February 1, 2021 for buildings with uses other than housing and, in climate zone E, for buildings with 20 or more dwellings.
- On July 1, 2021 in climate zone E, for buildings with fewer than 20 dwellings, and in climate zone D, for buildings with 20 or more dwellings.
- On December 1, 2021 in climate zone D, for buildings with fewer than 20 dwellings, and in climate zone C, for buildings with 20 or more dwellings.
- On February 1, 2022 in climate zone C, for buildings with fewer than 20 dwellings.
Since all consumption accounting systems installed from the entry into force of RD 736/2020 must have a remote reading service, art. 6 of the same provides for a transitional regime until January 1, 2027 for those individualized consumption accounting systems installed before the entry into force of the new standard that do not allow their remote reading, allowing during said transitional regime that the obligation to Consumption accounting is accomplished through a system of periodic self-reading by the end user. In any case, the information on the reading of the metering equipment and the individual settlement will be provided to the consumer free of charge, at least every two months if the system does not have a remote reading service, and monthly if it does. with the same.
