As from July 2024, new buildings will need to follow rules laid out in newly updated Minimum Energy Performance Requirements. This is meant to reflect Malta’s commitment to meeting European targets for carbon emission reduction. The proposed measures are designed to meet the objectives outlined in the European Green Deal, which aims to achieve buildings that reach nearly zero energy levels and, eventually, zero energy levels.
An updated document, called Document F, will serve as a crucial set of guidelines for professionals within the construction industry, including contractors. It outlines the specific requirements, standards, and best practices that must be adhered to during the design, planning, and construction phases of buildings.
A short history
In Malta’s historical context, specific criteria related to energy efficiency and construction practices have existed for a very long time. These criteria were enshrined in our laws, outlining specifications for yards, windows, specific stone block dimensions, and walls with adequate thickness to maintain optimal thermal conditions. These regulations, established as far back as the 1800s, persist in civil law to this day. Common design features included Persian blinds to block the sun while maintaining ventilation, the use of skylights and high windows for adequate natural light, and high ceilings were common design features. Over the years the introduction of artificial lighting, heating, and cooling led to less reliance on these design features and to more use of energy.
If we fast forward to here and now, we will find that today’s minimum requirements stem from the Energy Performance of Buildings Directive (EPBD) introduced in 2002 by the European Union. This European law aims to reduce energy consumption, since buildings account for 40% of energy usage across the EU.
The recent directive emphasises that each country must adopt minimuml energy performance standards. Malta, in response, has initiated the development of these guidelines to align with the directive’s objectives. Document F, which came into effect in 2008, introduced initial guidelines pertaining to wall construction, roof insulation, and other building aspects. Due to our climate conditions, the regulations included provisions to limit overheating.
Document F has undergone significant updates twice, first in the 2016 and next in the new document that will come into effect in July 2024. The 2016 revision marked a milestone by introducing requirements for overall energy savings in new buildings. A specialised software and methodology for Malta was developed, and trained assessors calculate the energy performance of buildings assessing various factors, such as the insulation of exposed walls and the efficiency of lighting and air conditioning systems. While all buildings being sold, built or rented are assessed, minimum levels are only applicable to new constructions and those undergoing renovation.
Notably, the changes in 2016 aimed to establish a certain standard of energy efficiency in new buildings. However, at that time, there was no requirement for assessing or upgrading the energy efficiency of existing buildings. The focus was primarily on ensuring that new constructions met the stipulated standards outlined in Document F.
A new, more stringent year
In 2024, the energy efficiency standards outlined in Document F will become more stringent. The directive guiding how these requirements are set emphasises that the minimum requirements must be updated to “cost-optimal levels”. This ensures that investments in building construction are sufficient to result in energy savings over the building’s lifecycle.
Studies are carried out to assess the cost-effectiveness of energy-saving measures, and these studies are mandated to be conducted every five years. The updated standards not only impose stricter requirements for energy savings in new buildings but also introduce specific criteria for renovations in existing buildings. In the case of renovations, the requirements are more flexible to consider the existing building.
How Document F will be implemented
The implementation process involves submitting energy performance certificates (EPCs) during the Planning application process. These certificates are reviewed by the Building and Construction Authority (BCA) at various stages, including during the application process and upon completion. This ensures that the constructed or renovated building aligns with the prescribed energy efficiency standards outlined in the updated Document F.
In the design process, thorough checks are conducted, including aspects like the presence of a well and the construction of double walls or insulation. These checks occur at various stages, from the initial planning to the construction phase and upon the completion of the building. A builder is required to issue a compliance certificate, and the BCA retains the right to conduct inspections to ensure adherence to standards.
You’re supposed to have a well
Interestingly, the revised document also incorporates pre-existing requirements that have been there for hundreds of years, such as the obligation for a well, which holds significance in Maltese legislation. The obligation to have a well is explicitly outlined in the law in Malta, and Document F supplements this with the requirement to actually connect the well to at least one water point. Despite this requirement, many places either do not have, or misuse this well, particularly in block apartments and commercial buildings. Many of these wells end up being smaller than the specified standards, and some are used for incorrectly collecting unwanted rainwater in garages, leading to the wastage of good water, drainage issues, and other complications.
The changes, outlined
A key focus of Document F is the mandatory installation of renewable energy sources in new buildings. This requirement aligns with the latest European regulations promoting nearly zero-energy buildings.
For hot water in buildings the emphasis in Malta is often on solar water heaters, although other renewable sources may be suitable such as biodiesel systems, especially in applications for buildings like hotels.
Additionally, there are changes in insulation standards, with a requirement for slightly thicker roof insulation (around 5cm). This adjustment aims to enhance the overall thermal efficiency of buildings.
Furthermore, improvements in the efficiency of heating and cooling systems have been included. Older systems, such as electric heating and boilers, are being phased out in favour of more energy-efficient alternatives. For instance, the shift from fixed-speed ACs to ones with inverters contributes to enhanced energy performance. These changes are applicable not only to new constructions but also to renovations where system upgrades are undertaken.
The efficiency standards for air conditioners (ACs) are established under the Eco Design Directive, ensuring that only energy-efficient models, and not those with fixed-speed, are imported into Malta. The installation of non-compliant ACs is not legal under Document F.
Required changes in lighting standards reflect technological advancements, demanding even greater efficiency for the bulbs used. Lighting, while not the major contributor to overall energy consumption, is one of the measures which has a relatively short payback period. Installing energy-efficient bulbs proves economically viable in a short timeframe.
For new buildings designed according to Document F, a crucial step is the allocation of space on the roof exclusively for photovoltaic (PV) panels. This allocation is ideally determined early in the project, often during the Planning Authority’s study phase, to avoid situations where the entire roof is designated for other purposes, such as roof gardens, when the permit is issued. The allocation of panels to specific apartments can be managed in different ways, involving the use of a single meter or separate meters for each unit, although the document keeps this flexible.
Will this impact the cost of buildings?
Affordability is a significant concern in the context of these energy efficiency measures. Studies have indicated a construction cost increase of 10-12%, which can be absorbed with the savings in the long term but may pose an economic challenge in the short term. Some projects might face feasibility issues, potentially rendering them unviable due to these added expenses.
There is a belief that increased awareness of Energy Performance Certificates (EPCs) will drive attention to energy efficiency. If we draw parallels with household appliances, a shift in consumer behaviour occurred when energy ratings became mandatory. While certain changes can be market-driven, regulation often plays a crucial role in creating a demand for more energy-efficient products and practices. The implementation of regulations and the promotion of EPCs can influence consumer choices and foster a more energy-conscious market.
The Building and Construction Agency’s role
The Building and Construction Agency (BCA) is the lead entity driving these changes. To cater for them, it is expanding its workforce, particularly in roles related to compliance. In fact, recent months have seen an increase in the number of architects, engineers, and technical officers, allowing the BCA to focus more on the technical aspects of compliance. It is also increasing its collaboration with the Planning Authority when it comes to various aspects during the design and beginning stages of building projects.
The Journal has learnt that, in the context of enforcing and ensuring compliance with energy efficiency standards, data is very often lacking, making it challenging to assess the performance of Malta’s buildings and to draw conclusions on our performance as a country. However, recent developments indicate a significant increase in the number of EPCs requested after planning applications are submitted, with over 10,000 certificates received yearly.
Challenges and benefits ahead
Solutions are being sought for various challenges. One notable challenge arises in cases when buildings are sold when they are not even erected yet – when there is only airspace. These issues become critical when it comes to obligations related to renewable energy sources, such as PVs. This often leads to contractual and legal complications and can hinder compliance for lower levels in multi-storey buildings.
Another challenge is that, while monitoring ongoing construction is manageable for the BCA, enforcing compliance in existing houses can be tricky. To address this, an informational campaign emphasising economic benefits may be more effective and feasible than strict enforcement.
These challenges pale in comparison to the estimated economic and environmental benefits that such changes will create. By incorporating features such as improved insulation, energy-efficient appliances, and renewable energy sources, these buildings significantly reduce operational costs, leading to long-term savings. They also play a pivotal role in mitigating climate change by curbing carbon emissions.
Beyond the financial aspect, energy-saving buildings contribute to enhanced comfort, improved indoor air quality, and increased property value. As key players in sustainable development, these structures align with global efforts to create a more resilient and environmentally conscious future, setting the standard for responsible construction practices.
You can access the new requirements by clicking here.