SECTION A – INTRODUCTION & CONTEXT
General Introduction and Context
The Malta Chamber of Construction Management (MCCM) is the official body representing local construction managers working within the construction industry at various supervisory and management levels. MCCM promotes and expects high standards in, quality, ethics, integrity and to be at the forefront of innovation of the local built environment. MCCM’s input continuously strives to influence policies and regulations that impact the industry towards improvements for the common good.
MCCM welcomes the initiatives and improvements being proposed by the Regulators and relative Authorities that are effectively the right step towards the regularization efforts of the Construction Industry that ultimately should lead towards improved quality of our infrastructure.
MCCM’s feedback is to be read within the premise that although MCCM represents the ‘Management’ aspect of the construction cycle of a property development, its members are involved in leading the multiple stages of a property development cycle. Therefore, considering that its members have an array of experience including the broader aspect of the industry, this feedback may not necessarily be limited to the technical aspects only but touches upon practicalities and related processes within the context of the Technical Document F use and applications. Once again, as done with reviews of other draft regulations, MCCM works in close liaison with The Chartered Institute of Building (CIOB) and conducts several consultations with this same body. Both MCCM and CIOB work hand in hand to promote improvements within the construction industry locally and internationally.
As with CIOB, the Environmental mandates (including social value and carbon net zero aspirations are considered top priority as can be seen within the 6th edition of CIOB’s guidelines to practitioners:
Quote
The sustainability mandate will influence key design parameters relating to sustainability, performance, and operational technologies. It should also outline the overall environmental management criteria including what are the key success factors (for the project(s)) in terms of sustainability management. It is the role of the project manager to debate, evolve, prepare, and manage all required sustainability mandates, noting that the environment is only one element of sustainability. This will require project managers to understand and have knowledge of environmental science/energy management of built assets, climate change science or biodiversity sufficiently enough to have meaningful discussions with the project stakeholders at all-life cycle stages. Unquote
B 1.00 `TECHNICAL FEEDBACK (specific to the Building Envelope)
B 1.01 Thermal Comfort
We understood that the concept behind revisions to Document F is to increase the thermal efficiency of buildings, with the target to reduce the carbon footprint and increase the comfort of our homes (quality of life), with all the associated benefits. As they say, buildings shape cultures.
While various ISO standards are mentioned in the draft documents, the standard that explicitly treats comfort in buildings i.e., ISO 773 is not mentioned. Thermal comfort is the thermal sensation experienced by the human body related to its thermal balance. In a simple term, the internal temperature of the building envelope (Stone and Windows) and the internal air temperature shall not differ by more than 4 degrees Celsius.
B 1.02 Primary Energy Demand
The primary energy demand, excluding renewable energy sources, is set on the high side. As a country, we must also meet the nZEB obligations. Therefore, Document F should align accordingly. Considering that the nZEB standard for the Mediterranean climate envisages a lower primary energy demand, it is understood that we should do our utmost to be as close as possible. In our opinion, what is being proposed as a minimum be reconsidered to be considered as maximum. Rather than giving a chance for designers/architects to come up with excuses if they do not reach these figures, they have to ensure that at least these values are achieved. Ideally, we should target Italy’s standard levels, as shown in the diagram (next page).
SECTION
–
DRAFT TECHNICAL
B
FEEDBACK TO THE
DOCUMENT F
nZEB requirements as prepared by the Building Performance Institute Europe
If one checks what is the PED of leading energy-efficient building standards such as Passivhaus (which has been in the market since 1989 and applied to all sorts of buildings all around the world), the maximum primary energy demand of buildings has to be less than 15 kWh/m2/year
B 1.03 Maximum Thermal Transmittance
In line with the primary energy demand, the maximum thermal transmittance of the buildings is also set on the high side and can easily be improved. Here is a comparison between what is being proposed to what the Passivhaus standard requires, it is noted that Passivhaus, as a standard, is much closer to nZEB (even more stringent) than nZEB is close to Document F. These values are extracted from the Passivhaus Institute and are valid for warm and hot climates like Malta.
B 1.04 Glazed Elements
The glazed elements are currently set at 4.0 W/m2K, which is very high. A glazed element comprises a frame and a glass, represented as Uf and Ug, respectively. When the calculation of both materials is conducted, we reach Uw. Therefore, the 4.0 W/m2K refers to both materials together. Each country must set the minimum requirements for the components, such as windows, and if we had to compare to a neighbouring country, like Italy, they specify a Uw value of 2.6 W/m2K for South Sicily and Lampedusa.
This means that what is being proposed is over 35% of the maximum value used in Lampedusa.
If we had to continue with the same example, Italy explicitly states that the Uw value has to be the installed value, meaning that the installers must be officially certified, and the products must meet stringent specifications. This is regulated by UNI 11673-1 and is already in the process of being further improved. Such a standard also considers using thermally broken subframes to avoid mould formation and increase thermal insulation.
On a side note, the installed Uw of windows required by the Passivhaus standards should be lower than 1.25 W/m2K, easily achievable by many Maltese companies for over ten years. Therefore, it is not an issue that these products are unavailable in Malta; on the contrary, many leading companies who follow international standards are well prepared to use such products.
In the same document, it mentioned that the glazed elements are required to be thermally broken. Such a statement is too much vague; therefore, we shall propose to issue a maximum Uw value, irrelevant of its thermally broken or not, while to be in line with the CE markings that will be introduced in the coming months, we shall also propose the below characteristics, that would reflect maximum thermal emissivity and the quality:
Uw Value - 2.6
Air Permeability - 4
Wind Resistance - C5
Water Tightness - E750
At point 3.4.2, the document also proposes the G Factor and Light Transmittance of Glass. These values are based on transparent glass, without the use of any coatings, which goes
against the EN 14351-1, which states that the minimum Ug value has to be 1.9 W/m2K, where such glass would have a G factor in the region of 0.40 (or 40%). It is typically recommended that in warm climates, the G Factor is lower than 0.5 (or 50%)
B 1.05 Thermal Bridging
While thermal bridging has been mentioned, we need to focus further on this aspect as it is one of the elements contributing to overheating, mould formation, and humidity in the winter
Thus, we must emphasise that designers (architects in our case) must adhere to stringent thermal bridging specifications and, if necessary, encourage specific training. For example, ideally, the Psi value of thermal bridging shall be lower than 0.01.
B 1.06 Airtightness
A concept that seems to have been omitted is air tightness. We might have a perfect envelope, including high-performance window systems, but both windows and the envelope leak air. Therefore, we suggest introducing a door blower test to confirm that such buildings are not leaking. Such tests are conducted at a negative pressure of 50 and test the number of air changes per hour, typically less than one air change. To compensate for the lack of natural ventilation, the document is already proposing mechanical ventilation with heat recovery, while we shall also propose to have humidity control since our climate is high in humidity
B 1.07 Humidity level
As with airtightness, one should also include allowable humidity levels, which shall be not less than 35% and not more than 55%, with a CO2 level of not more than 500 ppm. Such characteristics can be used as a part of an educational campaign where people can measure the internal relative humidity, temperature, and CO2 levels through a simple device, which can be the tipping point for building renovations.
B 2.00 `TECHNICAL FEEDBACK (specific to EPC)
B 2.01 Definitions ‘nZEB’
The definition of 'nearly zero energy building' is not clearly defined in either LN47/2018, LN134/2020, or Doc F itself. One may take Table 1 of Doc F to be the definition, but this is not stated explicitly.
B 2.02 Primary Energy Demand (smaller buildings)
The overall primary energy demand for s bui lding, in (kWh/m²a), indeed its 'performance', depends heavily on the building's floor area. Small buildings tend to have low er performance as a result of this aspect. DocF partially addresses this by having different building categories, but this measure is not sufficient. Small dwellings may find it very difficult, if not impossible, to achieve the required performance of, say, 50 due to the small area, whereas large dwellings may achieve it without extraordinary measures. Small dwellings, in particular those designed for low er income families, tend to consume less energy on a per capita basis, especially since they tend to be unconditioned Therefore, they should not be seen as the culprit from an energy perspective. Paradoxically, it is the larger dwellings with their high- consuming fully -airconditioned envelopes that perform better in the rat ing. The met hodology must include some means to address this inconsistency.
B 2.03 RES
There is little or no mention to next frontier in RES: communal systems. Considering that property development in Malta evolved within the context of clusters and mixed used development, we are seeing more and more blocks of apartments and clusters having common spaces. Therefore, Doc F needs to provide clear guidelines for the next frontier in RES: communal systems.
B 2.04 Shading and related constraints
Dwelling with neighbours shading their roofs cannot realistically seek alternative sources that that are anywhere near as effective. The entire process needs to provide ow ners of such dwellings who wish to improve their rat ing with a solution. Possibly a system of 'credits' may be contemplated
B 3.00 COMMENTS ON THE APPLICATION OF DOCUMENT F AND ITS IMPORTANCE (Practical applications)
B 3.01 Relevance of Document F
It is indeed a pity that notwithstanding that the current document F has been within the local regulations’ framework, not all professionals (designers and architects) follow the guidelines explicitly at design stage and even worse at development application stages with the Planning Authority. The process must therefore become ingrained within the design stages and most important its relevance at planning application stages i.e., the professional in charge to apply for development with the relevant authority should declare and provide the level of design results relative to Document F at design stage. In turn, the Planning Authority would eventually consult the Building Regulation Office / Authority (Consultee) to confirm the conformity at design stage and hence should a development permit be granted, the adherence to document F at completion stage would be subject to verification and compliance certification. Therefore, compliance in terms of connection to utilities should be tied to compliance relative to Document F.
B 3.02 Document F and EPC certification
Whilst Document F provides the minimum criteria, there is no such harm to encourage developers and property owners to go further and improve other than reaching the minimum standards. Therefore, the relevance and importance of an EPC certification becomes even more pressing and important especially within the notion of the long-term renovation strategy and targets to be achieved as a nation. The EPC and level of certification is therefore important to be given the much-desired weight. Similar to comments under B 3.01 above, a design rating certificate of the proposed development needs to be submitted at application stage whilst its relevance / attainment of certification as committed at application stage would be subject to verification at completion stage by the regulator and prior to connection to utilities and respective kick start of the buildings’ use / operation. Here is were the common areas become even more relevant to address as most often such areas become an issue going forward within the life cycle of the building once in use.
B 3.03 Life expectancy
Once a building is commissioned, assuming points above mentioned are taken in consideration, once would expect that the property in question would have the obligation to
Draft Technical Document F MCCM Feedback 3
maintain the minimum or relative certification it was compliant to (certified at completion / commissioning stages). Therefore, the EPC would have more relevance and the obligation of the property owner to ensure that the building / property maintains the level it was certified originally. EPC would be termed and hence the building is subject to recertification to ensure it maintains the certification with an obligation on the owner to rectify or upgrade as the building depreciates (fabric). Controls in the form of building passport and obligations to the building owner would be required including but not limited to penalties when it comes to nonalignment not excluding non-use of the building in worst case scenarios.
B 3.04 Asset value
Considering the points mentioned above, this would mean that from an economic perspective, these initiatives (to be potentially regulations) would automatically but indirectly push the real estate market to regularise itself especially when it comes to the real value of the properties and the value for money to the beneficiary / end user. It creates an equal playing field in terms of quality of property (minimum) and established benchmarks in terms of pricing.
B 3.05 Link to Construction regulations (building codes)
MCCM understands that the Regulator is working on the drafting of the National Building Codes. Therefore, it is understood that the Technical Document F would effectively be either phased out once the Building Codes are issued / launched in their entirety or the codes would cross reference to Document F.
Draft Technical Document F MCCM Feedback 4
