By their very nature ‘fugitive’ emissions can, at best, only be estimated during the design stage of an embodied carbon report, often called a Life Cycle Assessment (LCA). A LCA is a method of evaluating the environmental burden of processes and products during their life cycle from cradle to grave . Post installation record keeping of fugitive emissions can inform subsequent reviews, and reporting. Giving exaggerated importance to estimated fugitive emissions may compromise the selection of air conditioning equipment that is demonstrably more suitable for the application, and in many cases more energy efficient than the alternatives. What are fugitive emissions? Fugitive emissions refer to the gases or vapours that are released from pressurised equipment due to leaks, evaporation, or other unintended or irregular releases. In the context of refrigerant gas within air conditioning systems, fugitive emissions refer to the leakage of refrigerant gases into the atmosphere. Refrigerant gases are commonly used in air conditioning/heat pump systems as part of the mechanical cooling/heating cycle. Refrigerant gases may escape from the system due to various reasons such as equipment failure, poor installation, neglect during maintenance, and as part of final decommissioning. Fugitive emissions are rightly a concern, many refrigerants are potent greenhouse gases. For example, commonly used refrigerants like hydrofluorocarbons (HFCs) have a much higher global warming potential than carbon dioxide. Even small amounts can contribute significantly to global warming. How does the sector mitigate against fugitive emissions? It is not only good practice to mitigate against fugitive emissions refrigerant handling is also covered by several UK regulations and standards: The Fluorinated Greenhouse Gases Regulations 2015: This regulation implements the EU F-Gas Regulation in the UK, which aims to reduce emissions of fluorinated greenhouse gases (F-gases), including HFCs used as refrigerants. It requires companies that produce, supply, use, install, service, maintain or dispose of equipment containing F-gases to hold a company certificate issued by an approved certification body. Individuals carrying out these activities must also hold a qualification recognised by the Environment Agency. The Ozone-Depleting Substances Regulations 2015: This regulation implements the EU ODS Regulation in the UK, which aims to protect the ozone layer by controlling the production, supply, import, export, ownership, and use of ozone-depleting substances (ODS), including certain refrigerants. It requires companies that carry out these activities to hold a company certificate issued by an approved certification body. The Health and Safety at Work Act 1974: This act requires employers to ensure the health and safety of their employees and others who may be affected by their activities. This includes ensuring that refrigerants are handled safely. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) : These regulations require employers to assess the risks from hazardous substances, including refrigerants, and take appropriate measures to prevent or control exposure. British Standard BS EN 378: This standard specifies safety and environmental requirements in relation to the design, manufacture, installation, operation, maintenance and disposal of refrigerating systems and heat pumps. F-Gas Certification: Technicians who install, maintain or service stationary refrigeration equipment containing F-gases must hold a valid F-gas certificate issued by an approved certification body. Waste Management: The Environmental Protection Act 1990 and the Hazardous Waste Regulations 2005 require businesses to ensure that waste refrigerants are disposed of safely and responsibly. The legislation above illustrates that prevention of fugitive emissions is something that the industry is focused on and that the loss of refrigerant, other than through exceptional circumstances, is entirely preventable. Failure to comply with the applicable regulations can result in significant fines for responsible parties (beyond engineers and contractors). Therefore, it's crucial for landlords and building managers to ensure that the handling of refrigerants is done responsibly and in accordance with the law. The importance of Technical Asset Management in this regard should not be underestimated, site auditing is key to responsible building management, read more here . Including fugitive emissions within LCA reporting LCAs assess the environmental performance of a building and the outputs have numerous environmental indicators but are often collectively referred to as the amount of Carbon Dioxide equivalent (CO2e) emitted during the manufacture, transport, and construction of building materials, together with end-of-life emissions. BS EN 15978-1 provides a calculation methodology for the assessment of environmental performance of buildings. Whilst it is normal practice to include fugitive emissions within LCA reporting, it is also good practice that the reader is given guidance on their relevance, and importance, in understanding the buildings overall total environmental impact. Diligence should be taken to source manufacturers data, as an example, Daikin¹ recommend the following percentages for embedded carbon reporting: Refrigerant Recovery Efficiency = 99% Annual leakage rate = 2% of refrigerant charge Annual purge release factor = 0% Annual service release = 0% Probability factor for catastrophic failure = 0.001% This information confirms that: During refrigerant recovery, at end-of-life or because of repairs, gas lost is considered minimal and is associated with residual amounts (service engineers gauge lines). Industry studies show that correctly installed systems are not prone to refrigerant leaks. VRV systems do not require any purging of refrigerant, plus refrigerant purging is not permissible under UK and EU regulation. VRV leak checking as part of annual servicing can be done without ‘opening’ the refrigerant side of the system. Interestingly, Daikin Industries have carried out a study that shows that catastrophic failures on systems occur 1 in every 10,000 systems, there recommended 1 in every 1000 is a very conservative figure. In conclusion the reporting of fugitive emissions should be done with care, and reports should include explanatory notes. There are many factors when considering equipment selection, whilst embodied carbon is one of them it should form part of a holistic approach. A whole life carbon assessment (WLCA) standard can estimate the amount of carbon emitted throughout the life cycle of a constructed asset, from the early stages of development though to the end of life. It gives visibility to embodied carbon, operational carbon, and user carbon. Sources ¹ Daikin Pol01 BREEAM Calculation Default Values

The Technical Asset Management team at Resero oversees many areas, but at the heart of what we do is risk management. Our market-leading site audits are supported by tailored software that ensures consistent reporting whilst mitigating landlord risk. What is building statutory compliance in the UK?  Statutory compliance in non-domestic properties refers to the legal requirement for commercial buildings to adhere to certain laws, regulations, and standards. This is crucial in ensuring the safety, health, and welfare of the people who use these buildings and that the building complies with environmental regulations. Non-compliance can pose significant risks to insurance policies, the value of the property and of course the occupants’ health and wellbeing. The role of statutory compliance in non-domestic properties is multifaceted and includes the following:

If you're a tenant planning to make changes to your leasehold property, or a facilities manager of a multi-let property, it's crucial to understand the concept of License to Alter (LTA) and the importance of obtaining specialist M&E advice when approving tenant requests. In this technical guidance note, we delve into the significance of LTAs and why seeking specialist consultancy advice is paramount before proceeding with any alterations.  What is a License to Alter (LTA)? A License to Alter is an agreement between a tenant and a landlord granting permission for the tenant to carry out works on a leasehold property. It sets out the conditions under which the alterations may be carried out and ensures that no unexpected conflicts will arise as a result of the work. This agreement, held alongside the lease document, serves as a framework for future actions related to the property, including terminal schedules of dilapidations. Why is it important to seek specialist consultancy advice before approving an LTA? Facilities Managers play a pivotal role in ensuring tenants are accommodated while safeguarding the property's integrity. While it's essential to allow for and facilitate tenant alterations, it's equally important to mitigate any adverse impacts on other occupants, landlord services, and the property's Energy Performance Certificate (EPC) . Any works that involve electrical, or mechanical infrastructural changes should be approved through an LTA. The temptation might be to ‘save cost’ by reviewing the works without reference to an M&E specialist but the liability of risk will then fall upon the facilities management team if an issue arises later. Below we list some practical examples of why the LTA process requires an M&E consultant’s review.

In this blog our Projects Director, Joe Gubats, talks through some the latest legislation for maintaining sprinkler water tanks.  The lifespan of a sprinkler tank depends on various factors, in particular the quality of maintenance. On average a well-maintained sprinkler tank could last up to 30 years or more. The frequency of inspection depends on several factors, including, but not limited to, the size of the tank, its location, the type of water source, and of course, the type of sprinkler system installed. The LPC Sprinkler Rules for Automatic Sprinkler Installations is a comprehensive set of guidelines and standards that govern the design, installation, and maintenance of automatic sprinkler systems in the United Kingdom. This standard incorporates the full BS EN 12845:2015+A1:2019 standard, this is a European standard that specifies the requirements and methods for the design, installation, and maintenance of fixed firefighting systems. The LPC Sprinkler Rules are updated regularly with new Technical Bulletins to ensure they reflect the latest best practices and technological advancements in the field of fire protection. These bulletins provide detailed guidance on specific aspects of sprinkler system design and installation, such as pipe sizing, pump selection, water supply requirements, and system testing procedures. In addition to these technical requirements, the LPC Sprinkler Rules also include provisions for quality assurance and documentation. For example, they require that all work be carried out by competent personnel and that detailed records be kept of all system design calculations, installation work, and maintenance activities. By adhering to these rules and bulletins, building owners and operators can ensure that their sprinkler systems can provide effective fire protection. Moreover, compliance with these standards can also help to satisfy legal requirements and insurance conditions related to fire safety. Resero's Technical Asset Management audits ensure that statutory requirements are met and that detailed records are being kept. The Loss Prevention Certification Board (LPCB) updated its Technical Bulletin 203 (TB203), which outlines the care and maintenance requirements for automatic sprinkler systems. Published in September 2022, this bulletin now mandates a fully detailed 'Inspection/Condition Report' as part of the two-yearly routine, also known as the TB203 2-year inspection. Download a copy here . The Inspection/Condition Report is a comprehensive document that provides an in-depth assessment of the condition of the automatic sprinkler system. It is designed to ensure that the system is functioning correctly and efficiently, and that it meets all relevant safety standards and regulations. The report should include a thorough examination of all components of the sprinkler system, including but not limited to: Sprinkler heads: These should be checked for any signs of damage, corrosion, or obstruction that could prevent them from operating correctly. Piping: The pipes should be inspected for any signs of leakage, corrosion, or other damage. The report should also confirm that the pipes are correctly sized and installed. Control valves: These should be checked to ensure they are in the correct position and functioning properly. Water supply: The report should confirm that there is an adequate water supply for the sprinkler system, and that the pressure is sufficient. Alarm devices: These should be tested to ensure they are working correctly. Fire pumps: If present, these should be inspected and tested to confirm they are operating correctly. Records: The report should include a review of the maintenance records for the sprinkler system, to confirm that all necessary maintenance has been carried out. In addition to these specific checks, the Inspection/Condition Report should also include a general assessment of the overall condition of the sprinkler system, and any recommendations for repairs or improvements. The introduction of this requirement reflects the LPCB's commitment to ensuring that automatic sprinkler systems are maintained to the highest possible standard, in order to provide effective fire protection. It is therefore essential that all those involved in the commercial building industry are aware of this requirement and take steps to comply with it.

Be careful wise ones, "The wise man is one who knows what he does not know". The ‘Socratic paradox’, recognises that those that appear wise understand that neither they, nor anyone else, truly knows everything. Our judgements and opinions are formed from our interpretations of the world around us, but those interpretations are ultimately rooted in observations, formed by our own unique experience. Experience is fundamentally subjective, susceptible to inaccuracy, and unique to the individual. Theologists extend the view that our knowledge, no matter how "objectively" it is formed, stems from subjective roots. Objectivity and practicality require standards and regulations to interpret our judgements and opinions, but what we determine as standards also ultimately reflects our wishes and values, even when embedded through scientific research. Our ‘wishes and values’ regarding environmental sustainability have led to an ever-increasing list of regulations, standards, and political machinations. Global warming and climate change are now predominant in the list of concerns of adults in the UK. When asked about a range of issues, climate change was the second biggest concern facing adults in Great Britain (74%), with the rising cost of living being the main concern (79%). In 1973, the EU Commission issued its first multi-annual Environment Action Programmes (EAPs) setting out planned legislative proposals and goals for EU environment policy. In May 2022, the 8th EAP entered into force, as the EU's legally agreed upon common agenda for environment policy until the end of 2030. Initial progress was slow but in recent times the acceleration has been exponential. Environmental Sustainability is now big business, employment in the EU environmental economy increased from 3.2 million FTE in 2000, to 5.1 million FTE in 2020. The environmental economy generated €828 billion output and €341 billion gross value added in 2020. So, we now have a whole industry focused on environmental sustainability with sustainability ‘engineers’ producing endless reports, setting new targets against a whole host of standards and regulations. Not a day, even an hour goes by without someone, somewhere, generating a report or article warning us that we must do better, that we must double our efforts and change our ways. It all adds to our personal eco-anxiety and results in an increasing need to be ‘seen’ to be doing something. That need is reflected in more reports and regulations. It could be viewed that we have created an industry that is la rgely doing little more than creating shades of greenwashing; reports generated without deliverable actions and measured outcomes are little more than ticking boxes to allow large corporates to meet regulatory reporting requirements. In the sector that we, Resero, operate within – commercial real estate consultancy – we must be careful to keep our own house in order. We need to avoid overstating our contribution to environmental change and avoid rolling good practice into false claims of ESG generated initiatives. The actions we recommend are actions that should be taken for the greater good, they should never be recommended so a box can be ticked on an ESG report. As our clients are increasingly making their goals and commitments public, we need to be watchful that we are not complicit in committing the type of greenwashing infringements that could be seen as 'shades’ of greenwashing. Not the greenwashing that is so obviously demonstrated in the many examples of false advertising, but that which is hidden under the all-encompassing ESG policy documents.