Building technical systems control: increased oversight

Since 2023, commercial buildings must enhance the management of their technical systems via BACS. New obligations, controls, and deadlines to be aware of.

Olivier Daucet
Consultant HSE
Publication : 
24.05.2023
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

‍Since 2021, certain buildings housing commercial activities must be equipped with a building automation and control system (Building automation and control systems – BACS) when technically and economically feasible.

Such a system must, in particular, enable:

  • continuously monitoring, recording, and analyzing energy production and consumption data from the building's technical systems (e.g., heating, cooling, ventilation, lighting, etc.) and then adjusting their operation accordingly;
  • detecting energy efficiency losses in the building's technical systems;
  • Informing the operator of potential energy efficiency improvements for these systems.

The scope of this obligation has been expanded and supplemented by a decree and an order dated April 7, 2023.

What is the objective?

The objective is to better manage energy in commercial buildings in a context of energy sobriety and rising energy costs.

Which buildings are affected & what are their obligations?

The obligation to install an automation and control system applies to new and existing buildings:

  • in which commercial or non-commercial tertiary activities are conducted, including those belonging to legal entities (businesses, associations, etc.) from the primary (agriculture) or secondary (industries) sectors,
  • AND equipped with a heating system or an air conditioning system, combined or not with a ventilation system, whose useful nominal power is greater than 70 kW (instead of 290 kW).

It falls to the owner of the building's heating or air conditioning systems.

Note: for buildings where heat or cold generation is produced by heat or cold exchange with a district heating or cooling network, the generator power to be considered is that of the exchange station.

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Rated useful output of the heating or air-conditioning system, combined or not with a ventilation system Deadline for installing the building automation and control system Possible exemption from installing the building automation and control system Connection of technical systems to the building automation and control system
• Existing tertiary (commercial/office) buildings • Over 290 kW • 1 January 2025 • Where a study establishes that installing a building automation and control system is not feasible with a payback period of under 10 years (instead of 6 years) • The heating and/or air-conditioning system(s), combined or not with a ventilation system, with a rated useful output > 290 kW
• Technical systems* for which connection is feasible with a payback period of under 10 years (instead of 6 years)
• Over 70 kW • When the heating or air-conditioning system is replaced
• By 1 January 2027 at the latest 		• Where a study establishes that installing a building automation and control system is not feasible with a payback period of under 10 years • The heating and/or air-conditioning system(s), combined or not with a ventilation system, with a rated useful output > 70 kW
• Technical systems* for which connection is feasible with a payback period of under 10 years
• Construction of a new tertiary (commercial/office) building • Over 290 kW • Permit filed after 21 July 2021 • Where a study establishes that installing a building automation and control system is not feasible with a payback period of under 10 years (instead of 6 years) • In these buildings, all technical systems* are connected to the building automation and control system
• Over 70 kW • Permit filed after 8 April 2024 • Where a study establishes that installing a building automation and control system is not feasible with a payback period of under 10 years • In these buildings, all technical systems* are connected to the building automation and control system

* Building technical system: any technical equipment for space heating, space cooling, ventilation, domestic hot water production, built-in lighting, building automation and control, on-site electricity generation for a building or building unit, or combining several of these systems, including systems using renewable energy.

What checks are required for these systems?

Building automation and control systems are subject to:

  • Periodic checks

These checks are carried out by an external service provider or competent internal staff. Written instructions must specify the frequency of operations, the points to be checked, and provide for the rapid repair or replacement of faulty components.

These instructions are communicated to the building automation and control system manager.

  • Periodic inspection

At the owner's initiative, building automation and control systems must be inspected at least every 5 years.

This interval can be reduced to 2 years when:

  • an automation and control system is installed or replaced;
  • one of the technical systems connected to this automation and control system is installed or replaced.
The inspection includes:
  • an on-site visit of the accessible parts of the building automation and control system and the technical systems present in the building. This visit must take place on a partially or fully operational installation;
  • a document review, focusing in particular on the general information of the building and the inspected system;
  • a compliance assessment of the system's various functions;
  • providing recommendations on the proper use of the existing system and possible improvements

For systems in place as of April 8, 2023, the first inspection must take place no later than1st January 2025.

Are exemptions from checks/inspections possible?

Technical systems connected to a building automation and control system are exempt from:

  • the periodic energy efficiency check of boilers (excluding ICPE) with a power output between 400 kW and 20 MW;
  • the pollutant emissions check for boilers (excluding ICPE) with a power output exceeding 400 kW;
  • the periodic inspection requirement for thermodynamic systems with a power output exceeding 70 kW.

Conclusion

We invite you to review the situation with your department responsible for the maintenance of your heating and air conditioning systems in order to:

  • determine the necessity of equipping yourselves with an automation and control system if you do not have one and are subject to the obligation;
  • plan for the inspection of this system.

Construction and Housing Code Articles R. 175-1 to R. 175-9 / Amended by Decree No. 2023-259 of April 7, 2023 [Official Journal of April 8, 2023]

Order of April 7, 2023, relating to automation and control systems for tertiary buildings [Official Journal of April 8, 2023]

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Photo credit: 564486980 @bancha