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ScienceDirect Procedia Environmental Sciences 38 (2017) 704 – 712

International Conference on Sustainable Synergies from Buildings to the Urban Scale, SBE16

Review of the Greek Legislative Framework for Ground Source Heat Pumps (GSHPs) and Suggestions for its Improvement S.C. Karytsasa,* and I.P. Chaldezosa a

Center for Renewable Energy Sources and Saving / Geothermal Energy Department, 19th km Marathonos Av., Pikermi 19009, Greece

Abstract The current paper presents an overview of the Greek legislation which is directly or indirectly related to ground source heat pump (GSHP) systems. The legislative acts which concern, among others, geothermal potential, shallow geothermal energy, installation of heating/cooling systems and domestic hot water production, use of surface water or groundwater, heat pumps, development of renewable energy sources (RES), energy related products and energy efficiency of buildings are outlined in this study. Furthermore, the relevant European directives and decisions with which the Greek legislation has been harmonized are presented. The Greek legislative framework for the development of GSHPs has been improved over time mainly due to the relevant European directives and decisions; however further improvements and developments are required. Therefore, changes regarding the legislative framework involving the licensing process for the installation of GSHP systems are recommended, concerning: a) system definition, b) installation specifications, c) clarification of responsibilities of involved departments, d) technical issues and e) simplification of the process. © Published by Elsevier B.V. This ©2017 2017The TheAuthors. Authors. Published by Elsevier B.V.is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/4.0/). Peer-review under responsibility of the organizing committee of SBE16. Peer-review under responsibility of the organizing committee of SBE16. Keywords: Ground source heat pump; Heating / cooling; Legislative framework; Greek legislation

1. Introduction Ground source heat pump (GSHP) technology utilizes the relatively constant temperature of the ground or water to provide heating and cooling of buildings and domestic hot water (DHW) throughout the year [1-16]. During the winter, a GSHP carries thermal energy from the ground or groundwater to provide space heating. During the summer the energy transfer is reversed, with the ground or groundwater absorbing thermal energy from the building, in order to cool it. GSHPs are the key to the exploitation of the unlimited shallow geothermal energy resources, as they can be used almost anywhere, since they do not require the existence of geothermal resources (existence of hot water or steam) [2,3,5,9-11,14,16-20]. GSHP systems can be used from small residential buildings up to large individual buildings and complexes (offices, hotels, schools, shopping centers, etc.) [11,21].

* Corresponding author. Tel.: +30-210-660-3282; fax: +30-210-660-3301. E-mail address: [email protected]

1878-0296 © 2017 The Authors. Published by Elsevier B.V. This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/4.0/). Peer-review under responsibility of the organizing committee of SBE16. doi:10.1016/j.proenv.2017.03.152

S.C. Karytsas and I.P. Chaldezos / Procedia Environmental Sciences 38 (2017) 704 – 712

There are several different options regarding the GSHP systems types; the initial separation is whether the system is open or closed loop, and whether the closed loop is installed in a horizontal or vertical arrangement [3,4,9-13,18,21-26]. Apart from the more common system types mentioned above, many subcategories and variations exist, such as closed loop systems with inclined loops [27,28], standing column wells [2,7,9-11,23,26], direct expansion systems [11,29,30], systems with helical heat exchanger [31-33], systems using water from tunnels or mines [10,34,35] and hybrid systems [9,20,36,37] . The system type selected each time depends on the available land surface [3,4,11,13,38], the ground characteristics (composition, morphology, moisture, thermal properties, hydrogeological conditions, etc.) [3,4,11,13], whether water drilling is possible in the area [3,11,13] and the heating and cooling characteristics (loads, etc.) of the building/s [11]. These factors determine the most economical option for installation [4,11]. The first installations of GSHP systems took place more than 60 years ago in the United States [3,18,22], while in Europe countries leading the systematic adoption of the technology were Switzerland, Sweden, Germany and Austria [3,39]. During the last 15 years the countries with the largest markets are the United States and Canada in America; Germany, Switzerland, Austria, all the Scandinavian countries and France in Europe [6,11,17,18 22,40-47]. In Asia, some of the markets with the most significant growth are Japan, South Korea and China [6,24,48,-50]. The first pilot residential GSHP vertical closed system in Greece was installed in 1993 [51]. Since then, hundreds of systems have been installed throughout the country. The available information concerning the installed capacity and annual energy output of GSHP are summarized in Table 1, while it should be noted that in many cases the information presented in these reports is an estimate based on available data. Table 1. Data on Greek GSHP market 1999

2004

2007

2009

2012

2014

Installed capacity (MWt)

0.4

4

14

50

100

135

Produced energy (TJ / yr)

3.1

39.1

80

270

486

648

Capacity factor

0.25

0.31

0.18

0.17

0.15

0.15

Source [52-57]

The Greek GSHP sector presented a remarkable growth in the mid-2000s, with the installation of open and closed loop systems; in addition, seaside hotels operating only during the summer showed interest in cooling their facilities through the use of seawater [54]. According to the latest data, 61 % of installed capacity concerns open systems, 30 % vertical closed loop systems and 9 % horizontal closed loop systems (Figure 1) [57]. Factors contributing to the market’s development were: a) the increase of oil prices compared to the price of electricity, b) awareness of public and installers of heating/cooling systems and c) introduction of the licensing process for the installation of the systems (Law 3175/2003) [54,55].

Fig. 1. Types of GSHP systems in Greece in 2014, based on the installed capacity [57].

The development path that the market followed during the mid-2000s peaked around 2010. Since then, the sector shows a decline due to the economic recession and the stagnation of the construction industry [55,56,57]. Moreover, it should be noted that the GSHP market is largely dependent on the construction of new buildings, as opposed to the market of air source heat pumps, which can be installed during a simple renovation of a dwelling. Strong competition by natural gas is also a reason for the sector’s recession [56,57]. Other reasons of the market’s stagnation

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are the lack of a friendly investment environment (in contrast to e.g. natural gas technologies), as well as legislative barriers. The purpose of the current study is the presentation and analysis of the Greek legislative framework concerning GSHP systems; in addition, specific suggestions are made for its improvement. In this context the legislative acts that concern, among others, the geothermal potential, shallow geothermal energy, installation of heating/cooling energy systems, the use of surface or ground water, heat pumps, renewable energy sources (RES) development, energy related products and energy efficiency of buildings are presented. Furthermore, the relevant European Directives and Decisions are reported. It should be mentioned that the legislative framework is presented in a chronological order. 2. Presentation of the legislative framework The first time that geothermal energy is mentioned in the Greek legislation is in Article 2(1) of Legislative Decree 210/1973 [Government Gazette (GG) 277 A'] "Mining Code" [58], stating that natural steams (geothermal energy sources) are included in mineral resources that are considered mining minerals or ores. In Article 1 of Law 1474/1984 (GG 131 A') "Exploitation of geothermal potential" [59], definitions of "geothermal potential", "geothermal energy" and "hot waters" are given, while in Article 4(2) it is stated that in the aforementioned legislative Decree 210/1973 the term "natural steams (geothermal energy sources)" is replaced by "geothermal potential". Shallow geothermal energy, i.e. the type of geothermal energy which GSHPs utilize and which according to the Greek legislation is not characterized as geothermal potential, is first mentioned in Law 3175/2003 (GG 207 A') "Exploitation of geothermal potential, district heating and other provisions" [60]. The main points of this law that concern GSHPs are the following: x Article 2(1)(a): "Geothermal potential includes all indigenous natural steams, surface or ground hot waters and heat of geological formations that are over 25 oC.". x Article 11(1): "The installation, for own use, of energy systems for space heating/cooling through the exploitation of heat from geological formations and waters (surface or ground), which are not characterized according to the provisions of this law as geothermal potential, is allowed after permission granted to the owner of the property by the prefectural administration.". x Article 11(2): "The specific terms, conditions, required documentation and the licensing procedure are set by decision of the Minister of Development.". The current applicable ministerial decree that is referred in Article 11(2) of Law 3175/2003 is Ministerial Decree Δ9Β,Δ/Φ166/οικ.13068/ΓΔΦΠ2488 of 2009 (GG 1249 B') "Installation licenses for own use of energy systems for heating/cooling of spaces through the exploitation of heat from geological formations and waters (surface or ground), which are not characterized as geothermal potential" [61], and includes: x Article 1: The purpose of this decree is to determine the terms, conditions, required documentation and procedures for the licensing of the GSHP system. The license is a unified license for the implementation/installation of the GSHP system and operation of the licensed installation. x Article 2: The terms "system", "closed loop system", "open loop system", "productive well" and "reinjection well" are defined. x Article 3: It is defined that the license is issued by the Department of Development of the Prefectural Administration to which the property belongs to, in favor of the owner or usufructuary of the property. x Article 4: The restrictions that must be taken into consideration regarding the installation and operation of the GSHP system are defined. The restrictions concern the cases of well drilling or trench opening, the use of surface or ground water and the certification of the pumps and systems. Specifically, regarding the use of surface or ground water, in order to issue a license the relevant provisions of Law 3199/2003 (GG 280 A') "'Water protection and management – Compliance with Directive 2000/60/EC of the European Parliament and Council of October 23, 2000" [62] and the Ministerial Decree οικ.150559 of 2011 (GG 1440 B') "Procedures, terms and


x x

x x x

707

conditions for the permit issuing of existing rights of water use" [63] have to be taken into account. It is worth mentioning specific restrictions of Article 4. In paragraph 1 of this article it is stated that in the case of a well drilling, this must be located at least: a) two meters from the property boundaries, b) five meters from existing neighboring buildings of different ownership, c) five meters from the boundaries of the expropriated railway zone, c) ten meters from main natural gas pipelines, d) five meters from main underground pipelines (water, sewerage, etc.), e) ten meters from high voltage electricity distribution lines —except if a building exists between the line and the well and f) five meters from medium voltage electricity distribution lines —except if a building exists between the line and the well. In addition, in paragraph 3 of the article it is clearly indicated that during the drilling of each well cementation must take place for at least the upper five meters, while steel tubing must be placed along the aforementioned length of the well’s inner wall. Article 5: The required documentation that must be submitted for the licensing of the GSHP system is specified. Article 6: The licensing procedure is described (Figure 2). It should be noted that the decree does not state the period of time required by the Administrative Region for the issuing of the installation license of the GSHP system. However, it is worth mentioning that in practice this time period usually ranges approximately between eight and twenty working days. Article 7: Cases that may require amendment of the licence are described. Article 8: Cases that can lead to penalty fees and license recall are mentioned. Article 9: It is specified that the present Ministerial Decree replaces the Ministerial Decree Δ9Β,Δ/Φ166/οικ.18508/5552/2077 of 2004 (GG 1595 B') [64].

It should be noted that under Law 3852/2010 (GG 87 A') "New architecture of local government and decentralized administration – Kallikratis program" [66] the responsibilities of the prefectural administration set out in Law 3175/2003 and Ministerial Decree Δ9Β,Δ/Φ166/οικ.13068/ΓΔΦΠ2488 of 2009 are from now on responsibilities of the respective administrative region. Law 3851/2010 (GG 85 A') "Acceleration of renewable energy sources development for the resolve of the climate change issue and other provisions on jurisdictional issues of the Ministry of Environment, Energy and Climate Change" [67] is important for the development of renewable energy in general and particularly of GSHPs. Some of the main points related to GSHPs, that complement or replace Articles of Law 3468/2006 (GG 129 A') "Production of electricity from renewable energy sources and cogeneration of electricity and heat of high performance and other provisions" [68] and Law 3661/2008 (GG 89 A') "Measures for the reduction of energy consumption in buildings and other provisions" [69] —as defined in each case— are: x Article 10(2): It is reported that before the construction of all new buildings a study on the installation of at least one alternative energy system should be conducted, among which heat pumps with SPF higher than 1.15*1/η belong, with "η" being defined as the ratio of total gross production of electrical energy to the primary energy consumption for electricity production, according to Directive 2009/28/EC. It is emphasized that until the "η" value is determined by law, SPF has to be higher than 3.3. x Article 10(3): It is specified that part of the needs in hot water —at least 60 % of annual needs— is obligatory to be provided by solar thermal systems, for all buildings with a construction license applied after 01/01/2011. However, this obligation does not apply if the needs are covered by other systems, including heat pumps with SPF consistent to paragraph 2 of the same article. x Another legislative act concerning, among others, GSHPs is Ministerial Decree Δ6/Β/οικ.5825 (GG 407 B') "Approval of regulations of energy performance of buildings" [70], adopted in the context of implementation of the corresponding obligations under Law 3661/2008. This decree sets the principle framework and defines the terms and conditions for the improvement of energy efficiency of buildings. x Additionally, a reference should be made on the legislation concerning the energy-related products (including heat pumps) on: a) ecodesign requirements setting and b) the indication of consumption of energy and other resources. Specifically: x The Presidential Decree 7/2011 (GG 14 A') [71], harmonizes the national legislation with Directive 2009/125/EC "Establishing a framework for the setting of ecodesign requirements for energy-related products" [72] and amends Presidential Decree 32/2010 (GG 70 A') [73], which had a relevant objective.

708


Fig. 2. Flow chart of license issuing procedure for GSHPs in Greece [65].

x The Ministerial Decree 12400/1108 of 2011 (GG 2301 B') [74] harmonizes the national legislation with Directive 2010/30/EU [75] concerning "The indication by labeling and standard product information of the consumption of energy and other resources by energy-related products". In paragraph 11 subparagraph 12 of Ministerial Decree 1264/2012 (GG 230 B') [76] it is specified that in order to issue an installation license for GSHP systems, a €300 payment fee is required. The first time that heat pumps, utilizing geothermal, aerothermal or hydrothermal energy, are recognized officially as RES is in Law 4062/2012 (GG 70 A') "Promotion of the use of energy from renewable sources" [77] which harmonizes the national legislation with Directive 2009/28/EC [78]. This law mentions the following, in relation to GSHP systems: x Article 15(2)(b): It is stated that geothermal energy is the energy stored in form of heat beneath the solid surface of the earth. x Article 16(3): What exactly is calculated as gross final energy consumption from renewable sources for heating and cooling is determined. In the amount of this energy, among others, geothermal energy which is captured by heat pumps is taken into account —provided that the final useful energy output significantly exceeds the primary energy needed to drive the heat pumps. This definition is based on paragraph 31 of the reasoning of Directive 2009/28/EC. x Annex 2: Presents the calculation methodology of the "Quantity of thermal energy captured by heat pumps which can be considered energy from renewable sources". Law 4122/2013 (GG 42 A') "Energy performance of buildings" [79], which harmonizes Greek legislation with Directive 2010/31/EU [80], states in Article 2(9) that " 'heat pump' means a machine, a device or installation that transfers heat from natural surroundings such as air, water or ground to buildings or industrial applications by reversing the natural flow of heat such that it flows from a lower to a higher temperature. For reversible heat pumps, it may also move heat from the building to the natural surroundings.". The aforementioned law replaces the definition given for a "heat pump" by Law 3661/2008 (GG 89 A') "Measures to reduce energy consumption in buildings and other provisions" [81], through which the Greek legislation was harmonized with Directive 2002/91/EC [82] . Decree 2013/114/EU [83] sets out the guidelines to EU member states regarding the calculation of energy from renewable sources provided by different heat pump technologies, in accordance to Article 5 of Directive


2009/28/EC (which corresponds to Article 16 of Law 4062/2012). Specifically, through this directive, the performance factor "η" of the system is set at 0.455 (or 45.5 %) —a value that should be used until 2020. The SPF for electric heat pumps is set at 3.2 for ground–air heat pumps and 3.5 for ground–water heat pumps. These values apply to warmer, middle and colder climates. The aforementioned values of "η" and SPF are used for: a) calculating the amount of energy from renewable sources which heat pumps provide and b) determining the minimum performance of heat pumps so that the power they generate can be considered as energy from renewable sources. In addition, the minimum SPF value for electrically driven heat pumps should be 2.5 in order for the energy generated by these heat pumps to be considered —according to the directive— as renewable energy. It should be noted that there is: a) a Corrigendum to Decision 2013/114/EU [84] which corrects certain values and b) no need for a law to harmonize national legislation with the Decision 2013/114/EU, since decisions are binding to those to whom they are addressed and are directly applicable [85]. It should be also mentioned that literature is available, either in the form of scientific articles or in the form of studies, regarding the comparative examination of legislative frameworks related to shallow geothermal energy between different countries or at a global or European level [44,86,87,88]. 3. Suggestions The implementation of revisions to the existing relevant legislative framework is among the main actions that can facilitate the development and diffusion of GSHP systems in Greece. Based on the principles of environmental protection, hygiene and safety rules, relevant technical parameters and best practices from countries with developed GSHP markets (e.g. Sweden, Germany, France, The Netherlands) [89] the following revisions are proposed in order to improve the current situation of GSHP market, thus contributing to the improvement of the Greek economy: x Reduction of the distance of the well from existing neighboring buildings of different ownership, from five meters to two meters. x Reduction of the distance of the well from underground main pipelines (water supply, sewage, etc.), from five meters to two meters. x Reduction of the distance of the well from main natural gas pipelines, from ten meters to five meters. x Reduction of the distance of the well from medium voltage electricity distribution lines, from five meters to two meters. x Clear separation between open and closed GSHP systems regarding their license issuing procedure. x Simplification of the license issuing of the installation of closed loop GSHPs (e.g. higher than 20 kW th and/or 20 kWc) in all types of applications. x Replacement of license issuing with a simple approval procedure for execution of technical works for the installation of closed loop GSHPs up to a specific capacity (e.g. 20 kWth and/or 20 kWc) in all types of applications. x Revision of certain definitions concerning GSHPs in order to approach —to the greatest possible extent— the scientific truth. x Provision of the possibility of inclined boreholes drilling. x Certification procedure of contractors and drillers for the execution of the technical works (based on ANNEX IV of Directive 2009/28/EC [78]); determination of the body/organization responsible for the certification of GSHP systems. x Possibility of exploiting surface water through GSHP systems (extraction from the sea, rivers, lakes, etc.) not only for public [90,91], commercial (hotels) [90,91] and industrial [90,91] uses or for other investments of strategic character [91,92], but for private [residential and commercial (apart from hotels)] use as well. x Provision at a national and local level of an overall development master plan for GSHP systems, i.e. a common database of geothermal heat exchangers, wells and GSHPs with all required specifications. At the same time, each interested citizen (planner, owner, usufructuary etc.) will be able to access this database through a website, either for informational – scientific reasons, or in order to interactively check if a GSHP licence can be issued for a specific location (based on GIS data).

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x Creation of a development plan and database for all underground networks (water, sewage, natural gas, etc.) at a national and local level, which will be connected to the relevant abovementioned database concerning GSHPs. 4. Conclusion The Greek legislative framework for the development of GSHPs has been improved over time mainly due to the relevant European directives and decisions; however further improvements and developments are required. Therefore, changes regarding the legislative framework involving permission process for the installation of GSHP systems are recommended, concerning: a) system definition, b) installation specifications, c) clarification of responsibilities of involved departments, d) technical issues and e) simplification of the process. The exploitation of shallow geothermal energy in Greece is considered necessary —primarily due to the economic recession of the country— as GSHP systems provide heating, cooling and domestic hot water in several types of applications, with clear economic, environmental, energy, social and aesthetic advantages compared to available non-conventional or conventional systems. "For of all studies, that of legal regulations, provided they be rightly framed, will prove the most efficacious in making the learner a better man". [Plato, Laws: 957c] References 1. Younis M, Bolisetti T, Ting DK. Ground source heat pump systems: current status. Int J Environ Stud 2010;67(3):405-15. 2. Huttrer GW. Geothermal heat pumps: An increasingly successful technology. Renew Energ 1997;10(2):481-8. 3. Fridleifsson IB. Direct use of geothermal energy around the world. GHC Bull 1998;December:4-9. 4. Meng L. The application of ground-source heat pump systems in China. Energ Manage A 2003;4:1610. 5. Kaygusuz K, Kaygusuz A. Geothermal energy in Turkey: the sustainable future. Renew Sust Energ Rev 2004;8(6):545-63. 6. Curtis R, Lund J, Sanner B, Rybach L, Hellström G. Ground source heat pumps–geothermal energy for anyone, anywhere: current worldwide activity. In: Proceedings World Geothermal Congress, Antalya, Turkey; 2005. p. 24-9. 7. Florides G, Kalogirou S. Ground heat exchangers – A review of systems, models and applications. Renew Energ 2007;32(15):2461-78. 8. Trillat-Berdal V, Souyri B, Achard G. Coupling of geothermal heat pumps with thermal solar collectors. Appl Therm Eng 2007;27(10):1750-5. 9. US Department of Energy Publications. Geothermal (ground-source) heat pumps: market status, barriers to adoption, and actions to overcome barriers. US: Hughes PJ; 2008. 10. Omer AM. Ground-source heat pumps systems and applications. Renew Sust Energ Rev 2008;12(2):344-71. 11. European Geothermal Energy Council (EGEC). Geothermal Heat Pumps – Ground Source Heat Pumps. EU: EGEC; 2009. 12. Milenić D, Vasiljević P, Vranješ A. Criteria for use of groundwater as renewable energy source in geothermal heat pump systems for building heating/cooling purposes. Energ Buildings 2010;42(5):649-57. 13. Rybach L. CO2 emission mitigation by geothermal development–especially with geothermal heat pumps. In Proceedings of the World Geothermal Congress; 2010. p. 4. 14. Johnston IW, Narsilio GA, Colls S. Emerging geothermal energy technologies. KSCE J Civ Eng 2011;15(4):643-53. 15. Bayer P, Saner D, Bolay S, Rybach L, Blum P. Greenhouse gas emission savings of ground source heat pump systems in Europe: a review. Renew Sust Energ Rev 2012;16(2):1256-67. 16. Karytsas C. Current state of the art of geothermal heat pumps as applied to buildings. Adv Build Energ Res 2012;6(1):119-40. 17. Fridleifsson IB. Geothermal energy for the benefit of the people. Renew Sust Energ Rev 2001;5(3):299-312. 18. Sanner B. Current status of ground source heat pumps in Europe. Paper presented at Futurestock 2003, Warsaw, Poland. 19. Rybach L, Eugster WJ. Sustainability aspects of geothermal heat pump operation, with experience from Switzerland. Geothermics 2010;39(4):365-9. 20. Sarbu I, Sebarchievici C. General review of ground-source heat pump systems for heating and cooling of buildings. Energ Buildings 2014;70:441-54. 21. Rafferty K. Geothermal heat pump systems: an introduction. Water Well J 2003;57(8):24-8. 22. Sanner B, Karytsas C, Mendrinos D, Rybach L. Current status of ground source heat pumps and underground thermal energy storage in Europe. Geothermics 2003;32(4):579-88. 23. Office of the Deputy under Secretary of Defense. Ground-source heat pumps at Department of Defense Facilities. US: Office of the Deputy under Secretary of Defense; 2007, January. 24. Lund JW. Geothermal heat pumps – an overview. GHC Q Bull;2001:22(1). 25. Sanner B. Shallow geothermal energy. GHC Bull 2001;22(3):19-25. 26. Schonder J. Geothermal heat pumps deliver big savings for federal facilities. Federal Energy Management Program, DOE/EE-0291; 2004, April. 27. Cui P, Yang H, Fang Z. Heat transfer analysis of ground heat exchangers with inclined boreholes. Appl Therm Eng 2006;26(11):1169-75.


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