AHRI-HRAI Submit Comments on Amendments 18 and 19 to Canada’s Energy Efficiency Regulations

In April 2022, Natural Resources Canada announced its intent to launch Amendments 18 and 19 to Canada’s Energy Efficiency Regulations.

Members can find the comments here: PDF 1 & PDF 2.

The amendments will update testing procedures and/or energy efficiency standards for 19 currently regulated products and will introduce requirements for 7 new products.

This includes 3-phase central air conditioners and central heat pumps and large air conditioners and large heat pumps that are air-cooled.

Between June 22 and June 30, 2022, NRCan held a series of webinars to initiate the pre-consultation phase for the amendments.

On amending the regulations for 3-phase central air conditioners and central heat pumps, NRCan is considering aligning testing standards with the U.S. DOE with the following adjustments to account for cold climate conditions in Canada:

  • The optional -15°C (5°F) test point in the US DOE test procedure would become mandatory in Canadian regulations.
  • The HSPF2 metric that is used to evaluate compliance would be based on Climate Region V (for calculation of the performance metric in the test standard).

NRCan is considering referencing ANSI/AHRI 210/240-2023 – 2023 Standard for Performance Rating of Unitary Air-Conditioning & Air-Source Heat Pump Equipment to serve as the test standard.

Canadian HSPF2 energy efficiency standards for Climate Region V have been converted from U.S. HSPF2 energy efficiency standards for Climate Region IV, based on minimum performance levels expected for units tested to temperature test points required in the testing standard and the additional -15°C (5°F) test point.

NRCan is not considering any changes to labelling, verification, or importing requirements for 3-phase central air conditioners and central heat pumps.

The energy efficiency report required for three-phase central air conditioners and three-phase central heat pumps would include the following information:

  • SEER2.
  • Rated cooling capacity.
  • HSPF2 for Climate Region V and rated heating capacity at 8.3oC (47oF) for heat pumps.

In addition, the energy efficiency report would require the following information to be reported for three-phase central heat pumps:

  • Rated capacity at -15°C (5°F).
  • COP at -15°C (5°F).

On June 11, 2022, AHRI-HRAI submitted its final round of comments on Amendment 17 to Canada’s Energy Efficiency Regulations for single-phase central air conditioners and central heat pumps less than 19 KW.

In those comments, we requested NRCan to reconsider its proposal to mandate low temperature testing for single-phase products and instead limit low temperature testing to variable speed products with an effective date of January 1, 2025. 

In our latest round of comments to NRCan on Amendments 18 and 19, submitted September 15, 2022, we argued that it would be most appropriate for NRCan to harmonize the three-phase products with the single-phase products with the standards in the U.S. with an effective date of January 1, 2025.

On amending the regulations for large air conditioners and large heat pumps, while NRCan is currently aligned with U.S. DOE Tier 1, it is considering aligning energy efficiency standards, testing standards, and manufacturing dates with U.S. DOE Tier 2 for large air conditioners and large heat pumps that are air-cooled.

NRCan defines a large air conditioner as “a commercial or industrial unitary air conditioner with a cooling capacity of at least 19 kW (65,000 Btu/h) but less than 223 kW (760,000 Btu/h). It does not include a single package vertical air conditioner.”

And a large heat pump as a “a commercial or industrial unitary heat pump that is intended for air-conditioning and space-heating applications and that has a cooling capacity of at least 19 kW (65,000 Btu/h) but less than 223 kW (760,000 Btu/h). It does not include a single package vertical heat pump.”

NRCan is considering referencing Appendix A to Subpart F, Part 431 of Title 10 to the U.S. Code of Federal Regulations, entitled Uniform Test Method for the Measurement of Energy Consumption of Air-Cooled Small (≥65,000 Btu/h), Large, and Very Large Commercial Package Air Conditioning and Heating Equipment to serve as the test standard.

NRCan is not considering any changes to labelling, verification, importing, or the energy efficiency report requirements for air-cooled large air conditioners and heat pumps.

In our comments on large air conditioners and large heat pumps, AHRI-HRAI firmly opposed NRCan’s proposal to require for large heat pumps a heating coefficient of performance at -8.3°C (17.06°F) given that there are no third party labs in the United States capable of testing equipment to that low temperature.

While we understand and appreciate NRCan’s commitment to ensuring HVACR equipment will function reliably in cold climate conditions, this is simply not feasible when industry lacks the infrastructure to secure that commitment for the Canadian market.

Furthermore, the United States only regulates the heating efficiency standard at 8.3°C (46.94°F). Mandating manufacturers to comply with an additional regulation as proposed at -8.3°C (17.06°F) would be both burdensome and unnecessary.

We requested NRCan to reconsider their proposed amendment and instead only require manufacturers of air-cooled large heat pumps to comply with a performance rating only at 8.3°C (46.94°F), and not -8.3°C (17.06°F).

The pre-publication of the amendments in Canada Gazette, Part I is expected sometime in 2023.

This will launch an official 70-day public comment period.

The exact date for final publication of the amendments in Canada Gazette, Part II will depend on the number and nature of comments received during the public comment periods, but are typically within a year of the initial public comment period.

If you have any questions or concerns, please contact Stephen Chartrand at 1-800-267-2231 ext. 276, or email schartrand@hrai.ca.

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