HRAI-AHRI Submit Comments on Amendments to Ontario’s and B.C.’s Energy Efficiency Regulations
On October 5, 2022, HRAI and AHRI submitted comments (see links below) on proposed provincial amendments to Ontario’s and B.C.’s energy efficiency regulations. The comments on B.C.’s proposed amendments were submitted jointly with AHRI.
Ontario’s Ministry of Energy proposed amendments to 18 products to harmonize its energy efficiency regulations with upcoming federal changes under Amendment 17 to Canada’s Energy Efficiency Act as well as DOE Appendix M1 requirements. These products included commercial gas furnaces, residential air conditioners and heat pumps, and geothermal liquid-to-air heat pumps.
On commercial gas-fired furnaces with an input of at least 65.92 kW (225,000 Btu/h) but not more than 117.23 kW (400,000 Btu/h) and commercial gas-fired furnaces with an input of more than 117.23 kW (400,000 Btu/h) but less than 2,930 kW (10,000,000 Btu/h), Ontario will its increase efficiency requirements to harmonize with DOE requirements coming into effect on January 1, 2023. The changes would take effect six months later on July 1, 2023.
The amendment will also increase efficiency requirements for split-system residential heat pumps and air conditioners, less than 19 kW (65,000 Btu/h) to harmonize with upcoming federal changes under Amendment 17. Ontario’s changes are proposed to take effect on July 1, 2023. Testing requirements for single-package residential heat pumps and air conditioners would also be updated to harmonize with proposed NRCan changes.
On geothermal liquid-to-air heat pumps, excluding direct expansion, Ontario will update efficiency requirements to harmonize O.Reg. 509/18 with ASHRAE 90.1-2016 minimums. The proposed amendment would take effect July 1, 2023.
In their joint comments, HRAI and AHRI strongly encouraged complete regulatory harmonization between Ontario and Canadian/U.S. federal energy efficiency standards.
The associations also requested a meeting with ministry officials to better understand Ontario’s position where there was a lack of clarity with proposed amendments to other product categories (i.e., computer room air conditioners, gas-fired floor furnaces, pool heaters, room heaters, wall furnaces, and instantaneous electric water heaters) to ensure changes do not cause market disruption, imposing unnecessary regulatory burdens on manufacturers, and/or risking trade restrictions that would ultimately harm Canadian consumers.
B.C.’s regulatory proposals were more straightforward. Only two products are effected, (single-phase split-system heat pumps and electric storage-type water heaters). The amendments will remove the energy performance standard for single-phase split-system heat pumps and redefine electric storage-type water heaters as household water heaters. HRAI-AHRI supported the proposed changes as both would ensure that B.C. is harmonized with federal energy efficiency standards once Amendment 17 comes into force. The proposed changes will take effect January 1, 2023.
To access HRAI’s submissions, click on the links below:
HRAI-AHRI Comments on Proposed Ontario Amendments
HRAI-AHRI Comments on Proposed BC Amendments (Heat Pumps)
HRAI-AHRI Comments on Proposed BC Amendments (Water Heaters)
If you have any questions or concerns, contact Stephen Chartrand at 1-800-267-2231 ext. 276 or email schartrand@hrai.ca.
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