HRAI-AHRI Submit Comments to CSA’s SCOPEER Committee on EXPO7:22
On September 23, 2021, BC Hydro, Manitoba Hydro, and Hydro-Québec submitted a project proposal form (PPF) on EXP07:22, referred to simply as EXP07, to CSA’s Performance, Energy Efficiency, and Renewables (SCOPEER) Standards Committee.
The proponents of the project are seeking to move EXPO7, a load-based, climate-specific testing and rating procedure for heat pumps and air conditioners, “from a voluntary, non-accredited standard … to a national standard.”
“EXP07 uses a dynamic, load-based approach that measures a system’s performance across a wide range of outdoor temperatures, while meeting heating and cooling requirements that are typical for residential applications, using its own thermostat and internal control logic.”
“In this way, the lab environment during the test process is as close to a real-life installation in a house as it can be, while still being carefully controlled so that each test can be both consistent in its results, and provide fair performance comparisons between different models.”
EXP07 is a highly technical testing and rating procedure. For a simplified summary of the procedure, members can consult the Northwest Energy Efficiency Alliance (NEEA) plain language guide to EXPO7.
The proponents argue that current efficiency metrics, HSPF, SEER, and EER are not representative of what is currently available on the market. Moreover, current testing and rating procedures for air conditioners and heat pumps, i.e., CSA C656 (Canada) and AHRI 210/240 (USA), are outdated and do not represent the growing market for variable-capacity and cold-climate heat pump technology.
While industry recognizes the growing interest in load-based testing and rating procedures, following extensive discussions with members, HRAI and AHRI submitted comments to SCOPEER requesting a temporary pause on the accreditation process to address specific concerns raised by members as well as additional time to consider the efficacy of other competing load-based testing and rating procedures currently in development.
The specific concerns are as follows:
- The repeatability, reliability, and reproducibility of the test procedure;
- The selection of EXP07 as a seed document prior to the evaluation of other alternative test methodologies to address the concern of representativeness; and
- The fact that EXP07 currently does not address non-tested combinations or coil-only combinations, which would severely limit customer choice options that currently exist under AHRI 210/240. Until a load-based test procedure considers these combinations, it cannot be considered a replacement for AHRI 210/240.
Despite raising these concerns with the committee, SCOPEER recently voted in favour to move forward with the accreditation process.
Members should take note that the process will take several years before EXPO7 becomes a fully accredited national standard.
The comments can be found here.
For more information, contact Stephen Chartrand at 1-800-267-2231 ext. 276, or email schartrand@hrai.ca.
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