HRAI Seeks Member Input on Amendment 17
As members may be aware, Natural Resources Canada intends to amend Canada’s Energy Efficiency Regulations to align single-phase central air conditions and heat pumps with DOE Appendix M1 test standards coming into force in the United States January 1, 2023.
The test standard will introduce new performance metrics and prescribe more stringent minimum energy performance standards.
However, as noted in the technical bulletin attached to Amendment 17, NRCan is willing to align with Appendix M1 with the following adjustments:
- 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).
On March 10 and June 7 2021, HRAI-AHRI submitted joint comments – attached below – in which members strongly recommended complete regulatory harmonization and advised NRCan to revise its position.
NRCan is seeking these adjustments to the regulations because it wants to assure Canadian consumers that products will function reliably in cold climate conditions.
While members understand and appreciate that position, they believe what NRCan is asking for will impose unnecessary cost and compliance burdens on industry and hinder consumer choice in the market.
With the conclusion of the pre-consultation phase, NRCan has indicated it will pre-publish Amendment 17 in Canada Gazette, Part I sometime this fall. This will launch an official 70-day comment period in which members will have the opportunity provide further expert comments on regulatory harmonization with Appendix M1 and NRCan’s stated positions to date.
While it is possible we won’t see the pre-publication of Amendment 17 until early next year, regardless, HRAI wants to ensure members are prepared for the official comment period should it launch this fall.
Members who would be interested in participating in a preparatory meeting in advance of the official comment period, please contact Stephen Chartrand at 1-800-267-2231 ext. 276, or email email@example.com
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