HRAI seeks Member Input on Amendment 17

On February 9, 2022, HRAI provided members of AHRI’s Unitary Regulatory Committee a status report on Amendment 17.

As members may be aware, on January 10, 2022 NRCan informed HRAI that Spring 2022 is the intended date to pre-publish Amendment 17 in Canada Gazette, Part I. This will launch an official 70-day public comment period during which NRCan will also publish the results of its spring/summer 2021 pre-consultation phase.

The information package will include a series of market studies, comments received to date, and a cost benefit analysis of aligning Canadian energy efficiency standards with U.S. DOE Appendix M1, which are set to come into force January 1, 2023.   

Amendment 17 is part of NRCan’s 2021-2023 Forward Regulatory Plan. Once implemented, it will introduce new performance metrics and prescribe more stringent minimum energy performance standards for single-phase central air conditioners and heat pumps. 

As noted in the May 2021 technical bulletin attached to Amendment 17, NRCan is intending 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 in which members strongly recommended complete regulatory harmonization and urged 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.

Although 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.

While HRAI, alongside AHRI and member manufacturers, has been actively engaged with NRCan on this proposed amendment over the past year, there is still opportunity for members to weigh in, both during and in the lead-up to the official comment period.

Member input will ensure HRAI is well-prepared to comment on the regulatory package when it is pre-published.

Members can forward their ideas or comments to Stephen Chartrand at 1-800-267-2231 ext. 276, or email schartrand@hrai.ca

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