HRAI Seeks Member Input on Amendments 18 and 19.
In April 2022, NRCan announced its intent to introduce Amendments 18 and 19 to Canada’s Energy Efficiency Regulations. The pre-publication of the amendments in Canada Gazette, Part I is expected sometime early 2023, which will launch the official 70-day public comment period.
As members may recall, HRAI and AHRI submitted joint comments (attached below) on the proposed technical bulletins on September 15, 2022. With 2023 around the corner, HRAI is seeking further member input to help the industry prepare for the next round of regulatory amendments to Canada’s Energy Efficiency Regulations.
Amendments 18 and 19 will update testing procedures and/or energy efficiency standards for 19 currently regulated products and will introduce requirements for seven new products. This includes three-phase central air conditioners and central heat pumps and large air conditioners and large heat pumps.
Updating Currently Regulated Products
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Adding a New Product Category
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Refrigerators
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Clothes Dryers (Vented Gas)
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Combination Refrigerator-Freezers
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Uninterruptible Power Supplies
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Freezers
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Pool Pumps
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Clothes Washers
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Showerheads
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Integrated Clothes Washer-Dryers
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Faucets
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Clothes Dryers
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Dishwashers
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Portable Air Conditioners
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Electric Water Heaters
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Room Air Conditioners
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Battery Chargers
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External Power Supplies
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Gas-Fired Water Heaters
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Oil-Fired Water Heaters
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Ice Makers (Automatic Commercial)
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Large Air Conditioners and Heat Pumps
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General Service Lighting
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General Service Fluorescent Lamps
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Metal Halide Lamp Ballasts
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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 three-phase central air conditioners and central heat pumps, NRCan intends to align 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 also planning to reference ANSI/AHRI 210/240-2023 – 2023 Standard for Performance Rating of Unitary Air-Conditioning & Air-Source Heat Pump Equipment as the test standard.
The energy efficiency standards under consideration for three-phase central air conditioners and three-phase central heat pumps are summarized in the table below.
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.
ENERGY EFFICIENCY STANDARDS FOR THREE-PHASE CENTRAL HEAT PUMPS
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PRODUCT TYPE
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PRODUCT SUBCATEGORY
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SEER2a ENERGY EFFICIENCY
STANDARD IN THE U.S. AND CANADA
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HSPF2b (CLIMATE
REGION IV) ENERGY
EFFICIENCY STANDARD IN THE U.S.
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HSPF2 (CLIMATE REGION V) ENERGY EFFICIENCY
STANDARD IN CANADA
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AC’s other than those that are space constrained or small-duct-high-velocity with a cooling capacity less than 65,000 Btu/hr
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Split System/Single Package
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13.4
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Heat pumps other than those that are space constrained or small duct-high-velocity with a cooling capacity less than 65,000 Btu/hr
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Split system
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14.3
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Single package
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13.4
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Space-constrained AC’s with a cooling capacity less than 30,000 Btu/hr
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Split system
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12.7
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Single package
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13.9
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7.0
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5.6
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Space-constrained heat pumps with a cooling capacity less than 30,000 Btu/hr
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Split system
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13.9
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6.7
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5.4
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Single package
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13.9
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Small-duct, high-velocity air conditioners with a cooling capacity less than 65,000 Btu/hr
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Split system
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13.0
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Small-duct, high-velocity heat pumps with a cooling capacity less than 65,000 Btu/hr
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Split system
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14.0
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6.9
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5.5
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a Represents seasonal energy efficiency ratio 2.
b Represents heating seasonal performance factor 2.
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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 amending the regulations for large air conditioners and 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 heat pumps that are air-cooled.
The regulatory amendments would only apply to large air conditioners and large heat pump 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” 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 also 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.
The energy efficiency standards under consideration for large air conditioners and large heat pumps are summarized in the tables below.
ENERGY EFFICIENCY STANDARDS FOR AIR-COOLED LARGE AIR CONDITIONERS
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Cooling Capacity
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Heating Type
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Efficiency Level
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≥ 19 kW and < 40 kW (≥ 65,000 and < 135,000 Btu/h)
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Either without a heating section or with
an electric heating section
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EERa ≥ 11.2
IEERb ≥ 14.8
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With a heating section other than an
electric heating section
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EER ≥ 11.0
IEER ≥ 14.6
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≥ 40 kW and < 70 kW (≥ 135,000 and < 240,000 Btu/h)
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Either without a heating section or with
an electric heating section
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EER ≥ 11.0
IEER ≥ 14.2
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With a heating section other than an
electric heating section
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EER ≥ 10.8
IEER ≥ 14.0
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≥ 70 kW and < 223 kW (≥ 240,000 and < 760,000 Btu/h)
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Either without a heating section or with
an electric heating section
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EER ≥ 10.0
IEER ≥ 13.2
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With a heating section other than an
electric heating section
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EER ≥ 9.8
IEER ≥ 13.0
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a Represents the energy efficiency ratio, which is the ratio of the produced cooling effect of an air conditioner or heat pump to its net work input, expressed in kW (Btu/watt-hour).
b Represents the integrated energy efficiency ratio, expressed in British thermal units per watt hour, that constitutes a single number cooling part-load efficiency metric of a large air conditioner.
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ENERGY EFFICIENCY STANDARDS FOR AIR-COOLED LARGE HEAT PUMPS
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Cooling Capacity
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Heating Type
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Efficiency Level
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≥ 19 kW and < 40 kW (≥ 65,000 and < 135,000 Btu/h)
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Either without a heating section or with an
electric heating section
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EERa ≥ 11.0 Heating coefficient of
performance ≥ 3.4 with 8.3°C inlet air and ≥ 2.25 with -8.3°C inlet air IEERb ≥ 14.1
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With a heating section other than an electric
heating section
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EER ≥ 10.8 Heating coefficient of performance ≥ 3.4 with 8.3°C inlet air and ≥ 2.25 with -8.3° inlet air IEER ≥ 13.9
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≥ 40 kW and < 70 kW (≥ 135,000 and < 240,000 Btu/h)
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Either without a heating section or with an
electric heating section
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EER ≥ 10.6 Heating coefficient of
performance ≥ 3.3 with 8.3°C inlet air and ≥ 2.05 with -8.3°C inlet air IEER ≥ 13.5
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With a heating section other than an electric
heating section
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EER ≥ 10.4 Heating coefficient of
performance ≥ 3.3 with 8.3°C inlet air and ≥ 2.05 with -8.3°C inlet air IEER ≥ 13.3
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≥ 70 kW and < 223 kW ≥ 240,000 and < 760,000 Btu/h
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Either without a heating section or with an
electric heating section
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EER ≥ 9.5 Heating coefficient of
performance ≥ 3.2 with 8.3°C inlet air and ≥ 2.05 with -8.3°C inlet air IEER ≥ 12.5
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With a heating section other than an electric
heating section
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EER ≥ 9.3 Heating coefficient of
performance ≥ 3.2 with 8.3°C inlet air and ≥ 2.05 with -8.3°C inlet air IEER ≥ 12.3
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a Represents the energy efficiency ratio, which is the ratio of the produced cooling effect of an AC or HP to its net work input, expressed in kW (Btu/watt-hour).
b Represents the integrated energy efficiency ratio, expressed in British thermal units per watt hour, that constitutes a single number cooling part-load efficiency metric of a large heat pump.
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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.
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.
Members wishing to provide input or would like more information about Amendments 18 and 19, please contact Stephen Chartrand at 1-800-267-2231 ext. 276, or email schartrand@hrai.ca.
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