NRCan Clarifies Amendment 17 for Members

On April 20, 2022, Natural Resources Canada (NRCan) delivered a presentation on Amendment 17 to members of AHRI’s Unitary Regulatory Committee (URC).

As members may be aware, on April 2, 2022, NRCan published proposed minimum energy efficiency standards and updated test procedure regulations for residential and light commercial single-package and split-system central air conditioners and central heat pumps in Canada Gazette Part I, Amendment 17 to Canada’s Energy Efficiency Regulations.

The formal comment period will conclude June 11, 2022. The final regulations are expected to be published in the fall in Canada Gazette, Part II.

Central air conditioners and central heat pumps include single package, split system (single-split, multi-head mini-split, mini-split including variable refrigerant flow (VRF), multi-circuit systems), ducted, ductless, space-constrained, and small-duct, high-velocity air conditioners and heat pumps. The Amendment 17 regulatory proposal is for single-phase units.

While the primary purpose of Amendment 17 is to align Canadian requirements with new energy efficiency and testing standards in the United States, (specifically Appendix M1) that take effect January 1, 2023, NRCan is seeking the following adjustments in its proposal to ensure products coming into Canada will function reliably in cold climate conditions:

  • The optional -15oC (5oF) test point in the U.S. 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).

The proposed efficiency standards are as follows:

PRODUCT CLASS

SEER2 MEPs in the U.S. and Canada

HSPF2 (Region IV) MEPs in the U.S.

HSPF2 (Region V) MEPs in Canada

(i)(A) Split systems – air conditioners with a certified cooling capacity less than 45,000 Btu/hr

13.4

 

 

(i)(B) Split systems – air conditioners with a certified cooling capacity equal to or greater than 45,000 Btu/hr (and less than 65,000 Btu/hr)

13.4

 

 

(ii) Split systems – heat pumps

14.3

7.5

6.0

(iii) Single-package units – air conditioners

13.4

 

 

(iv) Single-package units – heat pumps

13.4

6.7

5.4

(v) Small-duct, high-velocity systems

12

6.1

4.9

(vi)(A) Space-constrained products – air conditioners

11.7

 

 

(vi)(B) Space constrained products – heat pumps

11.9

6.3

5.0

While there will be no changes to labelling or verification requirements, Amendment 17 would introduce additional reporting requirements for heat pumps. These include the HSPF2 for Region V and heating capacity for heat pumps, the COP at -15oC (5oF) at rated capacity, and the rated capacity at -15oC (5oF).

At the URC meeting, members voiced concerns that NRCan’s deviations from Appendix M1 could lead to significant testing and compliance issues, which might affect product availability in Canada.  On March 10 and June 7, 2021, HRAI and AHRI submitted joint comments advising NRCan to reconsider its position and harmonize with Appendix M1.   

Following member input at the URC, HRAI and AHRI intend to submit another set of joint comments to NRCan in response to the regulatory proposal.  HRAI will provide members regular updates on its engagement with NRCan and Amendment 17 during the formal comment period.

Members can submit comments through the Canada Gazette, Part 1 website.

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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