Proposed Regulations for Electric, Gas-Fired and Oil-Fired Storage Water Heaters

Bulletin (Update) – August 2003

Revisions to the Minimum Energy Efficiency Levels of Water Heaters

Water heaters are prescribed as regulated products under Canada's Energy Efficiency Regulations (the Regulations), which came into effect in 1995. The Office of Energy Efficiency (OEE) of Natural Resources Canada (NRCan) proposes to amend the Regulations under which Canadian dealers would be required to comply with more stringent minimum energy performance standards for water heaters imported or shipped interprovincially for sale or lease in Canada.

In 2001, the first bulletin was issued to representatives of manufacturers, utilities and other stakeholders. In preparation for the regulation changes, CSA committees have been actively updating the test procedure standards. These meetings have been useful to discuss the proposed levels and implementation details. Updates were distributed by email in mid-2002 and April, 2003. Another update was posted and emailed in May of 2003.

Since the original posting in 2001, the following significant changes have been made:

The purpose of this document is to provide stakeholders with further information for meaningful consultation on the content of the Regulations before proceeding with pre-publication in the Canada Gazette. It addresses recent issues that have been raised, and is an update to previous bulletins.

Product Description

The regulations apply to storage water heaters as described as follows:

This regulation applies to natural gas and propane gas storage-type water heaters having an input of 75 000 Btuh (21.98 kW) or less and a storage capacity of 20–100 US gal. (76-380 L).

This regulation applies to oil-fired storage tank water heaters with an input rating of 107 000 kJ/hr. or 30.5 kW (0.75 USGPH) or less and manufacturer's specified storage capacity of 190 L (50 U.S. gal.) or less.

This regulation applies to electric storage tank water heaters with volumes of 50 to 454 L (11 to 100 imperial gal.).

Energy Performance Test Procedure

The test standard for gas equipment will be CAN/CSA-P.3-2003, "Testing Method for Measuring Energy Consumption and Determining Efficiencies of Gas-Fired Storage Water Heaters."

For electric water heaters, the test standard CSA-C191-00, "Performance of Electric Storage Water Heaters" will be used.

For oil-fired water heaters, the Energy Efficiency Regulations will reference the test standard CSA-B211-00.

These standards are all available from:

Canadian Standards Association
5060 Spectrum Way, Suite 100
Mississauga, ON  L4W 5N6
Tel.: 1 800 463-6727
In Toronto, call (416) 747-4000
Web site: http://csa.ca

Energy Efficiency Standards

Storage tank water heaters manufactured on or after the effective date must meet the maximum standby loss or minimum Energy Factor (EF) as defined by the equations in column 2 of Table 1. These equations are performance minimums that allow manufacturers some flexibility in how they meet the Energy Efficiency Regulations.

Table 1. Proposed Maximum Standby Loss or Minimum Energy Factor (EF) for Water Heaters

V = rated storage capacity in litres.
* supply pipe external to tank and connection near the bottom.

Labeling Requirements

EnerGuide labels are not required for these products. Water heaters must bear an energy performance mark indicating that the energy performance of the product has been verified by a certification organization accredited by the Standards Council of Canada.

Verification, Reporting and Importing Requirements

NRCan proposes no changes to the verification, reporting and importing requirements currently in place for this equipment.

The reporting requirements are provided on NRCan's Web site at oee.nrcan.gc.ca/regulations. Note that it is the responsibility of manufacturers and dealers to ensure that all models are reported to NRCan.

Effective Date

The effective date for all changes will July 1, 2004.

Discussion

The previous bulletins outlined NRCan concerns with the US DOE / CSA-C745 test method. Variability of test results and whether the test method provided results which were representative of bottom insulation levels were described. No additional technical information has been submitted to address these issues.

Two additional concerns with that US DOE test method have come to NRCan's attention. The US DOE test method will indicate higher efficiency levels if the lower element is placed higher in the tank. Raising the element would reduce the amount of hot water available in some situations and is a negative for homeowners and utilities renting electric water heaters. Secondly, the US DOE test method gives efficiency credit for pipe insulation. While insulating the pipes is significant and should be done, the use of pipe insulation is an installation issue and does not relate directly to the efficiency of the water heater.

Therefore, NRCan intends to retain the CSA-C191 test method which measures standby loss which is a representative measure of the tank efficiency.

In setting the performance requirements for electric water heaters, input has been provided by two manufacturers.

The upper set of equations was proposed by one manufacturer. NRCan compared verified product ratings from CSA International and found this efficiency level is already being achieved by a significant number of models.

Since CSA-C191 is a static test (no water draws), it does not measure the efficiency improvement due to bottom inlet of cold water. The equations differ by 5 watts, which is a conservative estimate of the savings due to this design.

There have been concerns from manufacturers about having enough lead time to meet the original January 20^th, 2004 date. The implementation date will be moved to July 1, 2004 for electric, gas and oil-fired water heaters.

Overall, the improved efficiency required by these changes to the EE Regulations will provide significant benefits to Canadians.

Economic, Energy and Greenhouse Gas (GHG) Emissions Analysis

NRCan uses a benefit-cost analysis to determine the economic attractiveness of improving the energy efficiency of water heaters. The net present value, calculated by subtracting the present value of the incremental costs from the present value of the incremental savings over the life of the product is chosen as the indicator of economic attractiveness. The base case analysis used a 7 percent social discount rate, as prescribed by the Treasury Board of Canada Secretariat and on Canadian average electricity prices that are based on NRCan's official energy supply and demand forecast (Canada's Energy Outlook 1992–2020: Update 1999).

Using average energy prices and the 7 percent discount rate, results were positive for the common sizes of water heaters.

Sensitivity analyses of the discount rate and energy prices were conducted. The sensitivity analyses yielded positive results for every scenario. This supports the case for increasing the stringency of the minimum energy performance standards for gas-fired and electric storage water heaters.

Energy and GHG savings were estimated by comparing the forecast energy use of the market for water heaters with and without the efficiency improvements. The proposed amendment is projected to save 2.48 PJ of energy and 0.16 Mt of GHG emissions in 2005 and 21.56 PJ of energy and 1.51 Mt of GHG emissions by 2020.

Comments Invited

This information bulletin is being issued in advance of pre-publication in the Canada Gazette to allow time for concerned parties to comment on the proposal. Further written comments on this proposal should be directed to:

Brian Killins
Senior Standards Engineer
Office of Energy Efficiency
Natural Resources Canada
1 Observatory Crescent, Building 1, 2^nd Floor
Ottawa ON  K1A 0E4
E-mail: bkillins{at}nrcan.gc.ca