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

Bulletin (Update) – May 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 May 2001, a bulletin was issued to more than 50 people, including representatives of manufacturers, utilities and other stakeholders. In preparation for the introduction of these changes, CSA committees have been actively updating the test procedure standards. These meetings have been useful to discuss the proposed levels and implementation details.

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 attempts to address key issues that have been raised. It is not intended to provide a definitive representation of the proposed regulations. This is an update to previous notices.

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 "Performance of Electric Storage Water Heaters" will be used to determine the standby loss.

Information about ongoing changes to these standards can be obtained from the Canadian Standards Association.

For oil-fired water heaters, the Energy Efficiency Regulations will reference the 2000 version of the test standard CSA-B211.

These standards are all available from

These standards may be purchased on-line at www.csa.ca.

Energy Efficiency Standards

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.

V = rated storage capacity in litres.

Labelling Requirements

EnerGuide labels are not required for these products.

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 Dates

The effective date for all changes will be January 20, 2004.

Recent Comments Received

One manufacturer provided test results which indicate that the C745 test procedure does not give credit for the use of tank bottom insulation. NRCan has investigated this issue further and concluded that this is a valid concern. This issue has significant impact on energy use since about 75% of electric water heaters are installed on concrete floors.

NRCan is concerned with repeatability of test results when using C745 (which was originally proposed as the test method). This problem is described in a paper presented to ASHRAE entitled "Variability in Energy Factor Test Results for Residential Electric Water Heaters" by Healy, Lutz, and Lekov. For water heaters with high energy factors, the heat loss (efficiency) portion of the test becomes a small part of the total result. Small errors in measuring a number of parameters lead to significant variations in the results. At a March, 2003 CSA meeting for water heaters, the issues of repeatability and bottom insulation were discussed at length.

NRCan has decided to retain the C191 test method. Measuring standby loss is relatively simple and will give more repeatable and representative results.

Manufacturers have voiced some concern with this change given the target date of January 2004, but have agreed to provide data to assist in developing the levels in order to meet the deadline.

Manufacturers have asked NRCan to ensure that the effective date is the same as in the United States, and that compliance to the Regulations be well enforced.

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.

Harmonization

A consideration in developing all regulations is harmonization with other regulatory authorities. This avoids placing undue competitive pressure on manufacturers and purchasers.

In the United States, the DOE published a final rule in the U.S. Federal Register on January 12, 2001. This action is to regulate the efficiency of water heaters to the levels in ASHRAE 90.1-1999. The implementation date in the United States is January 20, 2004.

For electric water heaters, the test method will continue to be different in Canada. It is the intention of NRCan, with the assistance of the manufacturers and other stakeholders, to establish efficiency requirements for electric water heaters which are similar to those in the US.

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 are invited and should be directed to:

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