Air Conditioners and Heat Pumps under 19kW (65,000 Btu/h)

Bulletin Update – March 2005

Air conditioners and heat pumps of various types are prescribed as regulated products under Canada's Energy Efficiency Regulations (the Regulations). The Office of Energy Efficiency (OEE) of Natural Resources Canada (NRCan) proposes to amend the Regulations under which dealers would be required to comply with more stringent minimum energy performance standards for air conditioners and heat pumps less than 19 kW in capacity that are imported or shipped interprovincially for sale or lease in Canada.

The test method for central air conditioners and heat pumps (CSA-C656) has been finalized and will be published in time to be incorporated in the current amendment.

In the United States, federal regulations for higher efficiency levels will be implemented on January 23, 2006, with some further changes in 2010 for certain equipment. This amendment to the EE Regulations in Canada will increase the minimum efficiency levels for central air conditioners and heat pumps, to coincide, for the most part, with increased efficiencies required in the United States.

The purpose of this document is to provide stakeholders with an update to a previous bulletin and to summarize feedback received. By mid-2005, NRCan expects to pre-publish an amendment to the EE Regulations in the Canada Gazette Part 1.

Product Description

The proposed amendment to the EE Regulations will apply to permanently installed air-source air conditioners and heat pumps. Equipment types include air conditioners and heat pumps that are single package and split-system, single and three-phase, with rated capacity of less than 19 kW (65,000 Btu/h).

Through-the-wall, space-constrained, and Small Duct High Velocity (SDHV) equipment types are also included.

Energy Performance Test Procedure

The test standard for this equipment will be CAN/CSA C656-05, "Performance Standard for Split-System and Single Package Central Air-Conditioners and Heat Pumps", and will be available in French and English 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

Comments received

The Heating, Refrigeration, and Air-conditioning Institute (HRAI), an industry association in Canada, submitted a letter to NRCan supporting harmonization of efficiency levels with the levels approved in the United States for January 23, 2006.

NRCan distributed and posted a bulletin in July 2004 with proposed amendments to the EE Regulations.

One supplier of Small Duct High Velocity (SDHV) equipment provided information to indicate that this equipment could not meet the SEER 13 levels, and also provided documentation for an exception made by US DOE. A revised efficiency level has been incorporated into the Canadian requirement.

The definitions and requirements for speciality equipment were confusing. Air-Conditioning and Refrigeration Institute (ARI) provided helpful interpretations of the US requirements for "through-the-wall" and space-constrained equipment.

Air conditioners are not used for extended periods during the summer in Canada. However, air conditioners contribute directly to the need for new electricity generation, and therefore result in higher rates for electricity customers. NRCan proposed mandatory reporting of Energy Efficiency Ratio (EER) at 35C for the use of electricity utilities in those areas that are summer peaking, notably in Ontario where there is little excess generating capacity. Manitoba Hydro and BC Hydro also indicated interest in peak demand reduction since generating capacity would be available for future development and for export of electricity. Manufacturers, through HRAI and ARI, objected to mandatory reporting of EER, citing reasons of extra cost in testing, the possibility of creating confusion for purchasers, and concern about the quality of EER data voluntarily reported. A conference call and workshop were held to gather more information on this issue. About 30 attended the consulation workshop including manufacturers, HRAI, ARI, and electricity utility representatives. Utilities confirmed the impact of air conditioning on peak demand, describing air conditioning as the "worst load". Since Ontario utilities are still planning for demand side activities, and since ARI has committed to a verification process that will improve the quality of EER data, NRCan will continue to have EER ratings reported on a voluntary basis and will make that data available. NRCan will monitor EER reporting and verification and may address the issue in a future amendment. The EER for air conditioners and heat pumps must be reported to be Energy Star qualified.

In the US, air conditioners and heat pumps under 19kW operating on three-phase power were not addressed. Additional research was undertake to ensure that three-phase equipment is available and no technical barriers would prevent the inclusion of three-phase equipment in the amendment.

NRCan had proposed that for heat pumps, the Heating Season Performance Factor (HSPF) have an EnerGuide rating since energy use for heating is several times the energy use for cooling. Industry had concerns with confusion in the market place. NRCan intends to further assess the value of this addition, and it may be addressed in a future amendment.

Some manufacturers were concerned with timing of the amendment and the potentially short time between registration of the amendment and the effective date of January 23, 2006. Since all products are imported into Canada, and all must meet the US requirements, this should not be a barrier to complying with the new efficiency levels.

Requirements of the proposed regulation

Minimum energy performance standards

For air conditioners and heat pumps of less than 19 kW (65,000 Btu/h) and within the scope of the CSA C656-05 test method, NRCan expects to reference the following minimum Seasonal Energy Efficiency Ratings (SEER) and Heating Season Performance Factors – Region V (HSPF V):

Note: For comparison with U.S. efficiency levels for heat pumps, HSPF V = HSPF IV / 1.15.

Labelling Requirements

The equipment must bear a verification mark which indicates that the efficiency rating has been verified by an organization accredited by the Standards Council of Canada. EnerGuide labels are not required to be attached to this equipment or its packaging. In Canada, there is a voluntary, industry-managed labelling initiative, whereby manufacturers print an EnerGuide rating label on product brochures. The EnerGuide rating for both central air conditioners and heat pumps is based on the certified SEER. There is currently no EnerGuide rating for HSPF.

Verification, Reporting and Importing Requirements

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

Existing reporting requirements are provided on NRCan's website. It is the responsibility of manufacturers and dealers to ensure that NRCan receives an energy efficiency report for all regulated products prior to import and transport between provinces and territories.

Effective Dates

The effective dates will be January 23, 2006 and January 23, 2010. This means that equipment meet the minimum efficiency levels if the manufacturing process is completed on or after those dates.

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