Industry reacts to NRCan proposed equipment efficiency regulations
In October 2018 Natural Resources Canada (NRCan) published new proposed energy efficiency regulations for heating equipment in the Canada Gazette Part 1. These proposed regulations are part of Amendment 15 to the Energy Efficiency Act and introduce new or increased efficiency requirements to a range of products including commercial water heaters, household and commercial boilers, mobile home furnaces and gas fireplaces.
Publication in the Canada Gazette Part 1 is the last step the government takes prior to passing these new requirements into law. After publication of the proposed regulations, NRCan provided for a final comment period, which ended on December 29, 2018, that allowed all stakeholders to provide feedback.
The proposed regulations are controversial, with several of them being opposed by heating industry associations. The Canadian Institute of Plumbing and Heating (CIPH), the Heating, Refrigeration and Air Conditioning Institute (HRAI) and the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) represent manufacturers and distributors in the plumbing and heating industry. These three associations presented a joint submission to NRCan outlining their concerns regarding the proposed regulations. The submissions by CIPH-HRAI-AHRI covered two separate product categories: water heaters and boilers.
The water heater regulations being proposed by NRCan cover commercial electric, gas and oil-fired storage water heaters, and residential and commercial tankless water heaters. For electric and oil-fired storage water heaters, NRCan is harmonizing energy efficiency requirements with those already in place in the U.S.
For gas-fired storage water heaters NRCan is taking a new approach with two different efficiency requirements, which cover new installations and retrofit installations. New installations will require condensing level efficiency equipment, while retrofit applications can still use non-condensing equipment. The industry associations endorse most of the proposed water heater regulations and are very supportive of the concept of separate requirements for new construction and existing construction for commercial gas fired storage water heaters. The associations have however raised objections to the proposed regulations for non-condensing gas-fired storage water heaters that are more stringent than current United States Department of Energy (DOE) regulations.
“The industry objects to the increase in the efficiency requirements being proposed for non-condensing equipment that can be used for retrofit applications. NRCan is raising the thermal efficiency requirement for this category from 80 per cent (current DOE requirements) to 82 per cent for this category and this is extremely problematic for the industry,” explained Robert Waters, technical consultant for codes and standards for CIPH.
The industry associations claim this increased efficiency requirement will not be in harmony with U.S. regulations and will result in the elimination of the majority of the models currently utilized for replacement applications in Canada. The result will be a very limited product offering for consumers, as most models currently available would not meet the new efficiency requirements. There are also some technical and safety concerns with possible flue gas condensation in existing venting systems with the proposed higher efficiency equipment.
CIPH-HRAI-AHRI do not object to the proposed new water heater efficiency regulations for the new construction category, but have recommended the requirement for non-condensing equipment be harmonized with the current U.S. DOE regulations for those products, ensuring availability of a wide range of products and a smooth transition in the market. They have also asked NRCan to push back the proposed implementation date to allow more time for industry to react to the changes.
The boiler regulations being proposed by NRCan cover residential and commercial, gas and oil-fired boilers. For oil-fired boilers, NRCan is harmonizing efficiency regulations with current DOE regulations. For gas-fired boilers, NRCan is deviating from current DOE regulations and proposing only condensing level efficiency equipment can be used for all applications.
These proposed gas-fired boiler regulations are much more contentious. “The majority of our members are not in support of the new gas fired boiler regulations being proposed by NRCan,” stated Waters. “Members are very disappointed dual level efficiency requirements for replacement and new construction applications are not being proposed for gas-fired hot water boilers.
“NRCan has proposed this approach for commercial water heaters, but have not applied this same approach to boilers, even though similar technical and other issues apply to both categories of products,” added Waters.
NRCan commissioned a Cost-Benefit Analysis (CBA) study to look at the economic impact for consumers of the proposed new regulations. NRCan’s CBA report has been used to justify its proposal to increase efficiency levels to condensing technology for all gas hot water boilers. CIPH-HRAI-AHRI believe there are many issues with the CBA study and feel that it contains errors and inconsistencies as well as incomplete and/or incorrect data.
The industry associations state the market for household and commercial condensing boilers has grown significantly over the last 15 years without having any minimum efficiency regulations in place. CIPH-HRAI-AHRI believe that condensing boilers are being utilized extensively where they are economically justified, but feel there will be significant financial and technical burdens for consumers by forcing condensing boilers into all existing installations.
The associations have also stated there continues to be many retrofit applications where condensing boilers cannot be justified and non-condensing boilers are still the best option for consumers.
“There are many existing buildings that will have to incur huge costs to install new venting and mechanical room repiping to accommodate a condensing boiler,” said Waters. “There are also many applications that only use high system water temperatures, resulting in minimal condensing in the boiler. These applications will see minimal if any fuel savings from a condensing boiler, but may have to spend huge amounts to install the boiler.”
CIPH-HRAI-AHRI have recommended that NRCan implement dual level standards for household and commercial gas-fired water boilers for new installations and retrofit installations, similar in concept to the proposed efficiency regulations for commercial storage water heaters.
None of the new proposed equipment efficiency regulations are finalized yet, as NRCan is currently reviewing all of the final comments received. Once they finalize their review NRCan will then have to decide the final version for the new regulations. This is expected to be published sometime in the next few months in the Canada Gazette, Part 2, at which point the regulations will become law.
Waters noted that these regulations will have a big impact on what type of equipment Canadian mechanical contractors will be allowed to be installed in the future. <>
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May 11, 2022