Canada's Energy Efficiency Regulations

Proposed Amendment
Bulletin – April 2007

Gas-Fired Unit Heaters

Natural Resources Canada (NRCan) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) to implement standards similar to those included in the U. S. Energy Policy Act (EPACT) 2005 with respect to gas-fired unit heaters. The Regulations apply to products imported or shipped interprovincially for sale or lease in Canada.

This amendment is included in Canada's Clean Air Regulatory Agenda and accompanying Notice of Intent as published in the Canada Gazette on October 21, 2006.

This bulletin attempts to put the proposed amendment in plain language. The legal text of the amendment will be pre-published in the Canada Gazette, Part I.

Background

Canada's Energy Efficiency Regulations, which came into effect in February 1995, are administered by NRCan and typically incorporate by reference energy efficiency test standards that must be used to ensure the product's compliance to the minimum requirements.

The U.S. Department of Energy, through EPACT 2005, will require unit heaters sold in that country to be equipped with an intermittent ignition device and have either a power-vented system or an automatic flue damper or an automatic vent damper. In addition to these requirements, the State of California requires unit heaters to have a minimum 80% thermal efficiency at maximum rated capacity, 74% thermal efficiency at minimum rated capacity, and a maximum energy consumption during standby of 10 watts for natural gas units and 147 watts for propane units. Unit heaters are not currently regulated for energy efficiency in Canada.

Unit heaters are commonly used in commercial settings. Their sales in Canada are estimated at over 35, 000 units per year. Most units are gas-fired, and the market for oil-fired unit heaters is small. Research of product literature shows that unit heaters' performance is typically measured for thermal efficiency, which ranges from 76% to 83%. Some of these measurements, however, do not take into consideration off-cycle losses and heated air exiting the building through the unit heater draft hood. These losses could reduce efficiency performance by up to 20%.

There are technologies available that can limit off-cycle losses and improve efficiency, such as power-vented systems, pre-heating systems, intermittent ignition devices, separated combustion, dampers and condensing technology. Condensing technology can achieve efficiencies of 93%.

The Canadian Standards Association (CSA) is currently developing the performance standard, P.11-2007 Testing Method for Measuring Efficiencies of Gas-Fired Unit Heaters. This standard describes prescriptive requirements for efficiency improvements of gas-fired unit heaters as mentioned above, references a test method to measure and calculate the steady state thermal efficiency, and details a method for measuring the electrical energy / power consumption of gas-fired unit heaters.

Energy savings and emission reduction potential

To determine the potential impact of improvements in energy efficiency of unit heaters, a comparison is made using the lowest efficiency technology available (baseline) against one that incorporates the prescriptive and thermal efficiency requirements set out in this bulletin. This information comes from a study titled Economic Analysis of Unit Heaters – 2001 by Enermodal Engineering Limited for NRCan.

The baseline unit heater is a gravity-vented unit with a standing pilot. It has an estimated annual fuel utilization efficiency (AFUE) of 64.1%. It is estimated that combining a minimum thermal efficiency of 80% with the mandatory requirements of an intermittent ignition device and a power-vented system will increase the seasonal efficiency level to 79% AFUE. Unit heaters are assumed to operate for approximately 2,122 hours per year with an average size of 250,000 British thermal units per hour (Btu/h) and a projected life expectancy of 18 years. The annual energy consumption of unit heaters shipped in Canada is 18,567.5 gigajoules.

NRCan estimates that implementing these requirements will provide annual energy savings of 4.1 petajoules beginning in 2010 and increasing exponentially to 29 petajoules annually in 2030. Likewise, greenhouse gas reductions of 0.2 megatonnes annually are anticipated beginning in 2010 and increasing to 1.5 megatonnes annually for 2030.

Product description

NRCan is proposing that the Regulations apply to gas-fired unit heaters of input up to 2931 kilowatts (kW) (10,000,000 Btu/h). For purposes of the regulations, a gas-fired unit heater means a self-contained, automatically controlled, vented, gas-burning appliance. Such an appliance is intended for installation in the space to be heated without the use of ducts. It shall have an integral means for circulation of air, normally by a propeller fan, and can be equipped with louvers or face extensions.

Energy performance test procedure

The proposed test method is draft CSA P.11-2007 Testing Method for Measuring Efficiencies of Gas-Fired Unit Heaters.

The draft test method standard is 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: csa.ca

Energy performance standards

The minimum requirements are indicated in the following table:

Thermal efficiency at maximum heat input	80%
Prescriptive requirements	Intermittent ignition device; and either
	Automatic flue damper or automatic vent damper; or Power-vented system. The power-vented option is contingent upon the provision that conditioned room air not be introduced into the vent system downstream of the combustion process with the intent of diluting the products of combustion.

Effective date

NRCan is proposing that these energy efficiency requirements come into effect August 8, 2008.

Labelling requirements

There is no label requirement showing the unit's energy efficiency proposed for this amendment.

Verification requirements

The same verification mark requirements that apply to other products regulated under the Energy Efficiency Act will apply to unit heaters.

NRCan is proposing that regulated unit heaters carry a verification mark indicating that the energy performance of the product has been verified. The verification mark is the mark of a Standards Council of Canada-accredited certification body that administers an energy performance verification program for this product. NRCan will also accept labels issued by a province indicating that the product meets the provincial energy efficiency levels as a verification mark, provided that the provincial level is equivalent to or more stringent than the federally regulated level.

Reporting requirements

Energy efficiency report

The energy efficiency report required for unit heaters shall include the following information:

• Brand name
• Model number
• Manufacturer name
• Type of product
• Name of the organization or province that carried out the unit heater verification and authorized the verification mark to be affixed to the unit heater
• Type of fuel (natural gas or propane)
• Type of exhaust system (gravity-vented or power-vented)
• Maximum heat input in kW
• Maximum heat output in kW
• Reduced heat input (for multi-stage and modulating units) in kW
• Reduced heat output (for multi-stage and modulating units) in kW
• Thermal efficiency at maximum heat input
• Power consumption in kW, rated blower speed in revolutions per minute (RPM), power factor and voltage in volts at maximum heat input rated capacity
• Power consumption in kW, rated blower speed in revolutions per minute (RPM), power factor and voltage in volts at reduced heat input (for multi-stage and modulating units)

Instead of testing for power consumption, the manufacturer may choose to report either:

• The motor information rated by NEMA (National Electrical Manufacturers Association) relating power consumption as a function of the volume of air delivered and the static pressure drop to be overcome; or
• The following default values:
  
  
• For electronically commutated brushless DC motors:
  
  
  • Power consumption at maximum heat input = Maximum manufacturer's rated blower power consumption (kW)
  • Power factor at maximum heat input = 0.80 (or as stated by the blower manufacturer)
  • Power consumption at reduced heat input = 0.50 x Maximum rated blower power consumption (kW)
  • Power factor at reduced heat input = 0.75 (or as stated by the blower manufacturer)
  • Power consumption during fan-only or standby mode = 0.20 x Maximum rated blower power consumption (kW)
  • Power factor during fan-only or standby mode = 0.65 (or as stated by the blower manufacturer)
    
    
• For all other motors:
  
  
  • Power consumption at maximum heat input = Maximum manufacturer's rated blower power consumption (kW)
  • Power factor at maximum heat input = 0.90 (or as stated by the blower manufacturer)
  • Power consumption at reduced heat input = 0.85 x Maximum rated blower power consumption (kW)
  • Power factor at reduced heat input = 0.85 (or as stated by the blower manufacturer)
  • Power consumption during fan-only or standby mode = 0.20 x Maximum rated blower power consumption (kW)
  • Power factor during fan-only or standby mode = 0.65 (or as stated by the blower manufacturer)

This report must be submitted by the dealer to NRCan before the product is imported into Canada or traded interprovincially.

Importing reports

A dealer who imports these products into Canada must include the following information on the customs release document:

• Type of product
• Model number
• Brand name
• Address of the dealer importing the product
• Purpose for which the product is being imported (i.e. for sale or lease in Canada without modification; for sale or lease in Canada after modification to comply with energy efficiency standards; or for use as a component in a product being exported from Canada)

Harmonization

NRCan attempts as much as possible to harmonize with other regulatory agencies. The proposed amendment to the Regulations incorporates the major aspects of proposed or already accepted standards for unit heaters in the U.S.:

• The U.S. Department of Energy will regulate unit heaters starting August 8, 2008, for prescriptive requirements.
• The State of California is currently regulating unit heaters for a minimum thermal efficiency of 80% at maximum rated capacity, a minimum thermal efficiency of 74% at minimum rated capacity, a maximum standby power of 10 watts for natural gas units and 147 watts for propane units, prescriptive requirements for an intermittent ignition device, and either a power-vented system or an automatic flue damper or an automatic vent damper.

Comments invited

The information in this bulletin is being issued in advance of prepublication in the Canada Gazette Part 1 to allow for concerned parties to comment on the proposal. All correspondence should be forwarded by May 14, 2007, to:

Terry Brennan
Senior Standards Engineer
Office of Energy Efficiency
Natural Resources Canada
1 Observatory Crescent, Building #5
Ottawa ON K1A 0E4
Tel.: 613-996-2230
Fax: 613-944-6365
Email
Web site: oee.nrcan.gc.ca/regulations/home_page.cfm