Bulletin on developing electricity reporting requirements
The Office of Energy Efficiency (OEE) of Natural Resources Canada (NRCan) is proposing to amend Canada's Energy Efficiency Regulations (the Regulations) under which dealers in Canada would be required to comply with new electricity reporting requirements for air handlers used in central heating and cooling systems that are imported or shipped across provincial boundaries for sale or lease in Canada.
The purpose of this document is to provide stakeholders with background information for meaningful consultation on the content of the new regulation before proceeding with pre-publication in the Canada Gazette Part 1. This bulletin attempts to address key issues that may be raised. It is not intended to provide a definitive representation of the proposed regulation.
The electricity consumption of residential air handlers used in central space conditioning (heating, cooling, circulating) systems is not currently regulated under Canada's Energy Efficiency Regulations. Natural Resources Canada (NRCan) requires dealers of many types of HVAC systems to comply with minimum energy performance standards. Examples of regulated product categories include residential gas and oil-fired furnaces, air conditioners and heat pumps that are imported or shipped inter-provincially, for sale or lease in Canada. Effective January 1, 2010, the Regulations contain reporting requirements for electricity consumption of the furnace blower motor and standby power for gas-fired furnaces.
This bulletin provides advance notification of a proposed new regulation that will be forthcoming to strengthen electricity reporting requirements for gas furnaces and to extend electricity reporting requirements to other types of furnaces and air handlers that are used in residential central heating and cooling systems. Products that will be subject to the proposed new electricity reporting requirements include gas and oil furnaces, air handlers used in geothermal heat pumps and air-source heat pumps, and combination space and water heating (combo) air handlers.
Residential gas-fired furnaces have been designated as regulated products under Canada's Energy Efficiency Regulations (the Regulations) since 1995. Natural Resources Canada (NRCan) requires dealers to comply with minimum energy performance standards for residential gas and oil furnaces, imported or shipped inter-provincially, for sale or lease in Canada. As well, the Regulations contain reporting requirements for electricity consumption of the furnace blower motor and standby power.
NRCan first considered electricity use reporting requirements for air handlers in the 1990s. At that time, it was not considered to be feasible due to the lack of a method of testing and reporting that could be applied in a consistent way for different space conditioning appliances and different types of air handlers. There are significant differences in the test setups, operating pressures used for ratings, and measurement, calculation, and rating approaches for furnaces and air conditioners that make it difficult to compare electricity used by different HVAC appliances. Revising the existing appliance standards to provide consistent measurement and reporting of electricity use would be impractical because of logistical and technical considerations as well as harmonization-related issues. Changing test setups could affect the air flows and energy performance ratings for currently regulated products which might result in products that had previously satisfied minimum energy performance requirements failing to achieve those levels after the changes to the test methods.
Work is nearing completion on a new CSA performance standard that will be used to determine annual electricity consumption ratings in kWh per year for airhandlers used in ducted residential space conditioning systems. The technical subcommittee (TSC) responsible for developing the new standard had broad representation from HVAC appliance manufacturers, blower and motor manufacturers, researchers, testing laboratories and certification agencies as well as regulators and other interested stakeholders. They worked together to develop consensus for the new testing, rating and calculation procedures that are used in the C823 standard.
The C823 standard overlays a standardized system resistance static pressure curve that is based on the rated heating output of the system to the measured air delivery and power curves for each blower "speed" setting. The intersections of the system curve and the performance curves for each blower "speed" setting define the operating points that are used for ratings in C823. Because air delivery and power curves (or tables of performance data that describe the curves) are usually already reported by manufacturers in their technical literature, any additional testing burden to manufacturers is minimized.
Performance data tables for two representative furnaces were provided by manufacturers that participated on the TSC for use in the C823 standard development process. Using the data provided, a representative furnace with a conventional PSC blower motor would have an annual electrical energy consumption rating ranging from 1371 kWh when the blower is operated only for space heating and cooling to 3813 kWh when the blower is operated continuously. By comparison, a different furnace with approximately the same heating (23.5 kW (80,000 Btu/h)) and cooling (7 kW (24,000 Btu/h)) capacities that used a brushless DC blower motor would have an annual electrical energy consumption rating ranging from 498 kWh to 657 kWh per year. The difference between the rated energy consumptions of those two furnace airhandlers illustrates the potential to save as much as 3156 kWh per year of electricity for each air handler installation simply by using more efficient equipment. The overall results may vary if the airhandlers are used with add-on air conditioners with different capacities because different capacities require different air flows and different blower "speeds" for cooling. Because of this, the C823 standard produces annual electrical energy consumption ratings for each discrete step of air conditioning capacity, and it also accommodates multi-stage heating and cooling equipment.
For the purposes of the Regulations, an air handler is defined as the indoor air moving component of a space conditioning package that is designed to supply heating and/or cooling through a system of ducts with air as the heat transfer medium. The air handler may also circulate air to provide filtration or humidification, without addition or removal of heat.
Minimum performance levels
No minimum performance levels are proposed at this time.
Energy performance test procedure
The test method used to determine efficiency is CSA C823-XX - Performance standard for air handlers in residential space conditioning systems.
The standard will be available from:Canadian Standards Association
5060 Spectrum Way, Suite 100
Mississauga ON L4W 5N6
In Toronto, call 416-747-4000
Web site: www.csa.ca
This amended regulation will come into effect on January 1, 2012.
All air handlers that have their manufacturing process completed on or after the effective date, and that are subject to the Regulation, will be subject to the reporting requirement.
There is no requirement for the unit to have a label showing its electricity use rating.
There is no change at this time to the verification requirements.
In addition to current reporting requirements, the energy efficiency report required for air handlers will include the following information:
- Annual Electrical Energy Consumption (AECR) rating
- Electricity consumption rating and airflow for operation in heating mode
- Electricity consumption rating and air flow for operation in reduced heating mode
- Electricity consumption rating and air flow for operation in cooling mode
- Electricity consumption rating and air flow for operation in reduced cooling mode
- Electricity consumption rating for operation in circulation mode
- Electricity consumption rating for standby mode
For air handlers that are rated by their manufacturers for use with different cooling coils to provide different cooling capacities, separate electricity consumption reports are required for each step of rated cooling capacity. In addition to annual electrical use ratings, C823 also provides ratings of air moving efficacy in litres/second per watt (cfm per watt) for each discrete operating mode.
Reports must be submitted by the dealer to NRCan before the product is imported into Canada or traded inter-provincially.
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
- Name and 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)
This is a new reporting requirement. Consideration is being given in the United States for similar reporting.