Please Find Below Our Feedback in Regards to the Consultation Questions on Double Duct

To whom it may concern,

Please find below our feedback in regards to the Consultation Questions on double duct air conditioners.

1. Can you provide information about wither wall mounted double duct products would compete with window/wall and high wall split systems? Is this significant or marginal issue?

Our view on wall mounted double duct systems is that they directly compete with non-ducted unitary window type and non-ducted high wall split systems and they must be subjected to comply with the same MEPS levels, at least 3.1 AEER/ACOP not the proposed lower MEPS level of 2.5.

Double duct systems are differentiated from portable air conditioner by having the ability of using outside air to cool the heat exchanger allowing for faster cooling to the room without creating a negative pressure inside the room (please see figure 1 below).

This places the Double duct systems in direct competition with Window type and non-ducted Wall mounted split systems.

The introduction of wall mounted double duct air conditioning systems to the market at the lower MEPS level will have a significant impact on ActronAir as supplier of Wall mounted split systems. Currently a large portion of builders and developers install non-ducted wall mounted split type air conditioners in dwellings where they require a cheap solution to cool or heat their space.

If a double duct Wall mounted system is introduced to the market with a lower MEPS it can be manufactured at a lower cost than a non-ducted Wall mounted split and sold with a lower price tag, the system will also cost less to install as it doesn’t require the hiring of a qualified air-conditioning technician.

This will lead to majority of builders and developers who don’t necessarily care about energy efficiencies to replace the more efficient non-ducted Wall mounted split product with the less energy efficient Wall mounted double duct product.

Double duct systems will also be sold in large volumes to retail outlets at low costs which making it the first choice for a consumer who is after a cheap product to air-condition their area, which will also impact the non-ducted wall mounted split sales, and thus impacting the overall electricity consumption by using a less efficient products to do the same job.

2. Can you provide information about the cost of wall mounted double duct products (including heating/cooling capacity and energy efficiency), and how this compares to window/wall and high wall split systems? Providing information about product costs and installation cost separately if possible,

Most popular brands don’t offer double ducted portable products, however when we investigated pricing through one of our overseas suppliers we found that the average sale price difference for a 2.5kW system between a non-ducted Wall mounted versus a Double duct wall mounted would be approximately $250 not including installation or commissioning. There will be a much bigger gap for the consumer due to extra costs involved in installing and commissioning the non-ducted wall mounted split.

3. If double duct air conditioners were separated into wall mounted and portable categories, how would you define each category in a way that could be enforced?

Portable air conditioning systems should be limited < 2kW capacity as these systems provide spot cooling and are not conditioning an entire room. We believe this capacity CAP will help distinguish the product clearly. They can be subjected to the same MEPS level as portables.

Systems of 2.0kW or above that are designed to condition an entire room must be subjected to the higher MEPS level 3.1 AEER/ACOP or greater.

4. Do you have any other information or data you would like to provide that would assist in resolving this issue?

While we understand that there are some applications were a double duct system would be preferred due to some restrictions it should not compromise on energy efficiency and give this product an unfair competitive advantage over more efficient systems (such as Window/wall and non-ducted wall mounted splits).

While the department’s intention is to allow this type of product to enter the market to satisfy a small number of applications, it will be unfortunately used to target much larger markets that currently use higher energy efficient products.

Finally, we don’t see the reason why these types of products with today’s technologies wouldn’t be able to meet the same MEPS level as other competing products.

Kind Regards

Amro Said | Head Product Portfolio Manager

5 Irvine Pl, Bella Vista NSW 2153