Stakeholder comments form

Organisation: INFORSE-Europe and ECOS / Name: Gunnar Boye Olesen and Stamatis Sivitos / Date: May 4, 2012

ENER Lot 20: Local room heating products

Document comment relates to / Section in document / Page number / Topic / Comment / Proposed change /
All / n.a. / n.a. / General / Room heaters are converting a large share of Europe's energy supply into space heating. They consume as much as 1/3 of the consumption of boilers, the energy using product with the largest use in Europe. Combining this with the large improvement options for many of the room heaters, there are significant opportunities to save energy with Ecodesign and labelling regulations for these products. The Ecodesign product regulation must complement building regulations, which in some countries it gives clear guidance on where to use and where not to use certain room heating products, such as electric heaters. / See following proposals
Task 5 report and following / 5.1.4 / 14ff / Energy Consumption calculation / The choice of methodologies to evaluate the efficiency of room heaters in the preparatory studies are not based on a seasonal efficiency and are not harmonised among the base cases with a similar function (such as residential space heating ). The lack of a coherent and adequate methodology weakens the identification of improvement options and comparison of the different room heating technologies. We therefore propose to use seasonal efficiency for the evaluation of efficiency as it is done for ecodesign of other space heating equipment (e.g. boilers in ENER Lot 1). If test and calculation standards are not in place for evaluating seasonal efficiency, the study should highlight the lack of these and specify the necessary ones needed, highlighting the need for a mandate to be issued by the European Commission in this area. The proposal for standardisation work to be undertaken in CEN TC180 (technical committee on non domestic gas heaters), is indeed a step in the right direction. / Efficiency calculations for room heaters are changed to seasonal efficiencies for all products covered (all base cases). The method must include the effects of controls including different thermostats.
Where test and calculation standards are not in place for seasonal efficiency (including part-load testing), the preparatory study shall highlight the missing standards and propose transitional measures until standards can be in place.
Task 5 report and following / 5.1.2 and following / 10ff / General / The choice of base cases in the task 5 report show that half of the base cases (base case 1 - open combustion flued gas heater, 2 – open combustion flued gas fire, 4 - fixed electric convector heater, 5 - electric storage heater, 6 – underfloor electric heating) are effectively fulfilling the same function: heating a room of 15 m2 in a reasonably insulated house (consumption for the room is 1130 kWh per year which equals 75 kWh/ m2 per year, except for electric storage heaters, where a 15m2 room with a higher consumption is chosen). Since these base cases have the same function, they can in many ways be treated as one case. / The base cases with the same function (heating of a room, BC 1, 2, 4, 5, 6) are grouped into a super-base case in the reports 5-8 with similar improvement options etc.
Task 5 report and following / 5.1.3, table 5.2. and following / p.13ff / Base cases / The choice of a room of 15 m2 conceals the fact that the costs and benefits of different choices varies with the size of the heat demand. This is very clear from the improvement proposals of the base case 4, where an air-air heat pump is correctly stated as the BAT among local heating solutions, but is not included as an improvement option based on the argument that it is too expensive. In practice this option is chosen by many house owners and leads to a good user economy because they are being used in larger rooms, typically the living- room of a house. If a room size of 30 m2 was chosen as a second room size for base cases 1,2,4,5 and 6, this would have given a different picture, where the more advanced equipment, such as heat pumps would be more economically advantageous. / For the proposed “super base case” with BC 1,2,3,5, and 6, energy and economic calculations are also carried out for a room of 30 m2.
Task 5 report and following / 5.1.3, table 5.3 and following / p.13ff / The choice of a larger consumption for the storage electric heater base case (BC5) compared to other residential room heaters is not logical, and makes it more difficult to compare the different technologies. The argument that these heaters are used in the UK for rooms which are heated more permanently compared to other rooms heated by electricity is weak. Dwellings with electric room heaters are in general heated rooms with a comfort temperature similar to other heated spaces. / Energy demand of the room is set to the same for BC5 as for the other base cases.
Task 7 report / 7.1, table 7-1 to 7-12 / p.9ff / Improvement options / The improvement potentials are in several cases not well documented, and should be improved. This is for instance the case of the proposal of absence detection / Include calculation methods and documentation with sources for the improvement options for all base cases, based on a coherent method w. seasonal efficiency
Task 8 report / 8.2.3.1 / p.12 / Calculation and Ecodesign requirements / For gas heaters we support the proposal of minimum energy efficiency (MEPS), but insist that it shall be based on seasonal efficiency and gross calorific value, not on net calorific value as proposed. For gas heaters we propose air quality requirements similar to the requirements for gas boilers (ENER Lot 1), with the possibility for stricter national requirements. / MEPS shall be proposed based on gross calorific value seasonal efficiency with a method that include the effects of controls
NOx limits shall be proposed
Task 8 report / 8.2.3.2 / P13ff / Ecodesign measures / Given the large use of electric resistance heating for residential space heating, we find it absolutely essential to start regulating this product group due to the large energy consumption associated with these products. We propose that a seasonal minimum efficiency is set that requires advanced thermostat control (PI regulator) and timers for set-back control. These improvement options have pay-back periods of respectively 0.41 years and 1.25 years, with a combined savings potential of just above 20%. Even though the evaluation of the improvement potentials includes substantial uncertainty, there is little doubt that these functions are justified for room heaters used as primary space heating. In practice this can be required for fixed room heaters. For portable electric room heaters, the use of advanced thermostats (PI regulators) can be set as the minimum requirement.
Not regulating residential electric room heaters, as proposed in the report, would be a huge lost opportunity to improve energy efficiency and reduce energy consumption. / Ecodesign requirements shall be included for seasonal minimum energy efficiency requirements on a level that requires advanced thermostat control (PI regulator) and timers for set-back control for fixed electric heaters.
The misleading text of 100% real life efficiency of electric heater is replaced with a text that discusses the losses by overheating with simple thermostat as well as the saving potentials of timer-controlled temperature set-back.
For portable electric heaters ecodesign requirements shall be included for seasonal minimum energy efficiency requirements at a level that requires advanced thermostat control (PI regulator)
Task 8 report / 8.2.3 / P12-14 / Labelling / For all fixed, residential room heaters, in addition to minimum requirements, it is essential to inform consumers via a label that shows the difference between these room heaters, including both room heaters of similar technology and those with different technologies. This label should cover base cases 1, 2, 4, and 5 and eventually 6 (floor heating). / Propose an energy efficiency label based on seasonal efficiency to cover the base cases 1, 2, 4, and 5 and eventually 6, compatible with existing EU energy efficiency labels in the field.
Task 8 report / 8.2.4.1 / 14-15 / Calculation method, information / For large, warm-air heaters (furnaces) > 12kW (BC7), we support the proposal for MEPS, but insist that they should be based on seasonal efficiency and that the gross calorific value should be taken into account, not the net calorific value as proposed. We understand that a labelling scheme might not be useful, but insist that the obligatory information must include seasonal efficiencies for the most popular use patterns. Gas-and oil fuelled heaters should be harmonised with ENER Lot 21 and for air pollution related issues also with ENER Lot 1. / MEPS shall be based on seasonal efficiency and gross calorific value.
Consumer requirements of seasonal efficiency for the most popular use patterns (these patterns shall be defined by regulation and standards, not by manufacturers).
NOx requirements are set similar to ENER Lot1
Task 8 report / 8.2.4.2 / 15-17 / Labelling, NOx requirements / For radiant gas heater >12 kW (BC8) we support the proposed minimum radiant factors and the requirements for various controls including temperature controls, but insist that regulation should be enforced that drives this technology towards better part-load efficiency. We therefore propose a labelling scheme, based on a seasonal efficiency, where part load use plays an important role. We also support that air pollutant emission limits are set and that the levels are not higher than those for boilers but stricter when the combustion products are introduced into indoor air (which they often are). / Propose a labelling scheme, based on seasonal efficiency.
Propose NOx limits similar to ENER Lot 1, and stricter levels for applications where the combustion products are introduced into indoor air (which they often are).
Task 8 report / 8.2.4.3 / p-17-18 / Information requirements / For the base case 9, air curtains, we support the proposals for energy efficiency requirements and requirements for controls, as well as benchmarks for air stream controls. We also support the information requirements, but insist that in these it is clearly specified that the technical indicative benchmark includes use of heat pumps as well as central heating to supply heat to the air curtain. / In the information requirements, it should be clearly specified that the technical indicative benchmark includes use of heat pumps as well as central heating to supply heat to the air curtain.
Task 8 report / 8.2 / p.12ff / Recycling / We also support proposals related to take-back systems for heaters, to improve recycling and promote resource efficiency. / Take-back systems of used products should be considered - whenever relevant - as a requirement.
Task 8 report / 8.2 / p.12ff / Benchmarks / The establishment of indicative benchmarks is of importance, but there should be two levels for these: one for the same technology and one for the same function. In this way, the first benchmark for an electric heater would be an electric heater with advanced controls while the second benchmark would be a heat pump, or a central heating system if supplied with heat from renewable energy or efficient combined heat and power (CHP). / Indicative benchmarks are set in two levels: one for the same technology and one for the same function.

Proposal for a possible energy labelling scheme for room heaters.

Gunnar Boye Olesen, INFORSE-Europe, May 2012

Background and rationale: The sale of electric radiators, convection heaters, and heaters or fires with built-in fans is according to the manufacturers of fixed electric heaters (except for underfloor heating) 10,6 mill. units/year while fixed gas heaters is 0,7 mill units/year, in total 11,3 mill. units/year (data from lot20, task 2 report, numbers for 2009.)

The consumption per room and heater is in the base cases 1,2, 4, 6 1130 kWh of heat (one heater per room). This results in energy (electricity and gas) consumption from the annual sale of fixed electric and gas heaters of 13 TWh. With the expected 12-year lifetime, the total consumption is 156 TWh of electricity and gas, or converted to primary energy 375 TWh. If a label results in a 7.5% reduction (30% of consumers use label and save in average 25% by using the label, a conservative figure that does not include the market transformation effect) the saving will be 28 TWh of primary energy after 12 years (in 2025). This is a sufficient enough reason to introduce a room heater label. If the use of an energy label leads to market transformation, the savings can be 2-5 times higher.

Scope: The label should cover the residential local room heating options, including electric resistance heating, local gas heaters, and air-air heat pumps. The inclusion of floor heating can be considered.

Possible efficiency indicators: To evaluate the possible labels, the following table compares the agreed or proposed labelling schemes related to space heating:

first column: labels for boilers (lot1), second column: labels for low-temperature heat pumps (lot 1), third and fourth column: and air-air heat pumps. For air-air heat pumps the first column is the efficiency recalculated to the lot1 boiler efficiency[1]. The last column is the SCOP (Seasonal COP) that is used in the agreed air-air heat pump label.

Label class / Boiler eff / Low-T HP eff. / Air-air heat pumps / Air-air heat pumps
A+++ / lot1-eff.> 150 / lot1-eff.> 175 / lot1-eff.> 206 / SCOP >5,10
A++ / lot1-eff.> 125 / lot1-eff.>150 / lot1-eff.> 186 / SCOP >4,6
A+ / lot1-eff.> 98 / lot1-eff.>123 / lot1-eff.> 162 / SCOP >4,0
A / lot1-eff.> 90 / lot1-eff.>115 / lot1-eff.> 138 / SCOP >3,4
B / lot1-eff.> 82 / lot1-eff.>107 / lot1-eff.> 126 / SCOP >3,1
C / lot1-eff.>75 / lot1-eff.>100 / lot1-eff.> 114 / SCOP >2,8
D / lot1-eff.> 37 / lot1-eff.> 62 / lot1-eff.> 102 / SCOP >2,5
E / lot1-eff.>34 / lot1-eff.> 59 / lot1-eff.> 90 / SCOP >2,2
F / lot1-eff.> 30 / lot1-eff.> 55 / lot1-eff.> 78 / SCOP >1,9

Ideas for possible labels: Comparing the scales of the proposed boiler label and the air-air heat pumps, it is clear that they are too different to be merged into one joint label, applied to all the different kinds of room heaters.