We Wish You to Thank You for the Additional Days You Ve Given to Us in Order to Provide

Dear Sirs,

We wish you to thank you for the additional days you’ve given to us in order to provide our point of view in this RIS. We’ve read the two documents you prepared in February and December last year and, as far as chillers are concerned, retained the following points as the main changes to the present norms:

1. Remove the unique Australian/New Zealand chiller test standard and align with the United States (US) Air conditioning, Heating and Refrigeration Institute (AHRI) test standard 551/591:20112015. Physical test reports to AHRI 551/591:2015 would be allowed without meeting the selection, installation, operation and maintenance requirements for test instrumentation stated in Table C1 of the standard.
2. Include the energy efficiency requirements for A/C >65 kW capacity and chillers <350 kW under GEMS/New Zealand regulations and in Australia remove these from the NCC. Retain current NCC MEPS levels under GEMS/New Zealand regulations.
3. Remove MEPS requirements for all water-cooled chillers, and air-cooled chillers with a capacity of 700 kW or greater.

1. New test standard

As far as the new standard is concerned we agree that a global standard (AHRI ou EN-Eurovent based) will simplify the way to the market with certified products, also for Australian manufacturers exporting towards markets which are already using these two standards as reference.

What is important, and as I see is confirmed in your documents, is that the European manufacturers can provide their Eurovent certification and provide the selection at the conditions required by the AHRI standards (550 or 551).

1. Include minimum efficiency levels for chillers < 350kW.

We are in favor of such policy and agree that also this market needs to be protected from low efficient products. Ideally we would split the requirements for units with capacity lower than 50kW and above that capacity. For the lower capacity we would remain on the present values.

-For air cooled ones > 50kW

The point of COP > of 2,5 is, in our opinion, correct if associated with an IPLV of 4 (or 4,05) at least. The reason of this position is to be found in the actual operating conditions: as the chiller is often operated in conditions different than the nominal ones (in your table we see that the chiller is operated only 18% of the time at nominal conditions – and therefore it is 82% of the operating hours in partial operation) we consider efficient a machine which has a good COP but especially a good IPLV. All the European norms are as a matter of fact taking that direction with the minimum efficiency thresholds which we all have to respect starting from January 1st, 2018 and, as a second tier January 1st, 2021.

-For the water cooled ones > 50kW

The point of COP of 4,2 and 5,2 as IPLV is correct but a bit on the low side. We are in favour of a COP of 4,5 (or 4,51) and IPLV of 5,5

1. Remove MEPS requirements for all water-cooled chillers, and air-cooled chillers with a capacity of 700 kW or greater

-For air cooled chillers

In our opinion the present values are correct.

-For water cooled chillers

As it is clearly indicated in the rationale in your documents the risk of too high efficiency requirements would make the installation of a water cooled chiller so expensive that a great part of the market would move to cheaper (and less efficient) air cooled chillers. We partly agree on this and we see as one of the points the fact that the chiller must respect both COP and IPLV. In our opinion the high IPLV is to be considered as the main driver because the units are often used at partial load and that is the point which is hitting the energy point. Therefore, in our opinion, while the COP could be flattened to 5,5 for all water cooled chillers > 700kW (in order to let cheaper technologies in and the market profit of this opportunity to push higher efficiency in the market), an IPLV of 6,5 would be necessary up to 1000kW, to be increased for larger equipment seen the wide use of inverter in the units of last generation.

Thanking you for your attention and asking you to be kept in the loop in case of further releases of the norms, we remain at your disposal for further elements

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