Wednesday, 4 January 2017
To:
[email protected]
Fisher & Paykel Australia Pty Ltd
Re:
Regulatory Impact Statement - Air conditioners and
chillers - updated policy proposals
29 Metroplex Avenue
Murarrie QLD 4172
PO Box 3326
Tingalpa DC QLD 4173
T +61 7 3823 8113
F +61 7 3823 8103
In response to questions outlined in Air conditioners and
chillers - updated policy proposals document dated November
2016.
FISHERPAYKEL.COM.AU
HAIER.COM.AU
This document has been written by Jason Brown, with 28 years air conditioning
experience, on behalf of the air-conditioning department of Fisher and Paykel
Australia Pty Ltd.
Haier has been manufacturing since 1985 and Fisher and Paykel has been involved
with air conditioning when they started distribution of the Haier Air conditioner in
2015.
Please find following pages with responses, where applicable
Best Regards.
Jason Brown
PRODUCT MANAGER - Air Conditioning, Australia and New Zealand
T: +61 7 38238113
M: +61 439 486 375
E: [email protected]
Fisher & Paykel Appliances Pty Ltd
PO Box 798
Cleveland, QLD 4163
AUSTRALIA
FISHERPAYKEL.COM.AU
Table of Contents
UPDATED POLICY PROPOSALS [RESPONSE] ..................................................................... 3
1.
Adopt SEER standard for air conditioners ..................................................................... 3
2.
Replace existing Energy Rating Label with Zoned Energy Rating Label ...................... 3
3.
SEER label for all portable a/c, reduced MEPS for double duct portables ................... 3
4.
Replace AS/NZ chiller test standard with AHRI standard ............................................. 4
5.
Remove NCC regulated chillers and a/c and replace with GEMS/New Zealand
regulations ................................................................................................................................. 4
6.
Retain current NCC MEPS levels under GEMS/New Zealand regulations ................... 4
7.
Align >65 kW A/C MEPS levels to 39-65 kW GEMS and chiller MEPS levels to the
ASHRAE levels .......................................................................................................................... 4
8.
Single duct portable A/C subject to a MEPS level of 2.60 based on AEER/ACOP ...... 4
9.
Align New Zealand’s residential cooling MEPS to match Australia’s levels .................. 4
10.
Remove ‘part load’ compliance option........................................................................... 5
11.
SEER rating of A/C ≥30 kW capacity, with rating information made available on the
Energy Rating website ............................................................................................................... 5
12.
(New policy proposal) Remove MEPS requirements for all water-cooled chillers and
for air-cooled chillers of 700 kW capacity or greater ................................................................. 5
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UPDATED POLICY PROPOSALS [RESPONSE]
1. Adopt SEER standard for air conditioners
•
If Australia was to adopt the AS/NZS 3823.4 SEER standard there would be a great
financial burden to compliance for Fisher and Paykel. Currently AS 3823.2 minimum
compliance is two (2) test points (T1 & H1) to meet MEPS approval. Haier has chosen
that the testing is conducted locally in Australian with reputable third party laboratories.
CURRENT COMPLIANCE TESTING INVESTMENT
• Currently each test point cost is approximately $4,500 in Australia test laboratory. So for
two point test per model the cost is $9,000. Note; Haier have 5 capacity models in each
series - the range compliance cost currently is $45,000.
SEER COMPLIANCE TESTING INVESTMENT
• AS/NZS 3823.4 SEER standard requires 5 minimum tests (but many more optional tests)
and using the average compliance cost of $4500 per point, the compliance cost for one
model would increase from $9,000 to $22,500 ($112,500 per range). Fisher and Paykel
are concerned for the 250% increase in compliance cost for efficiency testing.
2. Replace existing Energy Rating Label with Zoned Energy Rating Label
•
Agreed, I would think Australia would make better purchasing decisions if all air
conditioners <30 kW would be included in the star rating scheme. Currently a customer
cannot compare star rating of ducted verses hi wall.
•
During the RIS discussion in December the proposed energy label will have less heating
stars than cooling stars. I think this should be reconsidered care to not mislead the
public into believing that the efficiency of an air conditioner/heat pump in not a good
heating system. Gas heating is not included in this scheme and may adversely gain
advantage through confusion with star labelling between gas and Air conditioner
schemes.
3. SEER label for all portable a/c, reduced MEPS for double duct portables
•
Agreed, Fisher & Paykel do not currently source portables.
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4. Replace AS/NZ chiller test standard with AHRI standard
•
•
•
•
Agreed,
Chillers can be manufactured with Centrifugal, Screw, Reciprocating and Scroll
compressor technology. Centrifugal, Screw and (and also reciprocating) compressor
technology is variable capacity and is conducive to the IPLV test requirements. Scroll
(DOL) have fixed capacities and therefore would most likely not be conducive with the
IPLV test requirements.
Haier have AHRI certification for Centrifugal and Screw compressor models >300kW (Yet
to Launch in Australia).
Haier have not been successful to date for AHRI certification for Scroll compressor
models <300kW.
5. Remove NCC regulated chillers and a/c and replace with GEMS/New Zealand
regulations
•
Agreed.
6. Retain current NCC MEPS levels under GEMS/New Zealand regulations
•
Agreed
7. Align >65 kW A/C MEPS levels to 39-65 kW GEMS and chiller MEPS levels to the
ASHRAE levels
•
•
AC Systems Agreed, AC systems >65kW to equal 39-65kW GEMS levels (2.9AEER/ACOP)
Chiller systems, more investigation necessary, Chiller <350kW air cooled. There may be
difficulty of achieving the proposed level of 2.87. EER of 2.7 is preferred.
Table 7 Proposed MEPS levels for chillers (Option B1/B2)
Cooling
Current
Proposed
COP %
medium
COP
COP
increase
<350*
2.50*
2.87
15
350-499
2.70
2.87
6
500-699
2.70
2.87
6
Air-cooled
700-999
2.70
2.87
6
1000-1499
2.70
2.87
6
>1500
2.70
2.87
6
<350*
4.20*
4.51
7
350-499
5.00
5.00
0
500-699
5.10
5.10
0
Water- cooled
700-999
5.50
5.50
0
1000-1499
5.80
5.80
0
>1500
6.00
6.00
0
Size (kW)
Current
IPLV
3.40*
3.70
3.70
4.10
4.10
4.10
5.20*
5.50
6.00
6.20
6.50
6.50
Proposed
IPLV
4.05
4.05
4.14
4.14
4.14
4.14
6.14
6.14
6.46
6.52
6.77
6.91
IPLV %
increase
19
9
12
1
1
1
18
12
8
5
4
6
8. Single duct portable A/C subject to a MEPS level of 2.60 based on AEER/ACOP
•
Agreed, but not a portable supplier (as yet)
9. Align New Zealand’s residential cooling MEPS to match Australia’s levels
•
•
Agreed, Haier models for NZ are same as Australia. So exceed Australia and NZ MEPS
limit already.
Furthermore NZ “Energy star” efficiency targets should be brought into line with MEPS
levels as they currently exceed the MEPS targets.
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10. Remove ‘part load’ compliance option
•
Remove from RIS as mentioned.
11. SEER rating of A/C ≥30 kW capacity, with rating information made available on the
Energy Rating website
•
No comment.
12. (New policy proposal) Remove MEPS requirements for all water-cooled chillers and
for air-cooled chillers of 700 kW capacity or greater
•
No comment, not a current supplier in this field. Personally I think they should remain
MEPS approved but utilise AHRI certification.
[END]
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