Public comment

New minimum standards for large AC

New greenhouse and energy minimum standards (GEMS) have been drafted for air conditioners above 65kW. They are open for public comment.

There are currently no minimum energy efficiency requirements under the Greenhouse and Energy Minimum Standards (GEMS) Act for air conditioners over 65kW capacity to be sold in Australia. There are, however, requirements in the National Construction Code (NCC).

The Greenhouse and Energy Minimum Standards (Air conditioners above 65kW) Determination proposes that manufacturers, importers and suppliers of air conditioners with a capacity of over 65kW must ensure that their products:

  • Have been tested to the relevant Australian Standard to determine their energy consumption
  • Meet a Minimum Energy Performance Standard (MEPS) of 2.90
  • Have been registered on the Energy Rating website, including their Total Cooling Seasonal Performance Factor and their Heating Seasonal Performance Factor.

According to Eddy Vickery from the Appliance and Building Energy Efficiency Branch at the Department of the Environment and Energy, the changes will bring treatment of the over 65kW sector of the market into line with the treatment of the 39–65kW sector.

Vickery says air conditioners over 65kW were not included in the 65kW and under Determination (signed in March) because the measures were proposed to come into force on different dates.  For units up to 65kW, the changes will come into effect on April 1, 2020; for units over 65kW, it is proposed that the changes take effect on April 1, 2021.

The proposed MEPS requirements for units over 65kW capacity are based on a full load Annual Energy Efficiency Ratio (AEER) for cooling at 35°C (T1) and a full load Annual Coefficient of Performance (ACOP) for heating at 7°C (H1).

The “Annual” refers to the average of a year’s worth of hourly inoperative power (standby and crankcase heater power), which is added to the power input of the EER and COP equation. This effectively raises the MEPS for a unit’s operating efficiency. MEPS requirements in the NCC for units over 65kW are based on EER and COP only. According to Vickery, the difference is fairly minor.

A part-load MEPS compliance option is provided for variable-speed models. This means that suppliers only have to achieve 95 per cent of the full load (i.e., 100 per cent capacity) MEPS level if the unit demonstrates good energy efficiency at part load (i.e., 50 to 99 per cent capacity).

Vickery notes that according to the new rules, air conditioners over 65kW will need to be under AS/NZS 3823.4 to determine their seasonal energy efficiency ratings (Total Cooling Seasonal Performance Factor and Heating Seasonal Performance Factor).

“This is a significant change from what is in place now for this class of air conditioners,” he says.

The Department is looking for input on the Determination. It is especially keen to get feedback on the proposed start date of April 1, 2021, and whether this would be too disruptive for industry.

The closing date for written submissions is at 5pm AEDT on Wednesday, September 4, 2019.

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