energy efficiency and conservation authority po box 388 · energy efficiency and conservation...

27 January 2017

Energy Efficiency and Conservation Authority PO Box 388 Wellington 6140

Attention: Lisa Sinclair

Dear Madam

Cooke Industries Limited

31 Station Rd, Penrose, Auckland, New Zealand PO Box 12021, Penrose, Auckland 1642

Telephone: (64 9) 579 2185 Facsimile: (64 9) 579 2181

E-mail: [email protected]

Re: MEPS Consultation Chillers and Packaged Units

Thank you for the opportunity to offer a submission on the changes to the MEPS regulations for Chillers and Rooftop Package Units.

We supply class leading European designed and manufactured water chillers and rooftop units into New Zealand.

We have included technical information and pricing with this submission and while some of the data you may use, we would request that the submission be kept confidential.

We have broken down the submission into:

Chillers: Information pertaining to the RIS document for Chillers

Rooftop Units: Information pertaining to the RIS document for Rooftop Package Units

Addendum 1: Breakdown in the quantities of Chillers, Heat Pumps and Multifunction Heat Pumps sold in New Zealand by Cooke Industries - Confidential

Addendum 2: Capacity, Efficiencies, Part Load Efficiencies and Price Breakdown for our primary range of air cooled chillers from 4kW to 1400kW in both the standard (generally Eurovent Class C) and the higher efficiency (generally Eurovent Class A) ranges. Where AHRI standard COP and IPLV data was available we have included this as well. Confidential

With regard to Addendum 2, we note that this confidential information has been provided per your request in our meeting for the purpose of comparison between the two current efficiency ranges. The pricing is a budget cost for the standard unit in NZD including refrigerant charges. Please note that there are higher efficiency models continuously being released, with a range of air-cooled chillers with EERs in the 3.5 band, due out in February this year. From inspection of the medium and larger size units, there is approximately a 1% price increase for every 1% increase in efficiency when comparing units of similar output. This rule of thumb does not hold for the very small units (<50kW)

We trust that the this meet your requirements. Please let us know if you need further clarification.

Yours faithfully COOKE INDUSTRIES LTD

Andrew Cooke Managing Director

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P:\Technical\MEPS\MEPS Consultation RIS Policy Options.docx

Consultation RIS Policy Options

Chillers 4: Remove the Australian/New Zealand chiller test standard and align with the US

We feel that the removal of the AS/NZS4776 standard would be good step forward, but relying only on the AHRI Standard 551/591 will unduly affect the supply of chillers supplied from the European market, which are tested to the EN14511-1 (2013) standard. Chillers rated to the European standard are the predominant supply into the New Zealand market.

The EN14511 standard was updated in 2013, to include an allowance for the power absorbed by the primary pump to overcome the internal resistance of the evaporator heat exchanger in the performance EER/COP. The difference in EER values between EN14511 (2011) and EN14511 (2013) vary according to chiller size, but range from 1% to 2.5% difference.

Also, there are significant differences between the part load ratings, the AHRI IPLV rating and the Eurovent ESEER rating, in both the ambient temperatures, fouling factors, and the individual weighting of different load conditions. The differences between the two rating methods is approximately 12%, with the IPLV giving a higher value.

Thus, we feel a dual compliance to the standard should be allowed.

In summary

EER = COP (EER pre-2013)

EER (2013) is approximately EER – 1.5%. EER (2013) includes pump power to overcome internal water losses.

ESEER is approximately IPLV + 12.0%. (varied from +11.6% to +12.5%). This is a result of the weighting and the temperatures used at the part loads. IPLV uses lower part load temperatures.

While the two part-load performances are for comparative purposes, how many chillers are running at 45% load at 18.5°C and at 25% load at 12.7°C. The ESEER is a more realistic part load performance to real life for New Zealand conditions.

ESEER Air Cooled Ambient

Water Cooled Ambient Weighting

100 35.0°C 30.0°C 3%

75 30.0°C 26.0°C 33%

50 25.0°C 22.0°C 41%

25 20.0°C 18.0°C 23%

IPLV Air Cooled Ambient

Water Cooled Ambient Weighting

100 35.0°C 29.4°C 1%

75 26.7°C 23.9°C 42%

50 18.3°C 18.3°C 45%

25 12.8°C 18.3°C 12%

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5: Remove NCC regulated chillers and a/c and replace with GEMS/New Zealand regulations

As per the Policy Option 4, this will affect the supply of units that are solely Eurovent rated. We feel that this will unduly effect the supply of chillers supplied from the European market, as the testing performed is to a different standard that was updated in 2013, to include an allowance for a pump input required to overcome the internal water losses in the EER performance. This effects the EER more as the units become smaller reducing the peak EER. Even the highest efficiency small chillers currently on the market could not achieve the required COP if a single standard of test was kept.

With this proposal, there is even more reason to use a dual compliance to the standard.

We feel that option 1 should be allowed but with Eurovent having its own rating due to the pump requirements and differences in the part load temperatures.

Additionally, as the chiller output reduces, the EER reduces as well. This is particularly evident in chillers in the range 5kW to 50kW. These small chillers, which are predominantly European in origin, would struggle to achieve an EER 2.7 across for the whole range. We feel that for chillers below 25KW should have a EER (COP) of 2.5.

With DC based inverter technology compressors in smaller chillers, achieving an ESEER of 3.7 is eminently achievable and should not impact the supply of chillers.

7: Align >65 kW A/C MEPS levels to 39 to 65 kW GEMS and chiller MEPS levels to the ASHRAE levels

We see no problem in increasing air cooled chiller to align with MEPS ASHRAE levels.

We however feel that if chillers <350kW are included, the MEPS levels should be:

<50kW at an EER of 2.7

<25kW at an EER of 2.5.

12. (New policy proposal) Remove MEPS requirements for all water-cooled chillers and for air-cooled chillersof 700kW capacity or greater

We feel that removal of MEPS requirements for water cooled chillers and air cooled chillers above 700 kW would be a retrograde step, although it would potentially advantage us in the water-cooled market.

Without a stick approach of regulation or other contractual obligation, developers and contactors will generally fit the lowest capital cost chiller, irrespective of total cost of ownership. Removal of these requirements altogether will allow a lot of inefficient and/or old-technology product into the market.

Currently many Eurovent A Class rated water chillers above 700kW do not quite meet the current MEPS requirements, which seem targeted at flooded evaporator vessels and variable speed compressor technology.

As the European suppliers have developed water-cooled chillers with the Eurovent targets in mind, where MEPS requirements are above this, this leads to a lot of European product been excluded from the market.

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Eurovent Chiller Class Tables

Cooling Mode

EER Class Air Cooled Air Cooled

ducted Air Cooled

Floor Water Cooled

Water Cooled Floor

Remote Condenser

A ≥ 3.1 ≥ 2.7 ≥ 3.8 ≥ 5.05 ≥ 5.1 ≥ 3.55

B 2.9 - 3.1 2.5 - 2.7 3.65 - 3.8 4.65 - 5.05 4.9 - 5.1 3.4 - 3.55

C 2.7 - 2.9 2.3 - 2.5 3.5 - 3.65 4.25 - 4.65 4.7 - 4.9 3.25 - 3.4

D 2.5 - 2.7 2.1 -2.3 3.35 - 3.5 3.85 - 4.25 4.5 - 4.7 3.1 - 3.25

E 2.3 - 2.5 1.9 - 2.1 3.2 - 3.35 3.45 -- 3.85 4.3 - 4.5 2.95 - 3.1

F 2.1 - 2.3 1.7 - 1.9 3.05 - 3.2 3.05 - 3.45 4.1 - 4.3 2.8 - 2.95

G < 2.1 < 1.7 < 3.05 < 3.05 < 4.1 < 2.8

Heating Mode

COP Class Air Cooled Air Cooled

Ducted Air Cooled

Floor Water Cooled

Water Cooled Floor

A ≥ 3.2 ≥ 3.0 ≥ 4.05 ≥ 4.45 ≥ 4.5

B 3.0 - 3.2 2.8 - 3.0 3.9 - 4.05 4.15 - 4.45 4.25 - 4.5

C 2.8 - 3.0 2.6 - 2.8 3.75 - 3.9 3.85 - 4.15 4.0 - 4.25

D 2.6 - 2.8 2.4 - 2.6 3.6 - 3.75 3.55 - 3.85 3.75 - 4.0

E 2.4 - 2.6 2.2 - 2.4 3.45 - 3.6 3.25 - 3.55 3.5 - 3.75

F 2.2 - 2.4 2.0 - 2.2 3.3 - 3.45 2.95 - 3.25 3.25 - 3.5

G < 2.2 < 2.0 < 3.3 < 2.95 < 3.25

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Questions Asked in the Documents

Is energy efficiency the main reason to install a water-cooled chiller?

Mostly. It is also used when air-cooled chillers struggle with high ambient conditions. As NewZealand is a more temperate climate, we have a much higher prevalence of air cooled chillers andheat pumps.

Is there a need to maintain MEPS for water-cooled chillers? If yes, why?

We feel there is a need for MEPS for water cooled chillers, however it should be aligned withEurovent A Class.

Are air-cooled MEPS requirements appropriate in providing an energy performance floor for the chiller market? Is a MEPS level necessary for products beyond 700kW? Is there another threshold that is more appropriate?

We feel that the levels above 700KW should be at least aligned with A class Eurovent levels. Thisis already a high mark, and will ensure that the general principal of setting a high efficiencybenchmark/goal is maintained. Without this benchmark level, then it is open slather on lowefficiency products in the market, and a certain portion of the market will move in this direction.

What are the most important things that buyers search for in chillers (please explain and rank)? Where does energy efficiency and running costs rank?

This is somewhat dependent upon whether a project is owner/user driven, or developer/contactordriven.

For Owner / User, it is based on total cost of ownership / reliability / back up service

For Developer, it is based on lowest installed cost followed by reliability

Are buyers optimising their total costs (including purchase, installation, maintenance and running costs)? If not, why not?

Generally only those buyers who are the end users. For the majority of the market, which is lowestprice tender driven, they are fitting the most economical capital cost solution they can get awaywith.

What proportion of buyers could benefit from considering energy use in their purchase decision?

We believe that setting revised MEPS benchmarks would affect at least 80% of the market.

What unintended outcomes might arise from increasing the energy efficiency requirements for chillers? Please explain and give examples if possible.

It will cut out some of the less efficient product. This product has less airflow, smaller heatexchanger surface area and smaller coils. The result of the increase in efficiency is that the chillerswill be larger. This may negatively affect the replacement market, as some of the newer units willnot fit in the space.

If the energy efficiency regulatory costs for water-cooled chillers are removed, would buyers be more likely to purchase them than an air-cooled chiller than they are now? Or are the regulatory costs relatively minor?

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The regulatory costs are not particularly significant for the New Zealand market. This is not thecase in Australia. We feel with the use of heat pumps and multifunction units on the rise, theremoval of requirements of the water-cooled chillers over 700kW will not affect the use of thesechillers as to air cooled. We are more likely to see a shift to multifunction units due to the increasedoverall efficiencies of these machines.

Reverse Cycle Heat Pumps

We feel that most of the product we sell is Eurovent based heat pumps or chillers below 350kW. The figures that you have for chillers is much aligned with the AHRI testing due to the size of chillers sold. If heat pumps and small chillers were included, you would have a very different picture of what is being sold in New Zealand. Refer to addendum 1.

We feel that all heat pumps should be included, even if the just must meet the MEPS requirement for cooling with a declaration of the heating performance.

We have seen very low efficiency heat pumps offered and installed on projects. This is again as a result of the supplier offering equipment that is the lowest cost of supply, rather than the lowest cost of ownership. One particular example we have seen was for a local government facility running 365/24/7, where a Eurovent D-class heatpump was used. The limits for this class is an EER of 2.1 to 2.3, where the MEPS requirement for cooling is 2.7 for that size of chiller.

Adiabatic (evaporative) chillers

We feel that adiabatic chillers should be included at standard test conditions. Adiabatic cooling increases the performance by pre-cooling the air before it goes through the main condenser coil, thus improving the efficiency at peak ambient temperatures. They do not have significant improvement at lower temperatures, and as such should be included, as the majority of the running time is spent operating with little need of the adiabatic feature.

Free-Cooling Chillers

These are normally a standard chiller with an extra feature of an additional coil to enable free cooling when the ambient is lower than the return water temperature. Because this is only available for a restricted period of time at low ambient air temperatures, the majority of the running time will be as a normal chiller, and therefore these units need to be included in E3.

Heat Recovery Chillers

These are normally a standard chiller with an extra feature such as a desuperheater or total heat recovery exchanger to recover the condenser heat. As such, the base chiller (the same chiller without the heat recovery option) should be included in E3. This will prevent circumvention of the rules as per heat pumps above.

High Static Propeller Fans

We feel that chillers with high static fans should be excluded from MEPS. By high static, we are generally referring to centrifugal fans, not “high static” versions of the standard axial condenser fans.

The effect of the extra power reduces efficiency, and these are typically used in very specific applications where a normal chiller would not work.

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Rooftop Package Units

About MEPS and Rooftop Package Units.

Alternative Pathway for Certification of Rooftop Units

We feel that Eurovent Certified product should be looked at as an alternative pathway to certification, if they meet energy requirements. These units are tested in an independent lab and certified to EN14511 2013.

Exemption for units designed specifically to run with exhaust air heat recovery and active refrigeration heat recovery.

There is no pathway for certification of product that is specifically designed to have heat recovery built into the units. These units have a nominal design fresh air airflow of either 30% for standard units and 80% for high occupancy units, and incorporate a return air fan, which is not taken as a variable in the current testing system. The current Australian standard relies on 100% recirculation, with no fresh air component.

The additional fan power of the return air fan adds a distinct disadvantage to meeting the MEPS requirements, as the additional absorbed power of the fan is added to the total power input under the current calculation methodology.

There are two heat recovery options currently employed:

With the return air exhausted over the outdoor condenser coil (under favourable conditions)

With a heat recovery coil in the exhaust air path prior to exhausting over the outdoor condensercoil (under favourable conditions).

When operating at standard conditions, the addition of a return air fan and/or heat recovery coil means these units are slightly less efficient than units without heat recovery. However, when conditions are less favourable, the heat recovery significantly improves the efficiency. This has the effect of maintaining the cooling and heating performance at higher efficiencies when competitor units without heat recovery lose both efficiency and performance.

As an example, comparing a competitor MEPS approved unit to a Clivet CKN 101 CKK (with heat recovery on the outdoor coil)

Clivet Unit Heating Capacity at 20°C indoor & 7°C Outdoor 38.3kW heating Gross (38.3 Net) COP 4.87 (refrigeration only) Heating Capacity at 20°C indoor & -5°C Outdoor 29.6kW heating Gross (26.3 Net) COP 5.01 (refrigeration only)

Competitor Heating Capacity at 20°C indoor & 7°C Outdoor 37.8kW heating Gross (37.8 Net) COP information not available Heating Capacity at 20°C indoor & -5°C Outdoor 25.3kW heating Gross (22.8 Net) COP information not available

Looking at active heat recovery from Clivet called THOR

As an example of a unit with active heat recovery These are all with 30% outdoor air. Clivet CSRN 30.2 CCKP at nominal 17000m³/h (with refrigerant heat recovery) Heating Capacity at 20°C indoor & 7°C Outdoor 103.kW heating 20.5kW compressor input COP 5.02 (refrigeration only) Heating Capacity at 20°C indoor & -5°C Outdoor 78.2kW heating 16.5kW compressor input COP 4.74 (refrigeration only)

As an example of a unit with active heat recovery These are all with 80% outdoor air. Clivet CSNX 40.2 CCKP at nominal 16000m³/h (with refrigerant heat recovery) Heating Capacity at 20°C indoor & 7°C Outdoor 149.2kW heating 25.1kW compressor input COP 5.94 (refrigeration only) Heating Capacity at 20°C indoor & -5°C Outdoor 121.1kW heating 18.3kW compressor input COP 6.62 (refrigeration only)

With most of the units that are supplied into NZ, especially in the South Island, spending a large part of their operation in heating mode, and subjected to more extreme low temperatures, we have looked specifically at the heating duties. The same is also evident for extremes in cooling conditions, but we do not experience the extremes as seen in Australia.

We feel that units with this should be exempted from MEPS. They are very efficient units in their own right, but do not conform the testing standard.

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Addendum 1 - Sales of Chillers (Confidential) Breakdown of Sales This was requested during the consultation meeting held in Auckland last year. This is for the chillers, heat pump chillers and multifunction chiller sales taken over a recent period, taking the last 100 units supplied in New Zealand.

This shows the need to implement MEPS below 350kW and the need to introduce MEPS for heat pumps as well.