Submission to the Energy Efficiency and Conservation Authority

Lassele Refrigeration Pty Ltd

Office 11 Kentia Crt., Elanora Q. 4221 Ph. 0408 185603 Email [email protected]

30th August 2016

A. Background. Our Company has been is an importer of self- contained food storage refrigerators and freezer cabinets for over 10 years. Prior to this period the Company principal has been employed in the sales and design area for three major commercial refrigeration manufacturers. Overall industry experience is 28 years.

B. Comment In the writers opinion and experience there is little to be gained in energy savings and ozone protection by including self- contained solid door storage refrigeration and freezers into the MEPS regulations.

With the configuration for this class of solid door self- contained cabinets being a closed fully insulated space, 95% of cabinets produced within the last 10 years and 100% of current market models have injected closed cell polyurethane insulation, efficient refrigeration systems and a small refrigerant charge weight. This class of cabinets by inputs of strong market competition and manufacturing costs is already very energy efficient.

We presume the definition of a inefficient versus an efficient energy use cabinet it would have to be the calculation of energy use as a factor of net storage area. This will be an interesting standard to quantify and need to factor in the “real world ” ambient and humidity conditions. The current MEPS 25 C ambient and 60% R/h certainly do not exist in most commercial kitchens ( and storage areas)

We must declare our own interest in this cabinet class but we genuinely believe that the resulting overall energy saving that could be achieved in this cabinet class will be an insignificant percentage of the total energy use in the commercial refrigeration / air conditioning sector ; vs the considerable cost to the Importer of registering to the existing MEPS and to the Regulatory Body of implementing and regulating a MEPS type system.

C. Submissions 1..We submit that self- contained block door storage cabinets, with less than 500 grams of refrigerant be exempt from a MEPS regulation

2. Energy Star Rating In preference we do however consider and support an Energy Star type rating system similar to the domestic refrigeration area. This is also being used in other Countries for this class of cabinet. We would prefer for it to be voluntary as we believe it will be quickly become a necessary marketing/sales feature when the end user can clearly identify the difference in energy use of competing Brands.

We know that the present MEPS register is not consulted in any purchase decision of a refrigerated Display cabinet and a voluntary Energy Star rating will involve little or nil regulatory costs.

3. Glass door merchandisers / display cabinets not to be used as substitutes for food storage. Here is one clear area were energy efficiency for food storage can be immediately improved. No glass door cabinet can achieve the energy efficiency of a solid door cabinet but in a high percentage of operations, because of the lower capital cost, they are used for food storage. It is also the most likely location and “last life” use for the old and most inefficient cabinets. This can be achieved simply by Health Authorities enforcing the food safe interior surfaces (ie s/steel) that do not exist in most glass door display cabinets.

D. Priority Areas for Meaningful Energy and ODP Savings

Just in the Commercial Refrigeration sector ( not even the whole HVAC sector) there are clearly identifiable areas that real meaningful energy reduction can be achieved. Self contained cabinet efficiency, with all due respect, is just fiddling around the edge of the whole issue.

Examples.

-Remote Installations such as Coolrooms / Freezer Rooms and Display cabinet line ups.

- The continued use of open display cabinets and freezer cases.

-The lack of maintenance on over 2 kg systems.

NB This is where the real loss of refrigerants into the atmosphere also occurs.

Yours faithfully

A R ( Tony) Anderson Director Lassele Refrigeration Pty Ltd