RIS Consultation - IR Trane Input

In ge rs oll Ra nd (A us tra lia) Lt d. (A BN 59 00 4 09 9 86 1) HVAC & Transport S u i t e

B o t a n y

R o a d

A l e x a n d r i a NSW 2015, Australia Tel: +61 419 773 080

th 4 March 2016 ref: sh160304a E3 Equip ment Energy Efficie ncy Depart ment of Industr y Austral ia

RE: Consultation RIS – Air Conditioners and Chillers

I represent Ingersoll Rand for Trane branded air conditioners and chillers sold in Australia and New Zealand. Trane branded products are currently sold through a distributor Veolia Australia and New Zealand. The aim of this letter is to provide input to the RIS Consultation document published in February 2016.

1. Australia/New Zealand (chiller) specific test standard

The adoption of the AHRI test standard for chillers, the AHRI550/590 is the best option to align Australia/New Zealand to a widely accepted international standard for these products. AHRI550/590 provides certification of the performance rating software of chiller products ensuring the reliability and repeatability of the estimated performance of chiller products that are certified by this program. At the same time the Eurovent standard for products certified in Europe should also be accepted as certification of performance data for chiller equipment.

Although the RIS report states that only 24% of the GEMS registrations rely on the Eurovent certification method, I believe the quantity of units sold in Australia/New Zealand that are Eurovent certified far exceed those that are AHRI certified, due largely to European sourced air- cooled chiller products.

Adopting the AHRI550/590 test standard also means that Eurovent certified products should be re-rated to AHRI (test standard) conditions (full and part load) for comparison to MEPS requirements. This has been the practice for European sourced products which are registered in GEMS. Obviously this relies on the availability of such data from the manufacturer(s) who have registered these products in GEMS.

2. Inclusion of chillers <350 kW into the scope of GEMS (MEPS) Trane is supportive of this move to ensure consistency of the program. Most of these products (<350kW chillers) are imported into Australia/New Zealand and are generally certified to either the AHRI or Eurovent standard. As noted earlier a large portion of these products are imported from Europe and hence are Eurovent certified. The challenge to bring it into the same program is to ensure there is sufficient performance data of these products to be re-rated to the AHRI test standard especially for part load performance (IPLV). As these European products are Eurovent certified their part load rating is based on the ESEER rating which has different weightings and test conditions to the IPLV rating of AHRI. Such a re-rating can only be determined through extensive physical tests which many manufacturers may not put through their small (<350kW) chiller range through, unlike larger chillers >350kW.

Trane proposes that for these small (<350 kW) chillers to only comply with the minimum full load COP and not have a part load IPLV performance requirement. The rationale here is it is easier to re-rate a chiller at full load rather than having to produce comprehensive (certified) part load data to re-rate to a different standard. I believe there may have also been past evaluations of energy consumption of chillers in this segment to conclude that it is not a major energy consumer in this segment of chillers sold. This method may also address some concerns relating to the lack of testing facilities in Australia/New Zealand.

3. Chiller MEPS levels for <350kW

The RIS proposes to adopt the levels similar to ASHRAE 90.1-2013 for air and water-cooled chillers for sizes <350kW. Trane propose to adopt a full load efficiency only requirement.

For air-cooled chillers <350kW, Trane propose to adopt a COP of 2.70 (per MEPS AS/NZS4776.2-2008 for air-cooled chillers >350kW) and for water-cooled chillers <350kW, a COP of 4.20 (per NCC). This allows the Australian/New Zealand market to continue to have options of products from European source (Eurovent based) as well as other sources. Retaining the NCC level for water-cooled chillers <350kW will not have much impact on greenhouse gas emissions as this segment of the market is relatively small.

Summary as follows:

Chillers MEPS NCC Consultation Proposed Levels - <350kW RIS – Feb 2016 Trane COP 2.50 2.87 2.70 Air-Cooled IPLV 3.40 4.05 N/A COP 4.20 4.51 4.20 Water-Cooled IPLV 5.20 6.14 N/A

4. Modular Chillers Trane supports the inclusion of modular chillers in the GEMS / MEPS scope. Generally these are smaller than about 150kW per module. With the extension of the scope to cover <350kW range, modular chillers will be included in MEPS / GEMS Act. This product is used primarily in retrofit projects for easy access to plant rooms to replace older equipment. Due to their modular nature, the specific price per kW is rather flat and so it can be (price) uncompetitive to install several units to make up the capacity of a single larger chiller. So the notion that there was a loophole previously when these types of chillers were not MEPS regulated and used in multiple units to compete with larger (MEPS regulated) chillers is not well founded.

The application for such chillers is largely dependent on space and access requirements. More recently there is demand for higher efficiencies from this type of products with the use of VSD and EC technology in modular chillers. Inclusion of this type of products in the scope of MEPS at the module level is appropriate. Extension of the scope to the final site installed capacity is not feasible due to the nature of the product and how it is applied. Furthermore a requirement to MEPS register site specific installed capacity for such applications is not practical. This is no different to an installation of multiple larger chillers in a large chiller plant where such a requirement is not practical.

5. Other chillers currently exempt from MEPS

In the current MEPS requirements, chillers that are of the heat pump (reverse cycle), heat recovery or free-cooling types are exempt from the program. Additionally air-cooled chillers with centrifugal fans are also exempt from MEPS.

Currently there is no similar (MEPS or efficiency) requirement in the ASHRAE 90.1-2013 standard for heat pump, heat recovery and free-cooling chillers. Rather it goes by scope of the temperature or application. If the chiller makes hot water higher than 115⁰F (46.1⁰C), then it is outside of the scope of ASHRAE 90.1-2013. This is generally the case for heat pump and heat recovery chillers. Furthermore in some cooler climates the choice of the heat pump chiller is mainly (although may not be exclusively) for heating, and as such the heat pump chiller’s performance is selected for the heating function (capacity and efficiency) rather than for cooling. It is not uncommon to see a heat pump chiller’s COP in the heating function being higher than the corresponding COP in the cooling function. If these chillers are included in the scope of MEPS, a new level of MEPS needs to be defined since these are not conventional cooling only chillers. Currently this type of chillers is outside the scope of ASHRAE 90.1-2013.

For free-cooling chillers, the mechanical cooling function is generally less efficient than a conventional chiller as a result of additional heat exchanger installed in the condenser to take advantage of cold climate conditions to produce cooling without (or much lower power consumption) compressor operation. Such free-cooling chillers are designed to save energy in cool climate conditions with some compromise in mechanical cooling mode. Just like heat pump chillers, if these chillers are included in the scope of MEPS, a new level of MEPS needs to be defined. Air-cooled chillers that have centrifugal fans are selected for use in areas where a ducted arrangement from the condenser is required generally due to the location of the chiller. As a result of the use of centrifugal fans to overcome the additional resistance, the chiller will have higher energy consumption and hence lower COP. Such chillers should not be included as part of the regular cooling only MEPS program.

6. MEPS Alignment to ASHRAE 90.1-2013

Trane agrees with the adoption of the efficiency levels from ASHRAE 90.1-2013 in general and as proposed by the Consultation RIS (Table 7), with the exception of part load requirements for chillers <350kW.

The use of the lower of the COP/IPLV values in ASHRAE 90.1-2013 Path A and Path B is acceptable.

7. Inclusion of air conditioners >65kW in MEPS

This proposal requires harmonization of firstly the test standard and secondly the MEPS level of the product. A portion of the large air conditioners >65kW are imported into Australia/New Zealand and are generally AHRI or Eurovent certified products. In the US such products’ performance is certified to AHRI 210/240 and AHRI 340/360. The minimum efficiency levels for these products are include in ASHRAE 90.1-2013 standard in the air-cooled unitary, water- cooled unitary and the air-to-air heat pump sections. Due to the size of the product, Trane propose that the international standards (AHRI and Eurovent) be made the acceptable certification for performance data, just like for chillers. There is a lack of test facilities in Australia/New Zealand for such products. Furthermore the HPRATE method of predicting air conditioner performance (for small air conditioners) is not used for compliance purpose outside of Australia/New Zealand.

The current GEMS registration requires compliance either by means of actual test reports or HPRATE simulation. This works for smaller air conditioner equipment generally <20-30kW where there are local test labs available for check testing. For larger air conditioners including >65kW, Trane propose that an international standard(s) and certification method (AHRI, Eurovent) be made acceptable as the test standard and certification of performance. In fact this should be a general direction for all air conditioners covered in MEPS.

The Consultation RIS propose to adopt a MEPS level for air conditioners >65kW of Option A as COP 2.70/2.80 for cooling only units and COP 2.60/2.70 for reverse cycle (Table 5). For Option B1/B2, the Consultation RIS propose increasing these levels to 2.90 to match the current GEMS Act levels for air conditioners of 39 to 65kW..

Trane supports Option A in the Consultation RIS but the test method and certification path needs to be per international standard as explained earlier. Note also that the proposed COP level for Option B1/B2 is even higher than ASHRAE 90.1-2013 for air-to-air heat pumps (COP 2.78) for a similar capacity range.

I trust this document provides the Department with a practical and balanced viewpoint of the Consultation RIS. Should you require further information or clarification on the points in this letter, please do not hesitate to contact myself.

Yours faithfully,

Simon Ho

Business Leader HVAC & Transport Australia & NZ Ingersoll Rand Australia

Cc: Paul Goodison Veolia Australia and New Zealand