Department of the Environment and Energy s1

Dear Sir, Department of the Environment and Energy Australia

I write as a representative of Ingersoll Rand, parent company of Trane, a brand of commercial air conditioners and chillers distributed in Australia and New Zealand via our distributor, Veolia Australia and New Zealand, to provide input to the aforementioned RIS supplementary consultation issued in November 2016.

Previously I had written in response to the first version of this RIS and would add the following comments in response to the supplementary consultation document. In summary:

Responses to Policy Proposal 5, 6 and 7:

 Trane supports the inclusion of chillers <350kW under MEPS with full load requirements only

 Trane supports the inclusion of A/C >65kW under MEPS but the MEPS levels should not exceed those in ASHRAE 90.1 standard (for sizes >65kW) o For heat pumps the ASHRAE 90.1 COP for a 70kW unit is 2.72 (not 2.90 as proposed) o Furthermore the method of performance/test validation should include international test standards AHRI and/or Eurovent, and not just the current method used in the MEPS for A/C less than 65kW. Just like chillers, a certified unit to AHRI or Eurovent should have its performance accepted as the test standard and not having to go through actual lab tests or modelled by simulation method.

Responses to Policy Proposal 11:

 Trane does not support the removal of MEPS requirements for all water-cooled and air-cooled chillers >700kW. Such a move will allow lower efficiency of chillers sold and allow cheaper chiller products to be introduced into the market to compete with the current standards upheld by the MEPS program.  At Trane we selectively put together a portfolio of products that could meet MEPS and be sold into the Australian and NZ markets. This is generally true for most major manufacturers to have a range of standard (relatively lower) efficiency models as well as high efficiency models, including the use of variable speed drives to position the products for respective markets, customers and regulations across different countries.  Hence this proposal to remove MEPS for chillers 700kW and larger would likely introduce more competitive and less efficient products into our market with the corresponding effect of increase our greenhouse emissions.  If the intent is to minimize the work and costs needed to register all units sold (by removing the MEPS requirement for chillers >700kW) then a more effective solution would be to adopt a requirement for certification of the products either to AHRI or Eurovent in order to demonstrate compliance to MEPS without having to register at all. For those products which are not certified, then a test report is required and hence model registration. However this may require more compliance (policing) effort. Furthermore there will be little visibility to the state of what is sold in the market with the loss of the MEPS register of complying products.

I hope this feedback information is useful to the Department in formulating its Policies. Should you have any questions please do not hesitate to contact me directly.

Regards,

Simon Ho Business Leader, HVAC & Transport ANZ Region

Ingersoll Rand HVAC & Transport (Trane & Thermo King) m: +61-419-773-080 e: [email protected] w: www.trane.com & www.thermoking.com