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According to a CIPH statement, the institute also warned that other negative impacts created by these proposals could include the following:
• Burden of enforcement will shift to individual municipalities as manufacturers and wholesalers cannot be accountable for differing product application such as replacement or new construction;
• Increases in product costs due to the high research, development, and production costs necessary to meet a Canada-only efficiency standard may result in a loss of Canadian manufacturing jobs.
• Differing protocols for different sizes and fuel types create difficulty for manufacturers to meet prescribed results. Since there is no singular metric to report test results, there should be consideration given for a revised compliance range when a product is tested with one fuel and reported for another.
• The potential loss of fuel-oil options will have the greatest negative impact in Aboriginal, northern, and Atlantic communities.
• Optimal performance of condensing units is sensitive to proper system design and installation. Rapid changes to regulations will not allow sufficient time for building codes, engineering, and installation practices to properly adjust. This may result in gaps of product performance and public safety.
• Non-alignment of performance target timing with those of the U.S. Department of Energy beyond 2012 will discourage provincial/territorial adoption and harmonization.
To avoid these potential negative impacts, CIPH recommended a revised performance and compliance schedule. Its key recommendation is that no performance standards beyond March 2, 2015, be considered at this time.
According to CIPH, the institute believes its recommendations “will accomplish the shared goals of higher energy-efficiency in a manner that will create higher adoption rates at lower cost while reducing the negative impacts on the Canadian market.”
The institute added that the benefits of its recommendations include the following:
• Creation of a stable regulatory environment will encourage Canadian manufacturers to invest in the development and testing of new technologies and green jobs.
• Establishment of more aggressive standards in Canada than the U.S. for 2015 will keep Canada at the forefront of environmental stewardship.
• Recognition that condensing technology for oil-fired boilers may not be technically achievable in the near future.
• Measured time frames will allow for needed changes to building codes and standards. This time is also necessary for adequate training of installers for condensing technology.
• Widespread availability of condensing units by 2015 will create enhanced opportunity for an industry and utility-led market transformation to achieve the stated goals of NRCan without the need for regulation.
• A consensus-driven market transformation model will allow for orderly adjustment of system design and engineering principles and practice.
According to CIPH, its member boiler manufacturers are prepared to meet with NRCan if necessary to provide any additional information that may be necessary.
For a copy of the draft regulation proposed by NRCan, visit http://oee.nrcan.gc.ca/regulations/bulletin/boilers-aug-2010.cfm?attr=4.
Publication date: 11/01/2010