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European law raises the ac efficiency bar

The new Eco-design directive has raised the bar for air conditioning efficiency, says David Dunn

The drive towards more efficient air conditioning has finally been enshrined in European law. The Eco-design Directive, which has been adopted by the European Commission after several years of detailed debate, has a major section devoted to the energy efficiency of air conditioning equipment.

For the first time it introduces a European-wide framework for energy efficiency targets, a process for testing manufacturers' performance claims, and accompanies the introduction of mandatory energy labels on air conditioners, similar to those displayed on domestic fridges.

The regulation (EU 206/2012) is being implemented in two stages, beginning on 1 January, 2013, with other requirements being introduced a year later.

It lays down minimum performance standards for equipment and gives detailed guidelines for the design of systems, aimed at significantly improving energy efficiency.

The requirements apply at this stage only to systems rated at or below 12kW, therefore covering the domestic and light commercial market. However, it demonstrates the direction of travel of legislators, and will have the effect of significantly raising the bar for the industry.

Focus on performance

In particular, it will require manufacturers to focus on how their equipment actually performs in practice, and provide a spur to research and development.

Those with inefficient equipment, as defined under the new legislation, will effectively either have to improve it to meet the minimum requirements or withdraw it from the market.

Why have legislators zeroed in on air conditioning? Energy consumption for most categories of power-consuming appliances is falling in developed countries, due to a combination of improved efficiency and plateauing usage, but this is not the case in relation to air conditioning.

Big strides have certainly been made by leading manufacturers in delivering more efficient products. However, the European Commission believes that continued growth in demand for air conditioning will overshadow efficiency gains in equipment, and lead to an unsustainable increase in power consumption by installed air conditioning.

To give some idea of scale: In 2005, annual electricity consumption by air conditioning equipment covered by the regulation across the EU was estimated at 30TWh. This is predicted to rise to 74TWh in 2020, unless action is taken.

The so-called summer 'brown-outs' experienced in London and other major European cities as a result of peak demand for air conditioning have underscored the issue.

By ensuring universal adoption of efficient design and best practice by manufacturers, the legislation aims to reduce average energy consumption of affected air conditioners by 40 per cent.

The combined impact of implementing Eco-design requirements, covering improved design and minimum stand-by power consumption is expected to result in annual electricity savings of 11TWh by 2020.

The new regulation introduces a fresh emphasis on Seasonal Energy Efficiency Ratio (SEER) as a measure of system efficiency, as opposed to Energy Efficiency Ratio (EER), currently more widely used. This is important because, while EER focuses on the efficiency of the unit at maximum cooling output under design conditions, SEER uses a weighted average of a unit's energy efficiency at different outdoor temperatures and cooling loads.

As a result, SEER provides a much better indicator of overall efficiency of equipment in operation in the real world.

While the legislators consider electricity consumption the most important environmental impact of air conditioners, the directive identifies refrigerant emissions as also highly significant.

No outright ban

The Commission had considered adopting rules that require the use of refrigerants with a low Global Warming Potential (GWP). A proposal to ban the use of high GWP refrigerants from 2019 was considered.

This would have impacted the use of HFC refrigerants, currently the most common fluids in use, in favour of the latest generation of HFO refrigerants. These have very low GWPs of between 4-6, compared with 1300 for R134a and 1890 for R410A.

The Commission decided against an outright ban on high GWP refrigerants within the scope of the Eco-design framework, partly because this issue is a major component of the separate F-Gas Directive, currently under review. This may yet result in further controls, or possibly even a ban on HFCs.

While drawing back from direct regulation of refrigerants, the directive attempts to steer the industry towards the use of environmentally friendlier refrigerants by setting lower minimum energy efficiency requirements for systems using low GWP refrigerants.

As a result of the changes, it seems likely that the cost of air conditioners at the lower end of the market will rise, due to the improvements in design and components specification required.

The Commission points out that any increase in capital cost for end users will be more than offset by savings in running costs over the life-time of the plant.

Overall, the effect of the directive will be to level the playing field for manufacturers. It should raise performance standards across all makes of equipment and for the first time open up manufacturers' efficiency claims to full public scrutiny.

//The author is commercial director of Toshiba Air Conditioning //
8 November 2012

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