EHPA suggestion We thus suggest to integrate waste heat recovery into the aligned test standards.

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1 EHPA review of the documents on possible requirements for air heating, cooling products and high temperature process chillers (Ecodesign ENTR Lot 6 / ENER Lot 21) EHPA, as the representative of the European heat pump industry, has reviewed the documents received in 2013 and wants to raise the following issues with regards to heat pumps! European Heat Pump Association Renewable Energy House Rue d Arlon B-1040 Brussels Belgium Phone Fax Annex III, 4)c: Seasonal efficiency calculation for engine driven gas heat pump (eghp 1 ) Internal combustion engine heat pumps recover the waste heat from the engine and make it useful for heating. The amount of recovered energy is available to the process and thus increases its efficiency. Thus it needs to be integrated into the calculation of the seasonal efficiency, in particular in the calculation of the SEER value. info@ehpa.org President: Karl Ochsner Contact: Thomas Nowak Secretary General Phone Thomas.Nowak@ehpa.org Excluding it instead would artificially reduce the unit's efficiency and may even harm the potential to reach the minimum efficiency requirements. We would like to underline, that engine driven heat pumps are a promising, but relatively new technology in the market. They are a type of heat pump that helps to fulfill the heating and cooling requirements of certain applications, including renewables and increasing efficiency. The opportunity of this contribution is special in the Mediterranean countries where both heating and cooling services are required The proposed measure does not take the specificities of eghp into consideration and is risking the exclusion of gas engine driven heat pumps from the European market. We thus suggest to integrate waste heat recovery into the aligned test standards. 2. Annex II, 5): NOx emissions of eghp The working document proposes to calculate the NOx limit based on fuel input, which is a common approach derived from the gas boiler technology. We disagree with this approach, as it does not give meaningful information for the emissions of eghp in real operation. NOx emissions depend on several parameters (outside temperature, engine rpm, gas refrigerant pressure etc.) and it varies (at standard rating conditions) between 300 mg/kw and 1200 mg/kw. Currently, no harmonized standard for the calculation of the efficiency and the determination of the related NOx emission exists. Obviously, both must use the same rating point and include part load operation. CEN/TC 299 WG3 is working on the elaboration of the approach and will integrate it into the future EN standard for eghp. Until this is a standard, we suggest referring to a seasonal calculation of efficiency and related NOx emissions. The existing Japanese standard JIS B :2006 could serve as guidance. 1 eghp = internal combustion engine gas heat pump

2 Indoor Outdoor DB WB DB WB Gas Type 13A ppm mg/kwh (G20) Name Capacity ppm mg/kwh A 45kW unit B 45kW unit C 56kW unit E 56kW unit E 71kW unit F 71kW unit G 85kW unit H 85kW unit Table 1: NOx emission values at rating point operation As the data presented in table 1 shows the limit set in the current working document - 240mg/kWh GCV fuel input - is not reachable for any eghp manufacturer today. In order to avoid banning this product group from the market, we suggest a change of the reference from mg/kwh GCV fuel input to an average value based on a the energy output in seasonal operation 3. Annex II, 4): Sound power requirements have to be deleted: There is a direct relation between efficiency and sound power. In consequence, stricter sound power requirements can only be achieved at the expense of efficiency. The currently proposed 2- tiered requirements are far beyond the requirements of other lots, without any rationale being found in the report for such ambition. It is unclear why an Ecodesign measure would value sound power higher than efficiency, in particular as the products in scope of this lot are usually installed and operated in a non- residential environment where the level of sound emissions is of less importance while efficiency directly affects operation cost. In addition, the products in scope are subject to local legislation and consumer requirements. These products are also already covered by the machinery directive and therefore should not be regulated 3 times for sound issues (locally, machinery, Ecodesign). Thus, the product choice should be left to the consumer with no unnecessary requirements on the sound power level being imposed by the measure. The sound power requirements should be deleted. Page 2 of 5

3 4. General: We support in general the conversion to primary efficiency both on cooling and heating. This approach is in line with the other Lots and should be kept across all legislation. EHPA would like to stress that the primary energy factor used should be updated in regular intervals to accommodate for the greening of the electricity mix. 5. Annex II, 2): The energy efficiency requirements for aircooled and watercooled chillers are too ambitious and have to be reduced: Current requirements are banning over 92% from the products currently on the market. Thus they reduce consumer choice and increase cost, as the top- class products are super- proportionally more expensive. In order to keep a sufficient range of affordable products in the market, we strongly recommend to reduce the requirements for the chillers. The same applies to the requirements for watercooled chillers above 400kW. They can only be met by oil- free technology currently produced by not more than one manufacturer. In order to overcome such a limitation of the market, we suggest to introduce a new capacity class, starting from 1500kW, and re- address the requirements accordingly. Based on Eurovent data, we propose to set the requirements as shown. This is still an ambitious target, but allows manufacturers to improve efficiency in line with typical product development cycles. 6. Annex II, 1): All heat pumps should have the same efficiency requirements, regardless of the energy source used: Products providing the same function should be subject to the same requirements! We do not see the need for different requirements for gas driven and electric driven heat pumps. We strongly request to align the requirements - as also done in ENER Lot 1 between fossil and electric technologies - again based on primary energy. Page 3 of 5

4 7. Annex III, Table 29: The hours to calculate the efficiency should consider reversible products: In the current proposal, only hours for cooling only and heating only are specified. For reversible products different hours are required as the off mode is considered to be 0. This was included already in Ecodesign lot 10 (2012/206/EU) and should be integrated here. We propose to apply the following hours for reversible products: Heating SCOP Reversible products Operational hours On mode (equivalent hours) Thermostat off mode Standby mode Off mode H CE H TO H SB H OFF H CK Average Colder Warmer Crankcase heater mode 9. General: We support the fact that the measure starts in January. This is appreciable as this coincides with the cycle of producing the catalogues for these products 10. Annex II, 6) x: The product information requirement to provide a list of combinations recommended by the manufacturer is complicated, and will result, due to the enormous amount of combinations in an overload of information: It should be understood that this requirements can never be met for VRF systems. The possible combinations for these products are unlimited. Such a product is designed to combine with more than 100 indoor units. Each indoor unit is selected based on the need of the room and can be wall mounted, ceiling suspended or floor standing. For each indoor unit several capacities are available. The possible number of combination is over 1 million. Typically a VRF system is custom- made towards the building and the engineers are provided with a full list of outdoor units and a full list of indoor units, where all features are explained and they can combine what they want and derive based upon the databook the efficiency of the total system. This is the current practice and cannot be altered. We strongly recommend to remove this requirement and maintain current practice. 11. Chapter 2, 76): The degradation coefficient specified in the tables should be modified based on the technology. In this definition, the default degradation coefficient is 0.9 for chillers, airconditioners and heat pumps. This is not according to the standard EN14825, ENER lot 1 and ENER lot 10. The degradation coefficient is dependent on whether the system distributes heat/ cooling by air or by water. Therefore the sentence: if Cd is not determined by measurement then the default degradation shall be Cd = 0.9. should be replaced by : If Cd is not determined by measurement, then, for air to air and water to air units the default degradation shall be Cd = 0.25; for air to water and water/brine to water units the default the degradation coefficient shall be Cd = 0.9. Page 4 of 5

5 12. Annex III, 4)c: SEER calculation It should be possible to base the SEER calculation on variable water temperature, as described by EN This is a very important aspect for increasing seasonal efficiency of HP and Chillers alike 13. Full load efficiency of chillers The increase of full load efficiency from 2.6 to 2.8 in A/W chiller category is particularly challenging especially for those systems (<400kW) that will require variable speed technology to achieve the seasonal performance targets. Limit the EER increase for the Tier 2 to 2.7 About EHPA: The European Heat Pump Association (EHPA, promotes awareness and proper deployment of heat pump technology in the European market place for residential, commercial and industrial applications. EHPA has 107 members from 22 European countries representing the majority of actors in the European heat pump industry. The association aims to provide technical and economic input to European, national and local authorities in legislative, regulatory and energy efficiency matters. All activities are aimed at overcoming market barriers and dissemination of information in order to speed up market development of heat pumps for heating, cooling and hot water production. It is the declared aim of the association to make heat pumps a core technology in the development towards a more energy efficient, RES-based, sustainable energy system. Page 5 of 5