CEN/TC 62 (Independent Gas Fire Space Heaters) response to DG energy use working document on possible eco-design and energy labelling requirements for local space heaters (Lot 15 local heaters and Lot 20 combined) This response focuses purely on gas-fired local space heaters used in domestic dwellings but will also address the combined labelling of biomass gas or oil and electric heating. CEN/TC 62 embraces the objectives of the eco-design and energy labelling requirements and this response has been developed with the aim of ensuring that the requirements are delivered into the market. We are concerned that currently there are aspects of the document which we believe are detrimental to the objectives the commission is looking to meet and we have therefore proposed how we believe they can be delivered into the market. These appliances are often used as the only source of heating in the property and therefore it is essential to get the mechanics right to influence the consumer. First of all we would like to make some general comments about the proposals and then provide more detailed views against the sections of the working document which we strongly believe should be considered by the commission as part of its consultation process. We should point out that there are some particular issues that we believe will cause market failure in some European markets, resulting in a reduction in the overall size of the market and would have a direct impact on the number of people employed in the sector - which we believe is not an outcome the commission is looking for as a possible unintended consequence. Seasonal efficiency Considering the fact that CEN/TC 62 current standards are based on nominal efficiency a revision of those standards is necessary to take into account the seasonal efficiency. Without elements on the calculation method that will be retained it is not possible for CEN TC 62 to express an opinion on the values proposed in the draft document. Energy Labelling The majority of CEN TC 62 would prefer to see an individual label for each of the proposed fuels - in other words solid fuel, gas, oil and electricity - which the current proposal combines together, using different efficiency calculations. Each of the fuels efficiencies has been calculated using different product standards than those that have been developed independently by the relevant room heater manufacturers. Without a consensus on this question at French mirror committee level, France does not support any CEN/TC 62 position on this issue at this stage. CEN/TC 62 believes that consumers are unlikely to be influenced by a label that covers all fuels as it is most likely that the purchaser has already decided on the fuel prior to identifying the room heater itself. This choice will be impacted by the individual situations in terms of the fuel that is currently used in household. Given the fact that all the efficiencies are calculated on a different basis, the label is misleading to the consumer and we do not support all this information on one label. We believe that this labelling concern has already been addressed in Lot 1 where heat pumps, boilers and Micro CHP units had separate labels because they generate different efficiencies. This is virtually the same situation for local room heaters and therefore we strongly believe that the same principles should be applied and each fuel given its own label. Referring to CEN/TC 62 standards: 1 P a g e
Flueless appliances covered by EN 14829 are not decorative since its scope states : There are no specific thermal efficiency requirements appropriate to these types of appliance as all the heat produced by the combustion process is released into the space to be heated. Open fires covered by EN 13278 are not only decorative but have also a heating function since two different classes of efficiency are defined with corresponding tests and markings. Consequently, CEN TC 62 is in favour of a unique label independent of the function and the technology used by appliances being type A, B or C categories as defined in CEN/TC 62 standards. Looking at the label as it is currently defined, the most striking aspect of it is that band D covers a range of 39 percentage points from 36% up to 75% efficiency. This is inconsistent with the approach that has been taken with Lot 1 where equal percentage banding has been used. Most significantly, it means that a large proportion of gas fires currently on the market, fall within a band where large differences in actual performance are not demonstrated, ie - no differentiation in terms of efficiency band between products that could be 74% efficient and others at 40% efficiency. This, in our view, undermines the principles of what the commission is trying to achieve - encouraging consumers to fit higher efficiency appliances through a combination of the regulatory measures to set the minimum standards of performance when coupled to a labelling scheme that nudges purchases to buy efficient products. If the proposed label is introduced, we feel, the consumer is not educated sufficiently in terms of identifying which appliances are more efficient than others and therefore has almost no value to either the purchasing process for the consumer or the drive to encourage effective installation of the highest efficiency fires available on the market place. We therefore strongly believe that the labelling needs to be revised, and a more even banding be used, attuned to the currently available efficiency range of gas fires. This will be more effective in allowing consumers to identify the higher efficient appliances within the gas range of products. A further complication arises with the Three Tiers efficiency proposals. We have looked carefully at the efficiencies calculated and detailed for open fronted appliances. We believe these are achievable albeit we are very surprised they are below the current levels being used in some markets and there may be an opportunity to increase these. Where we do have a concern is on closed front appliances. We strongly believe that the efficiencies at both Tier 2 and Tier 3 are not achievable with the currently available product and the best available technology is for this type of appliances. This was made clear in the Bio Intelligence Services report that was published in July 2012 but seem to have been ignored by the commission when calculating the efficiency tiers. Many European home only have chimneys which do not lend themselves to balanced flue appliances. Very few appliances are fitted close to an outside wall which is pre-requisite if a balanced flue appliance is to be installed. To achieve Tier 3 for closed fronted appliances would require a balanced flue appliance be installed. We would propose that more realistic values for the Tiers are as follows. Closed Fronted Appliances proposed efficiencies Tier II 54% Tier III 54% We would also propose the following labelling for Gas Fires only; 2 P a g e
A+ (78%) A (70%) B (62%) C (54%) D (46%) E (38%) F (30%) G (22%) Label for Gas Fires Band and Seasonal Efficiency Flueless Local Space Heaters We know that flueless fires are included within the energy labelling proposals but not in the ecodesign proposals, the assumption being that they are used mainly for decorative purposes. This is an incorrect statement. In the UK, for example, they are used for secondary heating which is not the same as decorative and that they are contributing to the overall heat demand of property. The attachment details a list of the specific issues we have with each part of the document which we hope are self-explanatory. Element Table 3 - Relation of thermal efficiency in NCV and seasonal efficiency in GCV of various products within scope Table 4 Energyefficiency classes achieved by different flues Page CEN/TC 62 concern No. 17 1. CEN/TC 62 are concerned about the use of seasonal efficiency and believe that the calculation proposed it too simplistic. Arguably, it should be the responsibility of the CEN TC committee to determine the efficiency calculation, overseen by the commission consultant. 19 We believe that a separate gas fire should have a top limit if an A+ band is added on the label. The label must differentiate between open fronted, closed fronted, flueless and balanced flue. We believe that the case for a separate label for gas fires is further strengthened by the commission agreeing to consider removing electric fires from the label. There is already a precedent within Lot 1 where gas boilers and heat pumps have separate labels. In addition, we cannot see the logic for having such a wide D band. This is a mis- 3 P a g e
Definitions 25 Auxiliary electricity References 49 representation to consumers and would result in all gas fires being in one band. One of the driving forces for Eco-design is to encourage improvement and grouping in one band does not achieve this as the consumer will not see a visual difference... CEN/TC 62 have produced revised text for the definitions as follows: flue-less heater means a local space heater, using gaseous or liquid fuels, of which the supply of air for combustion is taken from the room in which the appliance is located and which the products of combustion are emitted in the space the product is situated and which are not luminous heaters; open fire heater means a local space heater, using gaseous, liquid or solid fuels, of which the supply of air for combustion is taken from the room in which the appliance is located,, and which is sealed to a chimney or fireplace opening or requires a flue duct for the evacuation of products of combustion. It does not require a flue break or draft diverter; closed fire heater means a local space heater, using gaseous, liquid or solid fuels, which the supply of air for combustion is taken from the room in which the appliance is located and which is sealed to a chimney or requires a flue duct for the evacuation of products of combustion. It does require a flue break or draft diverter. Balanced flue heater means a local space heater that has an own duct system, which is an integral part of the appliance. This duct system supplies the air for combustion from the outside and removes the products of combustion to the outside into the same air pressure zone of the outside air. The system is sealed from the inner room air. CEN/TC 62 believe that the pellet factor is very misleading as the full environmental impact is not being taken into account on the calculations and 30 Gas fires do not have a requirement for electricity so there will be no losses. Pilots are discretionary and not used on all appliances permanently. The pilot is also is in the room and therefore contributing to the room. They also can be switched off when the appliance is off. It is traditional all over in Europe that at gas appliances the net calorific value is used, when the efficiency is expressed. CEN TC 62 believe that given its wide use, it would be confusing to the customer. Additionally in appliance standards only the net calorific value based efficiency is calculated. So the efficiency of the appliances based on gross calorific value is not known. Take out the definition of heat load at part load (Ppart) as this 4 P a g e
is not in the calculation References 50 EN 613 is in the wrong place as it is under Warm Air Remove the reference to part load as this is not in the Testing 52 calculation for gaseous LSH. We have assumed that variable means that the control goes from minimum to maximum which the consumer controls. Correction factors 55 For F(2) on an open fronted fire, you cannot legally have an unattended appliance controlling itself. 4. We cannot see a justification for this not being 5% as it is the best available technology (BAT). To our knowledge, it is not possible F(3) does not apply. F(4) needs to have a distinction between permanent and non Correction factors 56 permanent pilots. Most pilots are non permanent and do not require electricity to start them. As the pilot is located in the room, it would contribute to the overall head being delivered by the LSH and therefore acting as a secondary burner. Table 15 the wording here looks wrong as the text 'pilot flame equal to zero' does not make sense Item 2. Currently, there is not a requirement in the standards to maintain the test room temperature at 20 deg C as this General conditions for measurements and calculations 68 would require specialised chambers and add significant cost to the whole testing process which we do not believe is the commission's intention. We believe this is a key area that needs to be reviewed and would have a significant impact on manufacturers. 5 P a g e