Date : 09/09/2013 revised 26/09/2013 Auteur : MMT Destinataires pour action : UNICLIMA Document de travail DRAFT ECODESIGN REGULATION FOR ENER LOT21 PRODUCTS The document exclusively includes technical comments on the wording of the draft regulation. 1. DRAFT ECODESIGN REGULATION 1.1. Chapter 2 Definitions 9) p6 Comfort chiller shall not be defined by a maximum outlet temperature. In case of chiller used with floor cooling, the delivery temperature is 23 C. Remove the water temperature range 10) p6 The definition of fan coil unit is not understood as it is made reference to nor an outdoor unit. It shall be specified that the fan coil unit includes a heat exchanger between water and air. The definition given in the standard EN1397 shall be used, as follows: hydronic fan-coil unit factory-made single assembly which provides one or more of the functions of forced circulation of air, heating, cooling, dehumidification and filtering of air, but which does not include the source of heating or cooling Note 1 to entry: This device includes at least a liquid-to-air heat exchanger and a fan, and may be designed for free or ducted intake air and/or for free or ducted delivery of supply air.
11) c) p6 The outlet temperature at standard rating conditions is 7 C and not 6 C, to be in line with EN 14511 standard and refrigeration chillers in ENTR Lot1 11) d) p6 The draft regulation does not include any requirements nor specification for process chiller with remote condenser the chiller shall always integrate the condenser Modify d) 19) p7 It shall be specified if the definition applies to comfort and/or high temperature process chillers. 2. ANNEX I 2.1. Generic definitions 8) and 9) p11 η s,h and η s,c are used while the transitional method makes reference to η s,heat and η s,cool Tables 11 to 13 make reference to η s and SEER while Table 15 makes reference to η s only Harmonisation is required. 21) p11 The definition shall be a general one as it applies to all products and is duplicated under definition 80) on page 17. 2.2. Definitions related to heat pumps. 26) p12 The definition can be simplified by not repeating partially the general definition on a heat pump in 25) air-to-air heat pump means a heat pump [which has a heat generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (evaporator) allows heat transfer from ambient air; The term ambient air is not defined. Delete it or replace it by outdoor air
27) p12 The definition can be simplified by not repeating partially the general definition on a heat pump under 25) water/brine-to-air heat pumps means a heat pump [which has a heat generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (condenser) allows heat transfer from water or brine; In this case the outdoor heat exchanger is the evaporator and not condenser. 29) p12 Delete in in that provides in space cooling and: 30) p12 The definition can be simplified by not repeating partially the general definition on an air conditioner in 29) air-to-air air conditioner means an air conditioner [which has a cooling generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (condenser) allows heat transfer to air; 31) p12 The definition can be simplified by not repeating partially the general definition on an air conditioner in 29) water/brine-to-air air conditioner means an air conditioner [which has a cooling generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (condenser) allows heat transfer to water or brine; 33) p13 The definition can be simplified by not repeating partially the general definition on a comfort chiller under 9) air-to-water chiller means a comfort chiller [that has a cooling generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (condenser) [of the cooling generator] allows heat
transfer to air, including heat transfer that is based on evaporation into this air of externally added water; 34) - p13 The definition can be simplified by not repeating partially the general definition on a comfort chiller under 9) water/brine-to-water chiller means a comfort chiller [that has a cooling generator that uses a vapour compression cycle driven by an electric motor or fuel combustion engine and] whereby the outdoor heat exchanger (condenser) [of the cooling generator] allows heat transfer to water or brine, excluding heat transfer that is based on evaporation of externally added water; The last part of the definition excluding heat transfer that is based on evaporation of externally added water shall be deleted as it does not apply to water cooled chillers. 37) p13 A condensing unit only includes part of the cooling generator as the evaporator is not included in this cooling product It is a product that requires an additional evaporator to form a cooling generator. Furthermore it is not in the scope of this draft regulation. It is used nowhere else in the draft regulation definition shall be deleted. 2.3. Definitions related to the calculation method 40) p13 The definition shall be given by referring to the rated heating output as it is the correct term defined in 17) page 7 and not rated capacity for heating. 41) p13 The definition shall be given by referring to the rated cooling output as it is the correct term defined in 18) page 7 and not rated capacity for cooling. 47) p14 It is preferable, in order to be consistent with the other ErP regulations, to define heating and cooling season for the different climates
Proposal: heating/cooling season means a set of operating conditions for average, colder and warmer climate conditions, describing per bin the combination of outdoor temperatures and the number of hours these temperatures occur per season; 54) p14 QC and HCE to be replaced by Q C and H CE respectively. 60) and 61) p15 SEERon and SCOPon shall be defined as weighted average EER and COP. same definition as in regulation n 813/2013 for lot1 for the cooling season shall be replaced by for the designated cooling season 62) p15 The supplementary capacity for heating is defined by the symbol sup(tj) and the symbol P sup shall be then deleted. Reference to the temperature bin Tj is necessary Proposal: supplementary capacity for heating (sup(tj)) means the rated heat output [Psup] of a supplementary heater that supplements the declared capacity for heating to meet the part load for heating in case the declared capacity for heating is less than the part load for heating for the bin temperature Tj, expressed in kw; 66) p15 The definition shall be corrected to apply to chillers as follows: declared capacity for cooling (Pdc(Tj)) means the capacity of the vapour compression cycle of the air conditioner or chiller, pertaining to an outdoor temperature Tj and indoor air or water/brine temperature (Tin), as declared by the manufacturer, expressed in kw; 67) p15 and 113) p19 The definition shall be identical to that in regulation 206/2012, i.e. as follows: capacity control means the ability of the unit to change its capacity by changing the volumetric flow rate. Units are to be indicated as fixed if the unit can not change its volumetric flow rate, 'staged' if the volumetric flow rate is changed or varied in series of not
more than two steps, or 'variable' if the volumetric flow rate is changed or varied in series of three or more steps; The definition in the draft regulation for ENER Lot1 products shall also be revised to be consistent with the other regulations. The definition shall be a general one as it applies to all products and is duplicated. 68) and 69) p15 Both definitions shall used the corrected terms; rated heating output and rated cooling output 76) p16 The regulation is dealing with products that provide either air or water cooling. For units that provide air heating or air cooling, the degradation coefficient has a default value of 0.25 (definition of Cd in EN 14825) For units that provide water cooling, the degradation coefficient has a default value of 0.9 (definition of Cc in EN 14825) In addition, the degradation coefficient in cooling mode and in heating mode shall be differentiated by the symbols: Cdh, Cdc as in regulation n 206/2012 and as used in the Tables of Annex II. 2.4. Definitions related to high temperature process chillers 95) p18 Brine-cooled high temperature process chillers seem not to be in the scope of the draft regulation? 105) and 106) p18 The adjective ambient is generally used to described air temperature. Here the term ambient temperature is also used to describe the water temperature for water-cooled process chillers. cannot we use the term heat source temperature? 112) p18 The degradation coefficient shall be named Cdc and not Cc for consistency with other regulations.
3. ANNEX II 6) a) vi) p23 It is mentioned that for fan coil units, the information shall be measured in accordance with Annex III. However Annex III does not prescribe any procedure for fan coil units. Table 11 p26 o Indication of NOx emissions shall be removed. o Indication of combination heater : Yes/no shall be removed Table 12 p27 o Indication of combination heater : Yes/no shall be removed o Delete For air-to-water units: before the indication of the outdoor rated air flow rate as the Table is dealing with air-to-air conditioners. o The default degradation coefficient shall be Cdc=0.25 Table 13 p28 o Indication of combination heater : Yes/no shall be removed o The default degradation coefficient shall be Cdc=0.25 Table 14 p29 o Sensible and latent cooling outputs are not defined need for definitions of latent cooling output and sensible cooling output o The same symbol, P rated is used for the two outputs declaration identify P rated,sens and P rated, latent for example. o The temperature conditions, fan speed settings, for which information about cooling outputs and electrical consumption is required are not specified in the draft regulation, or the conditions for measurement of sound power level. Table 15 p30 and p31 o Replace air conditioner by heat pump 2 occurrences in the table o Replace air-to-water by air-to-air 4 occurrences in the table o Replace water/brine-to-water by water/brine-to-air o Indication of NOx emissions shall be removed. o Indication of combination heater : Yes/no shall be removed and delete information required fro combination heater
o Delete the information about WTOL which does not apply to water/brine-to-air heat pumps o The default degradation coefficient shall be Cdc=0.25 Table 16 p32 o The information required about refrigerant fluid(s) is not understood as the energy efficiency requirements of high temperature process chillers are not related to GWP of the refrigerant. o On the contrary the information about the refrigerant(s) to be used for other products shall be indicated in Tables 11 to 15 as the energy efficiency requirements are dependent on GWP values. o The operating temperature (t)shall be indicated ; however this temperature is not defined nor found somewhere else in the draft regulation o Harmonisation of the symbol for the degradation factor is needed o Definition 113) on page 19 does not define staged capacity control 4. ANNEX III There is no standard rating conditions for fan coil units 2) - e) and f) p33 Not understood 4) - a) p33 o The wet bulb temperature (19 C) associated with the dry bulb temperature of 27 C shall be indicated. o Chillers are not provided any cooled air, a water temperature of 7 C shall be indicated o Reference to point 5 is wrong and not understood. 4) - b) p33 water/brine cooled comfort chillers to be added 4) - c) iv) p34 H HE to be replaced by H CE Reference to Table 6 shall be Table 29 4) - c) v) (2) p34
standby consumption is missing. 5) c) iv) p34 HHE to be replaced by H HE 5) - c) v) (2) p35 standby consumption is missing. 5) p35 o This point shall be numbered 6) and not 5) o The adjective ambient is generally used to described air temperature. Here the term reference ambient temperature is also used to describe the water temperature for water-cooled process chillers delete ambient in reference ambient temperature see comment on p18 105) and 106) Table 18 p36 Are water-to-brine chillers in the scope of the regulation? If not, delete the corresponding test conditions given in Table 18. If yes, the efficiency requirements shall be differentiate from those of water-to-water chillers because of the less efficient heat exchange when using brine. If water to-brine chillers are in the scope, then air-to-brine chillers shall also be included (which seems to be the case with Table 19) and again efficiency requirements shall be different from those stated for air-to-water chillers. Why is the * only referring to one test condition of the Table? It can be helpful to refer to regulation n 813/2013 for finding the standard rating conditions in heating mode from which the flow rate shall be obtained. Table 19 p37 The footnote * is not refer to in the Table 19. Table 20 p37 The same footnote * or a shall be used. Explanation is required for this setting of the flow rate in cooling mode. In Tables 18 and 19 for chillers, the reference flow rate is in heating mode.
Table 21 p37 As the table is indicating standard rating conditions, all references to part load ratio shall be deleted the table can be simplified and have then the same format as the above tables. Reference to T A and T D are not understood. Table 22 p38 o Test conditions shall be indicated as A/B/C or D in order to better understand the use of this Table 22 with Table 27. o For accuracy in the calculations, part load ratio shall be also expressed with the equation, as follows : (Tj-16)/(Tref-16) o Water-to-air air conditioners can used dry coolers as outdoor heat exchanger with other temperature levels than the ones already indicated complete the table with additional test conditions according to EN 14825. o Water-to-water chillers can used dry coolers as outdoor heat exchanger with other temperature levels than the ones already indicated complete the table with additional test conditions according to EN 14825 o Footnote * is not understood. o Footnote ** shall be deleted and reference to EN 14825 test method made as this is part of the test procedure and is under improvement in the standard revision Table 25 p40 Reference design conditions are provided for warmer and colder climates for heating but these climates are not described and not used in the rest of the draft regulation. Only average climate is described in Table 26. The Table shall also identifies warmer and colder cooling seasons as they are used in Table 27. Table 26 p41 The average climate for high temperature process chillers (HTPC) has not the same bin temperatures as the average climate for comfort chillers, heat pumps and AC units in terms of range of temperature. Average climate (for both heating and cooling) includes bin temperatures from -10 C to +35 C, while the average climate of HTPC is extended down to -19 C and up to 38 C. It is not either consistent with colder climate temperature range Harmonisation is required. Table 29 p44
It shall be specified that Table 29 applies to air conditioners, heat pumps and comfort chillers. Set of hours to be used for reversed cycle units, i.e. units that can operate in cooling mode and heating mode shall be specified. 5. WORKING DOCUMENT ON TRANSITIONAL METHODS No mention is made to any European standard for fan coil units. EN 1397 shall be indicated. references p8 Degradation coefficient is named Cc while in the draft regulation, the symbol Cd or Cc or even Cdc are used indifferently. Harmonisation is required. 3.1 b) - p12 SCOP and SPER heat are not seasonal energy efficiency in active mode delete in active mode p14 The use of Cc shall again be harmonised with the definitions and symbols.