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Determination: Greenhouse and Energy Minimum Standards (Air Conditioners up to 65kW)

5 Apr 2018 09:30 AAEST
27 Apr 2018 17:00 AAEST

The air conditioner determination has changed a lot following legal review and changes requested by industry. These changes make the determination clearer and easier to follow.

You will find this third draft of the determination (the “exposure draft”) is organised differently from the earlier versions, but the policy intent has not changed. We have not used track changes in this draft, because it would have become difficult to read and follow the document if we had. For this reason, we are providing this guide to the determination to highlight the main changes to the document and to help you to find those parts of the determination that are of most interest to you.

The legal team reviewed the last draft from an outsider’s perspective. They pointed out that many terms, phrases and entire sections relied on a large amount of prior knowledge that people familiar with the test standards and existing regulations use to get around inconsistences, contradictions and imprecision. (Often, without even being aware of it).

We would be grateful for your careful consideration of the entire document and we welcome any feedback, comments or suggestions, you may have. Feedback is due by COB Friday 27 April 2018. Stakeholders in New Zealand should note that the determination would be called up by New Zealand’s regulations, so you should also provide any feedback as part of this review.

For this draft we have retained the proposed mandatory start date of 1 April 2019. But given the process has been delayed, we would like to hear your views on when the provisions in the determination should begin.

The GEMS air conditioning team hope you will find this draft of the determination to be clearer, more concise and easier to read and understand than the two earlier drafts. The main differences between the second and third drafts of the determination are:

Air conditioner definition: This definition has been changed to simplify the whole document and reduce repetition. It now covers electrically driven, vapour compression products that can cool, heat (i.e. a heat pump), or do both.

Coverage of air conditioners >65 kW: Due to the different start date, it is necessary to cover air conditioners over 65 kW in a separate Determination with a start date of 1 October 2020. This second determination will be based on this determination, once it is finalised and this additional determination will be the subject of a separate consultation process.

Layout: As explained above, many of the changes are intended to make the determination clearer. For instance, long sentences have been broken into subclauses and long sections have been broken into subsections. These changes are an attempt to make the document easier to use and understand, as well as to clearly separate MEPS and labelling requirements.

SEER related requirements moved: Feedback on the last two drafts suggested that the seasonal rating requirements should be moved out of the GEMS level requirements (i.e. MEPS) section and placed in the labelling section. The legal review agreed.

Test tolerances: Test tolerances will not be set by the determination. The tolerances specified in AS/NZS 3823.2:2013 will continue to apply. They will be included in a separate legislative instrument prepared by the GEMS Registration and Compliance teams and subject to a separate consultation process.

Labelling schedule: Although Schedule 3 in the determination is long and complex, industry will not need to be familiar with the details, because the registration system will automatically generate print-ready, registration specific labels for every product.

Some requirements have been removed from the determination and instead, will be mandated through the registration system. A factsheet outlining these registration requirements is attached. These requirements are:

Seasonal efficiency and noise ratings for unlabelled products: The determination will not mandate seasonal efficiency ratings (i.e. Total Cooling Seasonal Performance Factor and Heating Seasonal Performance Factor) or noise ratings for products (up to 30kW) not displaying an Energy Rating label. Instead, they will be mandated through the online registration form and available publicly on the Energy Rating website and through the calculator tools.

Demand response: The determination will not include the requirement for Demand Response capability to be disclosed. Instead, this disclosure will be mandated through the online registration form.