2012-11-01 Norwegian Comments onWorking Document on Possible Ecodesign and Energy Labelling Requirements for Local Space Heaters

8/12/2019 2012-11-01 Norwegian Comments onWorking Document on Possible Ecodesign and Energy Labelling Requirement

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Mr Paul Hodson

Energy Efficiency

DG Energy

European Commission

Our date: 1 November 2012

Our ref.: NVE 201107210-27 ee/ejrt

File no.: 651 Enquiries to:

Your date: 20 July 2012 Einar Tommelstad

Your ref.: S-1037822

Norwegian comments on Working Document on possible ecodesign and

energy labelling requirements for local space heaters

General comments

Norway welcomes the proposal of the Commission to set regulations with regard to ecodesign

requirements and energy labelling of local space heaters (LSH). In succession to remarks made in the

CF meeting 20th

September 2012 and the Norwegian preliminary comments handed in earlier we would

like to highlight a few issues which should be considered further.

We find that the commission has been too ambitious in attempting to gather together all localroom heaters in one common framework regardless of the heat source being, electric, gaseous,

liquid or solid. Since the improvement potential of electric heaters is limited, as in fact no or

insignificant losses occur if electricity is converted into heat, we recommend that electric heaters

are removed from the scope or at least exempted from the energy labelling requirements. If the

electric heaters eventually end up not being exempted, the Tier 3 efficiency requirement must be

reduced from 40 % to any finite value underneath 40 to allow for controls losses.

Introducing the BCC factor and the seasonal efficiency and still name the outcome efficiencyresult in confusion among consumers and professionals because of mixing different concepts.

Furthermore for local space heaters NCV should be used instead of GCV. The proposed emission threshold values should be related to recognized test methods available

in the EU. Norway recommends choosing the method that measures concentrations in the flue

gas under the most realistic conditions. In case several methods apply, the commission should

raise standards by choosing the method returning the highest results, bearing in mind one cannot

measure any higher concentration than present in the flue gas.

In distinguishing between local space heaters (originally Lot 20) and indirect space heaters(originally Lot 15) Norway supports the discriminator of 6 % heat output to the room. This is

fairly simple in understanding and testing and will not in our opinion lead to product confusion.


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Side 2

We find the ecodesign three-step-implementation basically useful. However the proposed Tier 1on emissions should be made redundant from the beginning, as most new stoves sold today

already perform better than the proposed Tier 1 emissions. It should not be forgotten that air

quality and related health problems are a challenge in many European cities and stricter limits

for emissions should be promoted faster. It should be acknowledged that wood stoves do require sufficient flue draft in order to operate

both efficiently and clean burning. Opposed to boilers, stoves by their nature are unlikely ever to

propagate into condensing operating mode. Consequently the efficiency of stoves (and the like)

will never reach 100 %, in fact efficiencies around 78-83 % must be regarded as pretty good, not

leaving a lot of improvement potential to be harvested. In Norway consumers are recommended

to install wood stoves as a back-up heat source, in case disruption of the primary heat source,

whether it being electric, gaseous or district heating. In order to safeguard this backup heat

source, it is utmost important to maintain wood stoves as comparatively uncomplicated heat

generators being able to operate without the need of electric extraction fans or other mains

powered aids.

Scope and definitions

Scope in general

Norway supports the idea of defining a lower heat output limit of local space heaters to be included by

the framework. This can be justified by at least three reasons;

1. An appliance must have a certain minimum heating capacity at all in order to be denominated aroom heater.

2. For appliances having fairly low heat capacity the saving potential is equal low.

3. By reserving the framework to those real room heaters having substantial heat capacity the

cost of market surveillance can be reduced dramatically.

Such minimum limit could be defined as 1 kW for electric heaters (if included at all) and 2 kW for

fuelled local space heaters.

Electric heaters

The improvement potential of electric heaters is limited as in fact no or insignificant losses occur if

electricity is converted into heat. As Germany we do not see the necessity to include these products in

the scope. From our point of view it is not a good idea to include electric heaters in the same framework

as the direct use of other energy carriers because this mixes together an evaluation of the product itself

and the electricity system it is used within. This will be misleading for consumers in the parts of Europe

were the electricity production originates from a high renewable share.

Decorative fires

Decorative fires should be excluded from the scope. The main issue is safety, not efficiency. These

appliances are not meant as the only heat source for a room.

Ecodesign requirements

Definitions

There is no technical justification for basing the efficiency calculations on GCV as wood stoves and

similar are highly unlikely ever to operate in condensing mode (opposed to boilers). We recommend

using NCV instead. This would align ecodesign requirements and the harmonized product standards and


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Side 3

current practice among professionals. Furthermore using the NCV also takes away some complexity of

the calculation of seasonal efficiency.

Calculations

In the last equation on WD page 29 the calorific value (GCVmf)right after the equation mark must be

GCVarinstead of GCVmf (or its equivalent given by the first equation).

Energy efficiency

Please bear in mind that these Norwegian comments primarily are related to the two types of LSHs

most relevant for Norway, namely electric heaters and wood stoves. In general we find the proposed

Tier 1-3 requirements on efficiency quite adequate.

Electric heaters

For electric heaters we have already made the point that they should be exempted from ecodesignrequirements or at least from the energy labelling requirements. It is not in the hands of manufacturers of

electric heaters to improve the overall efficiency from the generation of electric power, or transmission

to usage. In fact there is no or only insignificant improvement potential to be harvested for electric

heaters. In any case not enough to justify setting up this entire framework, imposing excess cost and

labour for manufacturers and to national authorities in their market surveillance.

Should electric heaters eventually end up not being exempted, the Tier 3 efficiency requirement must be

reduced from 40 % to any finite value underneath 40 to allow for controls losses.

Wood stoves

In calculation the F(1) loss factor (ref. WD table 13, page 55) it should be clarified how traditionalmanual heat output controls (typically the primary air valve and the secondary air valve) of wood

burning stoves should be interpreted. We have hitherto made the assumption that these traditional valves

must named a variable output (clearly by their nature they are neither one stagenor two stage) and

consequently the F(1) loss factor for wood stoves must be; 5 5 = 0 . This is quite crucial in relation to

whether the Tier 3 requirement for closed fires of 98 % (seasonal) is within reach or not.

Following the discussion of the CF-meeting the 20thSeptember, apparently both the BCC factor and the

division of the energy classes are subject to change. We find it utmost important that the Tier 3

efficiency requirement to come (closed fires), regardless of its calculation, does resemble a

standard NCV efficiency of not more than 80 % .

Stimulating industry to obtain efficiencies significantly higher than 80 % NCV may well happen at the

expense of increased health risk because of chimney mal function and increased emissions, both

spillages to the room and of pollutants emitted to ambient. For wood stoves high efficiencies and low

emissions in general are contradictory. The figure below illustrates the principal relation between

efficiency and flue draft for a typical modern wood stove. The higher efficiency achieved, the lower flue

draft, the poorer function of the stove.


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Side 4

Emissions of solid fuel LSH

Norway has had nationalregulation on emissions from wood burning appliances since the 1990s, so we

welcome the ecodesign emission proposal now applying minimum emission standards throughout

Europe. In general we find the proposed Tier 1 and to some extend Tier 2 requirements not challenging

enough for Scandinavian stoves, but if this is what it takes to impose emission limits to all European

countries, we can surely wait for the tighter requirements to come in Tier 3. However, if the fairly low

Tier 1 requirements are maintained in the final text, it is utmost important that member states and

affiliated states like Norway can maintain existing tighter national legislation. If such right cannotbe granted we need to request tighter requirements, not anything less than Tier 2 from adaption and, 2

years after, Tier 3 requirements must be out into force.

Also we are concerned about the test protocol for PM emissions. We will try to save the details till the

technicians meeting later, but briefly worldwide there are three different measuring principles:

1. Sampling of PM emissions in a diluted flue gas at ambient temperature. The test regime includestesting at up to four different valve settings from almost closed to fully open, thus provoking the

stove to its extremes. The mass of the fuel load is calculated as a function of the firebox

volume. This method is used for approving wood stoves in the America, Australia and New

Zeeland and Norway.

2. Sampling of PM emission direct in the hot flue gas direct in the chimney. The test regimeincludes testing at nominal heat output and the mass of the fuel load is for the manufacturer to

decide. This method is used primarily in Germany, Austria and some other central European

countries. The method has got quite some resemblance with industrial dust sampling wide

spread throughout Europe.

3. Passing the full chimney flow through an electrostatic precipitator thus attracting PM to theelectrodes of the precipitator. The test is repeated five times and the test regime includes testing

at low output and at rated heat output. This method is used in testing stoves to Smoke Control

Area exemption in England.

Leaving the last option out, the major difference between the two first is that the first will return higher

PM emissions because it also captures the condensable fraction of the flue gas (VOC, PAH, OGC etc).


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Side 5

The commission should thoroughly consider which attributes to the chosen PM test method is most

desirable; low PM emission values or a representative test result.

The German comments containing an opening for a better method, quote: We propose to develop more

realistic measurement procedures for the next review of the implementing measure. From our side we

see no reason to wait until once in the future, the more as such realistic methods with a long proventrack record already are available now.

Testing

Primarily all products must be tested to harmonized standards. Stoves and the like are under CPR and

must be tested to CE-labelling anyway. The test should be undertaken by a test lab, not only a notified

body but most significantly the test body must be accredited to testing by ISO 17025. Notably PM

emission (which is not now included in the harmonized standards) should comply with CEN/TS 15883

Annex A, part A2.

Product information

The proposed information requirements could lead to contradictory information. The ecodesign require

to display the NCV based efficiency and the ecolabel will display a much higher seasonal efficiency. At

least consider to rename the seasonal efficiency energy index.

Comments on energy labelling requirements

As we have previously pointed out we find the proposed energy labelling class division too compressed

to allow for sufficient product differentiation per technology, in the end impairing proper consumer

guidance. During the CF meting several countries incl. Norway pledged for exemption of the electric

heaters from the energy labelling requirements. We still find this utmost important, as there is muchdoubt on how to agree on one common CC factor which is fair and representative to various countries

power generation systems with their various mix of fossil and renewable power sources. The

improvement of the overall power generations efficiency is not in the hands of manufacturers of electric

heaters. By exempting the electric heaters from energy labelling requirements the CC issue will be

avoided.

Market surveillance

The Commission might want to consult the Group of Notified Bodies SG03/WG2 on the issue of

applicability of market control of local space heaters. In our opinion such control testing is possible also

yielding reproducible test results. According to EN13240, the users manual must give preciseinstructions on how to operate the stove at nominal heat output, as well as other advice. It might be wise

to allow the manufacturer to witness the control testing.

Yours sincerely

Einar Tommelstad

Senior Engineer

Documents

2012-11-01 Norwegian Comments onWorking Document on Possible Ecodesign and Energy Labelling Requirements for Local Space Heaters