Proposal to amend O.Reg. 509/18 under the Electricity Act, 1998 (“Efficiency Regulation”)

Description

A. The proposed changes would update efficiency requirements for commercial gas furnaces, residential air conditioners and heat pumps, roadway luminaires and highway luminaires as follows:

1. Increase efficiency requirements for commercial gas furnaces to harmonize with DOE requirements coming into effect on January 1, 2023. Ontario changes would take effect six months later, on July 1, 2023. This would fully harmonize Ontario’s requirements for these products with United States Department of Energy (DOE) requirements under 10 CFR §431.77. Affected products in O.Reg. 509/18 include:

1. Furnace, gas-fired, with an input of at least 65.92 kW (225,000 Btu/h) but not more than 117.23 kW (400,000 Btu/h)
2. Furnace, gas-fired, with an input of more than 117.23 kW (400,000 Btu/h) but less than 2,930 kW (10,000,000 Btu/h)

2. Increase efficiency requirements for split-system residential heat pumps and air conditioners to harmonize with proposed Natural Resources Canada changes expected to come into effect on July 1, 2023. Ontario changes are also proposed to take effect on July 1, 2023. Testing requirements for single-package residential heat pumps and air conditioners would also be updated to harmonize with proposed NRCan changes. One product category in O.Reg. 509/18 would be affected:

1. Air conditioner or heat pumps, central, less than 19 kW (65,000 Btu/h)

Only product classes being updated by NRCan would be changed in Ontario (air-cooled, single phase, non-VRF models) to ensure full harmonization with NRCan.

3. Update test method and efficiency requirements for roadway luminaires to require 100 lm/W for LED luminaires only; other technologies would continue to be subject to current test standard and efficiency requirements. Changes would take effect July 1, 2023. Affected products in O.Reg. 509/18 include:

1. Luminaire, used for roadway lighting

4. Update test method and efficiency requirements for highmast luminaires to require 100 lm/W for LED luminaires only; other technologies would continue to be subject to current test standard and  requirements. Changes would take effect July 1, 2023. Affected products in O.Reg. 509/18 include:

1. Luminaire, highmast

5. Update one of the four efficiency requirements currently specified for geothermal liquid-to-air heat pumps. Ontario revised three of the four minimum energy performance standards (MEPS) for liquid-to-air geothermal heat pumps in 2015 to harmonize with ASHRAE 90.1-2013 requirements. However, the minimum efficiency level for open-loop heat pumps in cooling mode was not increased to ASHRAE 90.1 levels. The proposed amendment would correct this and fully harmonize O.Reg. 509/18 with ASHRAE 90.1-2016 minimums (which are the same as ASHRAE 90.1-2013 levels for this product). Efficiency levels for closed-loop models and for open-loop models in heating mode would not be affected. This correction would take effect July 1, 2023. The product that would be affected by this change is:

1. Heat pump, geothermal, liquid-to-air, excluding direct expansion

B. The proposed changes would update scope definitions for six products currently regulated by Ontario and by DOE but not by NRCan, to introduce full rolling incorporation with DOE. These products already have rolling incorporation with DOE standards for test method and efficiency requirements. The affected products are:

1. Air conditioner, computer room
2. Floor furnace, gas-fired
3. Pool heater, gas-fired
4. Room heater, gas-fired
5. Wall furnace, gas-fired
6. Water heater, electric, instantaneous, input 12 kW or less

C. The proposed changes would update requirements for two products to more closely align with NRCan and/or DOE:

1. Dehumidifier, self-contained, with a daily water removal capacity of up to 87.5 litre

a. Scope would be updated to use rolling incorporation with DOE, and product title would be revised to “Dehumidifier” to reflect current scope

2. Water heater, electric, storage, greater than 454 L or with an input rating of more than 12 kW

a. Scope would be updated to better align with NRCan, and test method would be updated to include rolling incorporation with DOE to also harmonize with NRCan’s current testing requirement.

D. The proposed changes would clarify scope for three products:

1. Changes to the scope descriptions for four products should have no immediate impact on stakeholders, but are meant to clarify that O.Reg. 509/18 is intended to be harmonized with corresponding standards in other jurisdictions. Products affected by these proposed changes are:

a. Vending machine, other than refrigerated bottled or canned beverage

b. Water heater, gas-fired, storage, with an input rating of more than 22 kW (75,000 Btu/h)

c. Water heater, oil-fired, storage, with an input rate of more than 30.5 kW (105,000 Btu/h)

E. The proposed changes would update test methods for two products:

1. Liquid-filled distribution transformers

a. Use of the CSA standard specified under current requirements for this product would be allowed as an alternative compliance option to DOE requirements beginning on January 1, 2023. The intent is to include an ambulatory reference to the CSA standard so that if it is updated in the future those new, updated requirements would be automatically adopted into the efficiency regulation.

2. Geothermal liquid-to-water heat pumps

a. These products are currently required to comply with a test standard that is obsolete (CAN/CSA C446-94) and has been withdrawn. It is proposed to update the test method and reference CSA C13256-2-01, with no changes to the current minimum efficiency requirements.

F. Make changes to the regulation of a housekeeping nature. These changes could clarify the scope and/or requirements for some products, or update references to include the most relevant or most recent editions of test standards for products with no changes to the existing efficiency requirements.

Environmental Impact

Proposed changes for commercial gas furnaces, residential heat pumps and air conditioners, and roadway/highway luminaires would lead to significant savings on energy costs, reductions in electricity and natural gas use, and reduced GHG emissions.

No energy or environmental impacts are expected from changes that do not change minimum efficiency requirements. These are intended to clarify Ontario’s intention to harmonize with other jurisdictions for the affected products.

Analysis of Regulatory Impact

This proposed amendment would not introduce new compliance or administrative costs (e.g. new testing) since the products affected are already regulated in Ontario. However, it would avoid duplicate testing costs for residential heat pumps and air conditioners, which would have to be tested separately to meet NRCan’s and Ontario’s requirements if Ontario requirements are not updated to harmonize with NRCan. The ministry estimates these avoided costs to average approximately $7.2 million per year over the next ten years.