Stakeholder comments form
Organisation: INFORSE-Europe and ECOS
Name: Gunnar Boye Olesen and Stamatis Sivitos
Date: May 4, 2012
ENER Lot 20: Local room heating products
Document
comment
relates to
Section in
document
Page
number
Topic
All
n.a.
n.a.
General
Task 5
report and
following
5.1.4
14ff
Energy
Consumption
calculation
Comment
Room heaters are converting a large share of
Europe's energy supply into space heating.
They consume as much as 1/3 of the
consumption of boilers, the energy using
product with the largest use in Europe.
Combining this with the large improvement
options for many of the room heaters, there
are significant opportunities to save energy
with Ecodesign and labelling regulations for
these products. The Ecodesign product
regulation
must
complement
building
regulations, which in some countries it gives
clear guidance on where to use and where
not to use certain room heating products,
such as electric heaters.
The choice of methodologies to evaluate the
efficiency of room heaters in the preparatory
studies are not based on a seasonal
efficiency and are not harmonised among the
base cases with a similar function (such as
residential space heating ). The lack of a
coherent
and
adequate
methodology
weakens the identification of improvement
options and comparison of the different room
heating technologies. We therefore propose
to use seasonal efficiency for the
Proposed change
See following proposals
Efficiency calculations for room heaters are
changed to seasonal efficiencies for all
products covered (all base cases). The method
must include the effects of controls including
different thermostats.
Where test and calculation standards are not in
place for seasonal efficiency (including partload testing), the preparatory study shall
highlight the missing standards and propose
transitional measures until standards can be in
Stakeholder comments form
Document
comment
relates to
Section in
document
Page
number
Topic
Task 5
report and
following
5.1.2 and
following
10ff
General
Task 5
report and
5.1.3,
table 5.2.
p.13ff
Base cases
Comment
evaluation of efficiency as it is done for
ecodesign of other space heating
equipment (e.g. boilers in ENER Lot 1). If
test and calculation standards are not in place
for evaluating seasonal efficiency, the study
should highlight the lack of these and specify
the necessary ones needed, highlighting the
need for a mandate to be issued by the
European Commission in this area. The
proposal for standardisation work to be
undertaken in CEN TC180 (technical
committee on non domestic gas heaters), is
indeed a step in the right direction.
The choice of base cases in the task 5 report
show that half of the base cases (base case 1
- open combustion flued gas heater, 2 – open
combustion flued gas fire, 4 - fixed electric
convector heater, 5 - electric storage heater,
6 – underfloor electric heating) are effectively
fulfilling the same function: heating a room of
15 m2 in a reasonably insulated house
(consumption for the room is 1130 kWh per
year which equals 75 kWh/ m2 per year,
except for electric storage heaters, where a
15m2 room with a higher consumption is
chosen). Since these base cases have the
same function, they can in many ways be
treated as one case.
The choice of a room of 15 m2 conceals
the fact that the costs and benefits of
different choices varies with the size of
Proposed change
place.
The base cases with the same function
(heating of a room, BC 1, 2, 4, 5, 6) are grouped
into a super-base case in the reports 5-8 with
similar improvement options etc.
For the proposed “super base case” with BC
1,2,3,5, and 6, energy and economic
Stakeholder comments form
Document
comment
relates to
Section in
document
Page
number
following
and
following
Task 5
report and
following
5.1.3,
table 5.3
and
following
p.13ff
Task 7
report
7.1, table
7-1 to 7-12
p.9ff
Topic
Improvement
options
Comment
Proposed change
the heat demand. This is very clear from the
improvement proposals of the base case 4,
where an air-air heat pump is correctly stated
as the BAT among local heating solutions, but
is not included as an improvement option
based on the argument that it is too
expensive. In practice this option is chosen by
many house owners and leads to a good user
economy because they are being used in
larger rooms, typically the living- room of a
house. If a room size of 30 m2 was chosen as
a second room size for base cases 1,2,4,5
and 6, this would have given a different
picture, where the more advanced equipment,
such as heat pumps would be more
economically advantageous.
The choice of a larger consumption for the
storage electric heater base case (BC5)
compared to other residential room heaters is
not logical, and makes it more difficult to
compare the different technologies. The
argument that these heaters are used in the
UK for rooms which are heated more
permanently compared to other rooms heated
by electricity is weak. Dwellings with electric
room heaters are in general heated rooms
with a comfort temperature similar to other
heated spaces.
calculations are also carried out for a room of
30 m2.
The improvement potentials are in several
cases not well documented, and should be
Include calculation methods and
documentation with sources for the
Energy demand of the room is set to the same
for BC5 as for the other base cases.
Stakeholder comments form
Document
comment
relates to
Task 8
report
Task 8
report
Section in
document
8.2.3.1
8.2.3.2
Page
number
p.12
P13ff
Topic
Calculation
and
Ecodesign
requirements
Ecodesign
measures
Comment
Proposed change
improved. This is for instance the case of the
proposal of absence detection
improvement options for all base cases, based
on a coherent method w. seasonal efficiency
For gas heaters we support the proposal of
minimum energy efficiency (MEPS), but insist
that it shall be based on seasonal efficiency
and gross calorific value, not on net calorific
value as proposed. For gas heaters we
propose air quality requirements similar to the
requirements for gas boilers (ENER Lot 1),
with the possibility for stricter national
requirements.
Given the large use of electric resistance
heating for residential space heating, we
find it absolutely essential to start
regulating this product group due to the
large energy consumption associated with
these products. We propose that a seasonal
minimum efficiency is set that requires
advanced thermostat control (PI regulator)
and timers for set-back control. These
improvement options have pay-back periods
of respectively 0.41 years and 1.25 years,
with a combined savings potential of just
above 20%. Even though the evaluation of
the
improvement
potentials
includes
substantial uncertainty, there is little doubt
that these functions are justified for room
heaters used as primary space heating. In
practice this can be required for fixed room
heaters. For portable electric room heaters,
the use of advanced thermostats (PI
MEPS shall be proposed based on gross
calorific value seasonal efficiency with a
method that include the effects of controls
NOx limits shall be proposed
Ecodesign requirements shall be included for
seasonal minimum energy efficiency
requirements on a level that requires advanced
thermostat control (PI regulator) and timers for
set-back control for fixed electric heaters.
The misleading text of 100% real life efficiency
of electric heater is replaced with a text that
discusses the losses by overheating with
simple thermostat as well as the saving
potentials of timer-controlled temperature setback.
For portable electric heaters ecodesign
requirements shall be included for seasonal
minimum energy efficiency requirements at a
level that requires advanced thermostat control
(PI regulator)
Stakeholder comments form
Document
comment
relates to
Section in
document
Page
number
Topic
Comment
Proposed change
regulators) can be set as the minimum
requirement.
Task 8
report
8.2.3
P12-14
Labelling
Task 8
report
8.2.4.1
14-15
Calculation
method,
information
Not regulating residential electric room
heaters, as proposed in the report, would
be a huge lost opportunity to improve
energy efficiency and reduce energy
consumption.
For all fixed, residential room heaters, in
addition to minimum requirements, it is
essential to inform consumers via a label
that shows the difference between these
room heaters, including both room heaters of
similar technology and those with different
technologies. This label should cover base
cases 1, 2, 4, and 5 and eventually 6 (floor
heating).
For large, warm-air heaters (furnaces) >
12kW (BC7), we support the proposal for
MEPS, but insist that they should be based
on seasonal efficiency and that the gross
calorific value should be taken into account,
not the net calorific value as proposed. We
understand that a labelling scheme might not
be useful, but insist that the obligatory
information must include seasonal efficiencies
for the most popular use patterns. Gas-and oil
fuelled heaters should be harmonised with
ENER Lot 21 and for air pollution related
issues also with ENER Lot 1.
Propose an energy efficiency label based on
seasonal efficiency to cover the base cases 1,
2, 4, and 5 and eventually 6, compatible with
existing EU energy efficiency labels in the field.
MEPS shall be based on seasonal efficiency
and gross calorific value.
Consumer requirements of seasonal efficiency
for the most popular use patterns (these
patterns shall be defined by regulation and
standards, not by manufacturers).
NOx requirements are set similar to ENER Lot1
Stakeholder comments form
Document
comment
relates to
Section in
document
Page
number
Task 8
report
8.2.4.2
15-17
Topic
Labelling,
NOx
requirements
Task 8
report
8.2.4.3
p-17-18
Information
requirements
Task 8
report
8.2
p.12ff
Recycling
Comment
For radiant gas heater >12 kW (BC8) we
support the proposed minimum radiant
factors and the requirements for various
controls including temperature controls, but
insist that regulation should be enforced that
drives this technology towards better partload efficiency. We therefore propose a
labelling scheme, based on a seasonal
efficiency, where part load use plays an
important role. We also support that air
pollutant emission limits are set and that
the levels are not higher than those for boilers
but stricter when the combustion products are
introduced into indoor air (which they often
are).
For the base case 9, air curtains, we support
the
proposals
for
energy
efficiency
requirements and requirements for controls,
as well as benchmarks for air stream controls.
We
also
support
the
information
requirements, but insist that in these it is
clearly specified that the technical indicative
benchmark includes use of heat pumps as
well as central heating to supply heat to the
air curtain.
Proposed change
Propose a labelling scheme, based on
seasonal efficiency.
Propose NOx limits similar to ENER Lot 1, and
stricter levels for applications where the
combustion products are introduced into
indoor air (which they often are).
In the information requirements, it should be
clearly specified that the technical indicative
benchmark includes use of heat pumps as well
as central heating to supply heat to the air
curtain.
We also support proposals related to takeback systems for heaters, to improve Take-back systems of used products should be
considered - whenever relevant - as a
recycling and promote resource efficiency.
requirement.
Stakeholder comments form
Document
comment
relates to
Section in
document
Page
number
Task 8
report
8.2
p.12ff
Topic
Benchmarks
Comment
Proposed change
The establishment of indicative benchmarks
is of importance, but there should be two Indicative benchmarks are set in two levels:
levels for these: one for the same technology one for the same technology and one for the
and one for the same function. In this way, same function.
the first benchmark for an electric heater
would be an electric heater with advanced
controls while the second benchmark would
be a heat pump, or a central heating system if
supplied with heat from renewable energy or
efficient combined heat and power (CHP).
Stakeholder comments form
Proposal for a possible energy labelling scheme for room heaters.
Gunnar Boye Olesen, INFORSE-Europe, May 2012
Background and rationale: The sale of electric radiators, convection heaters, and heaters or fires with built-in fans is according to the
manufacturers of fixed electric heaters (except for underfloor heating) 10,6 mill. units/year while fixed gas heaters is 0,7 mill units/year, in total 11,3
mill. units/year (data from lot20, task 2 report, numbers for 2009.)
The consumption per room and heater is in the base cases 1,2, 4, 6 1130 kWh of heat (one heater per room). This results in energy (electricity
and gas) consumption from the annual sale of fixed electric and gas heaters of 13 TWh. With the expected 12-year lifetime, the total consumption
is 156 TWh of electricity and gas, or converted to primary energy 375 TWh. If a label results in a 7.5% reduction (30% of consumers use label and
save in average 25% by using the label, a conservative figure that does not include the market transformation effect) the saving will be 28 TWh
of primary energy after 12 years (in 2025). This is a sufficient enough reason to introduce a room heater label. If the use of an energy label leads
to market transformation, the savings can be 2-5 times higher.
Scope: The label should cover the residential local room heating options, including electric resistance heating, local gas heaters, and air-air heat
pumps. The inclusion of floor heating can be considered.
Possible efficiency indicators: To evaluate the possible labels, the following table compares the agreed or proposed labelling schemes related to
space heating:
first column: labels for boilers (lot1), second column: labels for low-temperature heat pumps (lot 1), third and fourth column: and air-air heat
pumps. For air-air heat pumps the first column is the efficiency recalculated to the lot1 boiler efficiency 1. The last column is the SCOP (Seasonal
COP) that is used in the agreed air-air heat pump label.
Label class
Boiler eff
Low-T HP eff.
Air-air heat pumps Air-air heat pumps
A+++
lot1-eff.> 150
lot1-eff.> 175
lot1-eff.> 206
SCOP >5,10
A++
lot1-eff.> 125
lot1-eff.>150
lot1-eff.> 186
SCOP >4,6
A+
lot1-eff.> 98
lot1-eff.>123
lot1-eff.> 162
SCOP >4,0
A
lot1-eff.> 90
lot1-eff.>115
lot1-eff.> 138
SCOP >3,4
B
lot1-eff.> 82
lot1-eff.>107
lot1-eff.> 126
SCOP >3,1
C
lot1-eff.>75
lot1-eff.>100
lot1-eff.> 114
SCOP >2,8
D
lot1-eff.> 37
lot1-eff.> 62
lot1-eff.> 102
SCOP >2,5
1
boiler.
Boiler (lot1) efficiency from SCOP by dividing with the primary energy factor of 2.5, subtracting 3% loss because of lack of regulation, and adding 5% because of avoided heat system losses compared with heat from a
Stakeholder comments form
E
lot1-eff.>34
lot1-eff.> 59
lot1-eff.> 90
SCOP >2,2
F
lot1-eff.> 30
lot1-eff.> 55
lot1-eff.> 78
SCOP >1,9
Ideas for possible labels: Comparing the scales of the proposed boiler label and the air-air heat pumps, it is clear that they are too different to be
merged into one joint label, applied to all the different kinds of room heaters.
Instead it could be used as an energy efficiency or energy consumption index, following the SCOP of heat pumps or the Lot1- energy efficiency. It
could be a label with just an efficiency indicator without any arrows. An example is given below:
Efficiency(SCOP)
kW
0.95
1.0
With this example, the number would be similar to the SCOP of the air-air heat pumps, and thus the air-air heat pumps would not need the label,
since the SCOP already appears on the agreed label for these heat pumps. To use the label for gas heaters, the conversion factor of 2.5 could be
used to equate with electricity. Based on this proposal the different room heaters would have the following approximate efficiency index:
electric storage heaters: 0.7 – 0.9
electric convection heaters: 0.8 - 1.0 (with simple and advanced thermostatic controls)
 electric convection heaters with timer/night set-back: 0.9 – 1.2 (if it is allowed to have more than 100% efficiency for heaters than can
regulate the temperature of the room, a night set-back bonus)
 radiant electric heaters: 0.9 – 1.1 (with simple and advanced controls, assuming 2oC lower room temperatures)
Stakeholder comments form



radiant electric heaters with timer/night set-back: 1-1.3
gas heaters: 1.7 – 2.2 (with minimum efficiency of 90% on lower calorific value, different thermostatic controls
gas heaters with timer/night set-back: 1.8 – 2.5 (allowing more than 100% efficiency for heaters than can regulate the temperature of the
room)
 least efficient air-air heat pump allowed in 2013: 3.4
 A+++ air-air heat pump: 5.1
(the numbers are approximate and illustrate the values that could be used)
The benefit of this label would be:
 it corresponds to the air-air heat pump (SCOP is used as an efficiency indicator)
 no need for double label on air-air heat pumps
 no confusion with existing labels
Issues for further discussion
The details about the timer and control bonus must be discussed. There should be some additional requirements to claim the bonus, such as a
simple user instruction, minimum lifetime of eventual battery to power the control, factory set night-set-back (if night set-back is included.)
Test standards for part load do not exist for all equipment and are needed for the SCOP. It will be easy to implement this for electric heaters, but
some further work might be needed for part-load efficiency of gas heaters. The study should highlight the lack of these standards highlighting the
need for a mandate to be issued by the European Commission in this area.