Stakeholder comments form
ENER Lot 22: Domestic and commercial ovens
Additional comments from ECOS (on behalf of environmental NGOs)
April 2011
Contact: Edouard Toulouse (Ecodesign Officer) - edouard.toulouse@ecostandard.org
Stakeholder
Document
comment
relates to
Section
in doc
Page
nbr
Topic
ECOS
(expert:
Stephen
Edwards)
TASK 6
6
5
Technical
Analysis of BAT
“Main approaches to improvement of eco design....” should as much as possible also include
technologies that influence user behaviour (where that behaviour has an impact on energy
consumption).
6.1
7
State of the Art
in Applied
Research for the
Product
Unglazed door – this proposal has been rejected due to the belief that consumers will find it
unacceptable and benefits are stated as uncertain. The US DoE study suggests that there is
still benefit with 4 or less door openings which would seem more than adequate to check one
dish and given that even a glazed door has to be opened to check on the food, the argument
that door opening will offset savings is weak.
The SAVE 11 study (section 6.1.1) indicates that there is 16% energy saving at a cost of just 1
Euro. These 2 studies alone suggest that it has significant energy saving potential,
especially if it was combined with sensors.
6.1_1
9
Domestic
10
Comment
Unglazed door – comments as above
Low emissivity oven design – the energy saving potential is stated as 35% - this is
significant although the cost is high – since the SAVE 11 study in 2000, has any further
technological development happened in this area? What is the industry's perception of this
technology? Does it have a future, if not as BAT, then as BNAT?
The SAVE 11 study also identifies the optimisation of vent flow for domestic electric ovens as
an energy saving potential of 8% for an increased cost of 12 Euros This is stated as now partly
adopted. What further development potential is there?
1
Stakeholder comments form
6.1_2
11
Forced convection for gas ovens in SAVE 11 study suggests 13% saving potential at 15 Euros
cost. Yet this is stated by CECED as wrong and that forced convection in gas actually
consumes more energy.
Has this always been the case and if so how would that explain SAVE 11 results? Or is this the
result of other improvements to gas ovens in the last 10 years despite there being no labelling
scheme to encourage such significant developments?
13
The statement that “Changes to user behaviour that reduce energy consumption are difficult to
achieve” must be challenged. They are nevertheless difficult to measure (compared with
straightforward technical improvements) but not necessarily difficult to achieve. This is
an important difference.
1416
Domestic
Microwave
Ovens
There is a degree of public perception that regards microwaves with suspicion on the grounds
of health and safety owing to the microwave radiation. It appears the potential dangers are
easily overcome by correct use and maintenance of the microwave oven but perhaps there is
not wide enough communication of this. As there is significant energy saving potential in using
microwaves instead of ovens for some cooking processes (e.g. reheating food) as well as
nutritional advantages there is a definite need to consider these perceptions and
manufacturers have an important role here.
These comments are also appropriate for TASK 3 report on Consumer Behaviour and TASK 7
on Improvement Potential. This issue also suggests that combi ovens with a microwave may
enable significant savings where users are clearly informed of the savings potential for
particular cooking processes.
6.2_2
23
2324
Glass Doors
The statement “...consumers will not accept doors without glass...” can not be backed up with
any evidence and is a broad sweeping statement. 'Consumers may not accept doors without
glass' would be a fairer and more accurate description. In fact, if sensors were present and
energy savings could be demonstrated, many consumers may well be willing to have an
oven without a glass door. See also comments above for 6.1 p7.
Is there any evidence that supports the notion that the increased thermal capacity of triple or
quadruple glazed doors offsets any savings from the improved thermal insulation? Will low
emissivity coatings on the insides of the glass not counterbalance this effect by preventing the
heat from absorbing into the glass?
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Stakeholder comments form
6.2_4
26
Gas Burners
“...15% excess air is regarded as optimum for minimising energy efficiency...” should this not
be “maximising energy efficiency”?
6.2_6
28
Other
Innovations
Line 7 – perhaps this should read “...that they claim PREVENTS cooking residues from
adhering”
6.4_1
29
Sous Vide
Cooking
Similarly, another piece of low tech equipment definitely worth mentioning here is the Hay Box
(6.4_2?) as this may present some ideas for developing a modern version that could be
integrated into an oven. When cooking a casserole or similar dish the food is initially heated to
temperature (either by hob or oven) and then placed in a box packed with hay or other similar
insulation material and then left either overnight or through the day. The latent heat in the food
will be retained enough to slow cook the food without the use of any energy (except the initial
heating).
A modern version of the Hay Box with an insulated drawer and a special pot sitting under the
oven cavity is offered here to manufacturers as an open source innovation potential.
TASK 7
6.5
30
Potential for
Energy Savings
6.6_2
34
Conclusion –
Commercial
Ovens
7.1
35
Identification of
Design Options
It would be worthwhile to know exactly what proportion of worst performing ovens would have
to be removed from the market to achieve the 20% reduction in energy consumption.
Alternatively, it can be argued that energy savings through changing user behaviour presents
significant potential and opportunity - yet there appears to be a culture of belief that technology
is not able to influence behaviour. Whilst there is a challenge that the impact on user
behaviour is difficult to measure in existing test standards that make a quantitative assessment
of impact problematic, through appropriate studies and research, measuring the impact of
ecodesign on user behaviour is possible. User behaviour contributes significantly to
energy consumption across numerous sectors and appears to be particularly relevant in
the case of cooking appliances. Consideration of user behaviour must form a critical
part of innovation in ecodesign strategies.
Results for Ecodesign options for Base Cases 4-8 (Commercial Ovens) appear drastically
underestimated for energy saving potential. Except for one option of 4%, all options range
between 0.5-2.0%. This compares with 1-14% for Base Cases 1-3 (domestic ovens) and yet
commercial ovens have not been regulated unlike the domestic sector so energy savings
should actually be greater for commercial sector. Also better insulation is given as 1.5% for
both electric and gas and yet for domestic ovens is given as 4% for electric and 14% for gas.
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Stakeholder comments form
As commercial ovens have been identified as being on for longer periods than domestic ones
then insulation should provide greater energy savings than for the domestic estimates of 4%
and 14%.
1627
In Base Case 6, software controls are cited as requiring an increase in cost of 50 Euros, yet for
base case 7 the cost for the same option is given as 1400 Euros, which seems particularly
excessive.
Despite energy savings seeming to have been considerably underestimated for the
commercial sector, payback times are still radically lower than for domestic ovens and
so cost would appear not to be a barrier for ecodesign options in the commercial sector.
7.5
79
Long-term
Targets (BNAT)
Parag 2: why is feasibility of energy efficient improvements uncertain for domestic gas ovens?
Some explanation is required here.
Parag 4: commercial appliances should have greater potential for energy savings than for
domestic as they have not been regulated (see comments above). The relative increased cost
of improvements to the user will also be less than for the domestic sector due to the high
purchase cost of commercial appliances.
7.6
80
Conclusions
Parag 2: “Some improvement options even allow saving less energy in the use phase than
what they require during the other life cycle phases” This sentence is very unclear as to what it
is trying to say.
GENERAL
There appears to be a lack of ambition particularly from the commercial sector. Targets
and improvement potentials are worryingly small considering there is much scientific
opinion that believes we need to cut emissions by up to 80% by 2050. Innovative
technological options presented in the research are dismissed on cost or consumer
unacceptability, which is not always clearly explained.
Commercial ovens small improvement potential is explained due to less variability in energy
performance than in the domestic sector. This appears questionable. Also the commercial
sector has been stated as much more varied, disparate, fragmented and is currently less
regulated (no labelling scheme) than domestic sector, and this would therefore suggest there
has been little incentive for improvement and consequently significant improvement potential.
4
Stakeholder comments form
Innovation will nearly always cost more until the new technology reaches maturity (e.g.
induction hobs were significantly more expensive than standard electric hobs when first
released onto the market but over last 5 years have dramatically decreased in price and are
becoming competitive and demonstrate significant energy savings). To what extent should
cost be given as a barrier? There is growing evidence that consumers will pay more for energy
efficient products.
User behaviour is an important consideration for all energy using products but appears to be
particularly relevant for cooking appliances. User behaviour needs to be taken more seriously
by the industry – this is a design challenge where designers and manufacturers need to
consider in more depth how:




to understand the behaviour patterns of users
to view the product from a user's point of view
to identify ways in which the design of a product can influence the user
communicate the ecodesign features to the user effectively
A user-centred, participatory design approach would enable addressing of behaviour
elements of energy consumption. Better communication of energy-saving features is a
key factor in improving user behaviour.
There are no test standards that account for user behaviour. Could test standards or
appropriate academic research be explored in the future that consider and measure user
behaviour to inform the EU's ecodesign strategy? This may be more time consuming and less
precise, but as technology improves, the impact of the user becomes even more critical.
Patents are understandably required in some cases but can stifle innovation. Could
mechanisms be increased that encourage knowledge sharing and technology transfer across
the industry? For example, open source technology that would lead to greater collaboration
between domestic and commercial sectors and also across into other sectors, thereby
maximising innovation.
5