Comments of

The Air-Conditioning, Heating, and Refrigeration Institute (AHRI)

On

The Australian/New Zealand Regulatory Impact Statement (RIS) on Air conditioners and Chillers
(February 2016)

AHRI is pleased to have the opportunity to comment on the above-referenced RIS. AHRI is a not-for-
profit trade association, chartered in North America, with global interests and global services,AHRI
represents more than 300 manufacturer members from virtually every continent, that produce more
than 70 percent of the world’s heating, cooling, commercial refrigeration, and water heater
equipment. AHRI’s three main activities, buttressed by an extensive research program and training
and education activities, are: Advocacy, Standardization, and Certification.

AHRI commends the Australian and New Zealand governments for this very appropriate initiative.
AHRI believes in and endorses those governmental initiatives that aim to ensure the availability of
high quality HVACR and water heating equipment to customers in any market, and that provide for a
credible program that verifies claimed energy efficiency of such equipment. This helps governments
reach energy efficiency targets and provides for a level playing field for manufacturers. The benefits of
these two goals, if achieved, accrue to the consumer and to society in general.

AHRI notes that that the governments’ stated1 objective is to amend existing regulations concerning
air conditioners and chillers “…where there is scope for significant simplification and harmonisation
changes…which can address adverse consequences and improve energy efficiency.”

AHRI members constantly innovate to improve the performance, including energy efficiency, of the
products and equipment they manufacture. They recognize the value of that innovation to
governments, the industry, and consumers and therefore, in concert with ASHRAE, produce the
largest global technical body of knowledge on test methods, testing and rating standards, and
minimum energy performance standards (MEPS) values for equipment. AHRI is also fortunate to
benefit from the experience and data derived from managing the AHRI Certification Program -- the
globally recognized, industry respected voluntary program that verifies energy efficiency claims of
equipment produced by the world’s leading HVACR and water heating manufacturers. That growing
program has more than 400 participating manufacturers from almost 30 countries2.

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RIS. P. v.
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www.ahrinet.org
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 Specific Comments

Chillers

AHRI supports updating chiller MEPS based on ASHRAE Standard 90.1. Further, AHRI strongly
recommends the referencing of AHRI Standard 550/590 (I-P)-2015 with Errata, Performance Rating of
Water-chilling and Heat Pump Water-heating Packages Using the Vapor Compression Cycle – Effective
on April 1, 2016, or its metric (SI) companion document, AHRI Standard 551/591 (SI)-2015 with Errata,
Performance Rating of Water-chilling and Heat Pump Water-heating Packages Using the Vapor
Compression Cycle – Effective on April 1, 2016.

AHRI also understands that there are discussions in Australia concerning the comprehensiveness and
global scope of the AHRI standards and certification program. Specifically, we understand these
conversations involve a comparison of the AHRI and Eurovent certification programs3. AHRI is very
familiar with the Eurovent program, having established it with European partners more than twenty
years ago to address European needs. Despite what may appear to similarities, there are differences
between the two programs, with AHRI’s being global4.

1. Certified Data (One Point vs Operating Map)

- Eurovent only certifies performance at Eurovent Standard Rating Conditions which include ESEER.

- AHRI certifies the entire operating map of water-cooled products and the entire operating 100% load
map of air-cooled products including IPLV. This is critical in terms of the availability of certified data
that can be used in building analysis in addition to data at the Standard Rating Condition, which is only
a single point of operation of infinite number of points.

2. Certification Program Scope (Small vs Large Range)

- Eurovent certifies the performance of air-cooled chillers up to 170 tons (600kW) and water-cooled
chillers up to 426tons (1500kW).

- AHRI certifies the performance of air-cooled chillers up to 600 tons (2110kW) and water-cooled
chillers up to 3000 tons (10551kW).

- AHRI provides free certification verification services that will ensure customers’ ratings provided for
specific jobs are certified.

3. Testing Requirements (General vs Detailed)

- Eurovent specifies general testing requirements and laboratory approval.

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RIS Option B.
4
AHRI 550/590 is one of a suite of AHRI standards currently being adopted by the Kingdom of Saudi Arabia for
its MEPS compliance program for commercial air conditioners and chillers.
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- AHRI details specific requirements for air-cooled and water-cooled chiller testing including diagrams,
checklists, and a laboratory approval process that does not exist in the Eurovent Chillers Certification
Program.

4. Testing Standard (European vs Global)

- Eurovent tests to a European based standard.

- AHRI is updating AHRI Standards 550/590 and 551/591 to include global climate zone standard rating
conditions (i.e. a separate standard rating condition for each global climate zone).

5. Global relevance (European vs Global)

- Eurovent’s program consists of participants doing business in Europe.

- AHRI’s program consists of participants doing business globally; including all major manufacturers
from China, India, and the Middle East.

- AHRI’s program is specified globally.

Multi-splits and VRF

The RIS raises5 several questions regarding the adoption/adaptation of international standards for
Australian and New Zealand use, and understandably frames that question in terms of ISO standards.
Framing the issue in that fashion suggests that authorities may not realize that there are many
international standards that are not ISO standards, and that those standards also need to be reviewed
and considered. This is certainly the case for AHRI and ASHRAE standards.

There are three important reasons to include the above standards in the review: First, the AHRI
testing and rating standards and ASHRAE 90.1, which specifies MEPS levels, constitute the only
complementary set of standards that directly links testing rating, and certified results of nearly all
production models to a specific MEPS level. The latter is found in ASHRAE 90.1, and the former in the
AHRI standards. No such combination and reference exists in any other global HVACR standards. The
ramification of specifying a non-AHRI standard, not directly linked to a testing/certification scheme
will result in testing of individual units or self-declaration. The ASHRAE 90.1 values derive from testing
using AHRI standards and thus provide a credible reference for tested equipment.

Second, as more countries consider establishing effective energy efficiency and market surveillance
programs, the need for the linkage is increasingly obvious; thus the reason for increased adoption of
the AHRI and ASHRAE standards globally.

Third, the ASHRAE test methods and the AHRI testing and rating standards are the world’s most
rigorous, dependable, and verifiable. These standards are also the basis of the AHRI global
certification program which has become the global Gold Standard for HVACR and water heater energy
efficiency verification.

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P. 40
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In this context for multi-splits and VRF, AHRI strong recommends that the RIS reference AHRI 340/360,
Performance Rating of Commercial and Industrial Unitary Air-conditioning and Heat Pump Equipment
– 2015, and AHRI 1230, Performance Rating of Variable Refrigerant Flow (VRF) Multi-Split Air-
Conditioning and Heat Pump Equipment – 2010.

AHRI especially recommends AHRI Standard 1230 because it tests and rates the entire VRF system,
rather than just the outdoor unit, thereby delivering a more reliable assessment of system efficiency.
MEPS levels for equipment tested to these standards are found in ASHRAE 90.1

AHRI appreciates the opportunity to comment on this excellent effort by the Australian and New
Zealand governments, and is ready to discuss any of these points, and any others, the governments
may wish, regarding the RIS, and will provide additional information if requested.

Please note that AHRI’s standards are available for download, free of charge, on the AHRI website.6 .

Best Regards,

/s/

Jim Walters

James K. Walters

Vice President, International Affairs

Air-Conditioning, Heating, and Refrigeration Institute

2111 Wilson Blvd, Suite 500

Arlington, VA 22201

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Op. cit.
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