Comments on the NRCan May 2021 technical bulletin on amending the standards for appliances

Robert Singlehurst

Equipment Division
Office of Energy Efficiency
Natural Resources Canada
930 Carling Avenue, Building 3, 1st Floor
Ottawa, Ontario K1A 0Y3 

RE: A17 to the Energy Efficiency Regulations – Appliances 

Dear Mr. Singlehurst: 

This letter constitutes the comments of Efficiency Canada and the Appliance Standards Awareness  Project (ASAP) on the Natural Resources Canada (NRCan) May 2021 technical bulletin on amending the  standards for appliances. 

Efficiency Canada is the national voice for an energy efficient economy. We are a research and advocacy  organization housed at Carleton University’s Sustainable Energy Research Centre. 

ASAP organizes and leads a broad-based U.S. coalition effort that works to advance, win, and defend  new appliance, equipment, and lighting standards that deliver large energy and water savings, monetary  savings, and environmental benefits. ASAP is led by a steering committee that includes representatives  from energy and water efficiency organizations, the environmental community, consumer groups,  utilities, and state government.  

We support the proposed approach of adopting minimum energy performance standards (MEPS) that  are equivalent to the ENERGY STAR efficiency criteria. In response to the December 13, 2019 Mandate  Letter,1 NRCan is considering amending the MEPS for clothes dryers, clothes washers, dishwashers, and  refrigerators and freezers to the ENERGY STAR efficiency criteria that was in effect as of December 2019.  

NRCan’s preliminary analysis shows that these updated standards would achieve net benefits of $5.9  billion CAD through 2050 and reduce cumulative CO2 emissions by 19 million metric tons.2 Furthermore,  the estimate of net benefits is likely to be conservative for at least three reasons: (1) NRCan’s analysis is  based on current product prices in the market, which may overstate the actual incremental cost of  models that meet the ENERGY STAR performance levels since ENERGY STAR models are currently a  premium product; (2) as NRCan noted during the June 16 webinars, while the analysis assumes that  costs remain constant over time, in practice costs tend to decrease over time; and (3) NRCan’s analysis does not monetize water savings, which can be significant for clothes washers and dishwashers.

The updated MEPS under consideration would harmonize with the higher tier of efficiency levels in  the North American market. There are effectively two efficiency tiers of appliances in the North American market—those that just meet the MEPS and those that meet the ENERGY STAR performance  levels. The ENERGY STAR levels represent established efficiency levels with high market penetration; for  each of the four product categories (clothes dryers, clothes washers, dishwashers, and refrigerators and  freezers), at least 50% of current shipments in Canada already meet the ENERGY STAR efficiency levels.3 The proposed amendments to the MEPS will thus harmonize with the higher tier of efficiency levels in  the North American market. 

It is appropriate for Canada to take the lead on MEPS for appliances as the U.S. has fallen behind. The  Canadian MEPS are generally harmonized with U.S. standards. However, the U.S. is significantly behind schedule in updating efficiency standards for a wide range of products including home appliances. The  U.S. Department of Energy (DOE) was required to publish proposed rules4 in 2017 to update the  standards for clothes dryers and refrigerators and freezers and in 2018 and 2019 for clothes washers  and dishwashers, respectively,5 but DOE is still at the preliminary stages for all these rulemakings and  has yet to publish any proposed rules. Furthermore, for home appliances, the U.S. appliance standards  law requires a 3-year lead time between publication of a final rule amending energy conservation  standards and the compliance date.6 Therefore, it is appropriate for Canada to establish amended MEPS  that can achieve significant greenhouse gas reductions and savings for Canadian consumers in the  meantime as the U.S. works to catch up on missed deadlines for updating standards. Once the U.S.  completes updates to the standards for home appliances, Canada can harmonize with any U.S.  standards (and accompanying compliance dates) that are more stringent than the Canadian standards. 

We support NRCan’s proposal to add gas clothes dryers as a regulated product. While the U.S.  standards for clothes dryers apply to both electric and gas models, the current Canadian MEPS apply  only to electric dryers. The addition of gas clothes dryers would harmonize the scope of the Canadian  standards with the U.S. standards and achieve additional savings. 

We urge NRCan to require that clothes dryers be tested using Appendix D2 (or equivalent provisions  in CSA C361-16). In the May 2021 Technical Bulletin, NRCan proposes to allow clothes dryers to be  tested to any of three testing standards for determining compliance with the MEPS: CSA C361-16 for  electric clothes dryers, and Appendix D1 or Appendix D27—which are the U.S. DOE test procedures for  clothes dryers—for electric or gas dryers.8 We understand that CSA C361-16 includes provisions that are  equivalent to those in Appendix D1 and Appendix D2.

The current efficiency standards for clothes dryers in the U.S. were developed based on performance  according to Appendix D1, although manufacturers can certify clothes dryer models as meeting the DOE  standards using either Appendix D1 or Appendix D2. The significant difference between Appendix D1  and Appendix D2 is that Appendix D1 fails to capture the impact of automatic termination controls. For  dryers with automatic termination controls, Appendix D1 requires the test technician to stop the drying  cycle when the remaining moisture content (RMC) of the test load is between 2 and 5 percent.9 In  contrast, Appendix D2 requires that the dryer be operated until it automatically shuts off.10 DOE’s  testing has found that many dryers have poor automatic termination controls that result in significant  overdrying of the clothes and corresponding wasted energy. Yet this wasted energy use is not captured  in Appendix D1. For example, while the current minimum Combined Energy Factor (CEF) standard for  vented standard electric clothes dryers is 3.73 lb/kWh (1.69 kg/kWh), the least-efficient model in DOE’s  test sample based on testing according to Appendix D2 had a CEF of just 2.20 lb/kWh.11 

The U.S. is already moving towards requiring testing according to Appendix D2. While manufacturers can  certify clothes dryer models as meeting the DOE standards using either Appendix D1 or Appendix D2,  EPA requires that Appendix D2 be used to determine ENERGY STAR qualification.12 Furthermore, DOE  has indicated in their recently published preliminary analysis for clothes dryers that the next U.S.  standards will be based on the Appendix D2 test procedure (i.e., that manufacturers will be required to test to Appendix D2 for determining compliance with future standards).13 

The May 2021 Technical Bulletin states that the new standards under consideration “would reduce the  energy use of household clothes dryers sold in Canada by approximately 25%,”14 which is consistent  with our understanding of typical savings from dryers meeting the ENERGY STAR specification. However,  importantly, most of these savings come not from the higher CEF levels compared to the minimum  standards, but rather the required use of Appendix D2. For example, for vented standard electric dryers,  the minimum standard is 1.69 kg/kWh and the new MEPS under consideration is 1.78 kg/kWh, which,  based on testing to the same test procedure, represents energy savings of about 5 percent.15 But while  ENERGY STAR certified clothes dryers are tested to Appendix D2, typical baseline clothes dryers just  meeting the minimum standards are tested to Appendix D1 and perform significantly less efficiently  when tested to Appendix D2. Therefore, we urge NRCan to specify that clothes dryers must be tested  using Appendix D2 (or equivalent provisions in CSA C361-16) in order to ensure that the expected  savings from the ENERGY STAR performance levels are realized. 

Thank you for considering these comments. 

Sincerely, 

Brendan Haley, PhD
Policy Director
Efficiency Canada

Joanna Mauer 
Technical Advocacy Manager
Appliance Standards Awareness Project