Commercial gas- and oil-fired water heaters

July 2017

Technical bulletin on developing the standards

Webinar – August 2017

On March 4, 2017, the Office of Energy Efficiency at Natural Resources Canada (NRCan) issued a Notice of Intent to amend Canada’s Energy Efficiency Regulations (the Regulations) to adopt  minimum energy performance standards (MEPS) for commercial gas- and oil-fired water heaters. This technical bulletin has been released to initiate the consultation process and to collect stakeholder views on the requirements being considered for commercial gas and oil-fired water heaters.

Input received during this stage of the process will inform the development of the Amendment 15 proposal.  In addition, NRCan is undertaking a cost-benefit analysis using the best-available Canadian market data to assess the economic and environmental impacts of these updated standards and to ensure Canadian consumers and businesses benefit from their implementation.

The Government of Canada intends to pre-publish a regulatory proposal in the Canada Gazette, Part I, within approximately two years of this bulletin.

Background

Through the Pan-Canadian Framework and Energy and Mines Minister’s Conference the federal, provincial and territorial governments have committed to working together to achieve climate change goals. Through this collaboration, governments agreed that standards for some space and water heating products, such as commercial water heaters could, for climatic and market reasons, differ from those in the U.S.

In Canada, commercial water heaters are not subject to the Regulations.  NRCan is considering introducing MEPS for commercial gas- and oil-fired storage water heaters, residential-duty gas- and oil-fired storage water heaters, and commercial instantaneous gas-fired water heaters. NRCan has undertaken a market study to look at the potential costs and benefits of introducing standards for commercial water heaters at different benchmark levels, including at:

NRCan’s assessment of the market shows that commercial gas- and oil-fired water heaters shipped in Canada are at or above the current United States Department of Energy (U.S. DOE) MEPS of 80% thermal efficiency.  NRCan is therefore considering MEPS levels that are beyond those currently regulated in the U.S. for gas-fired water heaters and at the current U.S. levels for oil-fired water heaters.

Gas-fired water heaters

A preliminary cost benefit analysis suggests that introducing MEPS at the following thermal efficiency and standby loss levels is economically feasible in Canada: 

Commercial gas-fired storage water heaters in:

  • new construction – at the minimum condensing thermal efficiency level and U.S. NOPR standby loss levels
  • existing construction – at a modest increase above current U.S. DOE levels for thermal efficiency and standby loss requirements at current DOE levels.

Residential duty commercial gas-fired water heaters in:

  • new construction – at a UEF (uniform energy factor) equivalent of the minimum condensing thermal efficiency level and U.S. NOPR standby loss levels, and
  • existing construction – at a UEF equivalent of a modest increase above current U.S. DOE levels for thermal efficiency and with standby loss requirements at current DOE levels.

Commercial gas-fired instantaneous water heaters in:

  • new and existing construction – at U.S. NOPR thermal efficiency level.

Oil-fired water heaters

NRCan is considering setting MEPS at the current U.S. DOE levels for thermal efficiency and standby loss for commercial oil-fired storage water heaters in new and existing construction.

Product description

A commercial water heater heats water for use in cooking, cleaning, and bathing, using natural gas, propane or oil as the fuel source. Commercial gas-fired storage water heaters have input rates of ≥75,000 Btu/h. Commercial oil-fired storage water heaters have input rates of ≥105,000 Btu/h. Commercial gas-fired instantaneous water heaters have input rates of ≥200,000 Btu/h.

Energy performance testing standard

NRCan is considering referencing the following energy performance testing standards:

Residential duty commercial water heaters

CSA P.3-15Testing method for measuring energy consumption and determining efficiencies of gas-fired and fuel oil-fired water heaters

Commercial water heaters

ANSI Z21.10.3-2015/CSA 4.3-2015Gas-fired water heaters, Volume III, storage water heaters with input ratings above 75,000 Btu per hour, circulating and instantaneous

The CSA testing standard can be ordered from:

CSA Group
Toll free phone: 1-800-463-6727
In Toronto, call 416-747-4044
E-mail: sales@csagroup.org
Website: http://www.shop.csa.ca

Some CSA energy efficiency testing standards are also available at no cost on their website. To access free standards you will first need to create an account to join the CSA Communities of Interest.

Energy performance standard

Minimum energy performance standards being considered for commercial gas- and oil-fired water heaters
New construction
Product type Heating capacity Btu/h Minimum efficiency
Residential duty commercial gas-fired storage water heater 75,000 to <105,000 Btu/h UEF ≥ 0.7856 – (0.0009 x Vr)
Commercial gas-fired storage water heater ≥105,000 Btu/h TE ≥ 90%
SL ≤ 0.63*(Q/800+110√Vr)
Residential duty commercial oil-fired storage water heater ≥105,000 Btu/h and <140,000 Btu/h UEF ≥ 0.6740 – (0.0013 x Vr)
Commercial oil-fired storage water heater ≥140,000 Btu/h TE ≥ 80%
SL ≤ Q/800+110√Vr
Commercial gas-fired instantaneous water heater ≥200,000 Btu/h TE ≥ 94%

UEF is the uniform energy factor
Vr is rated volume (gal)
TE is thermal efficiency
SL is standby loss (Btu/h)
Q is input rate (Btu/h)

Minimum energy performance standards being considered for commercial gas- and oil-fired water heaters
Existing construction
Product type Heating capacity Btu/h Minimum efficiency
Residential duty commercial gas-fired storage water heater 75,000 to <105,000 Btu/h UEF ≥ 0.6719 – (0.0009 x Vr)
Commercial gas-fired storage water heater ≥105,000 Btu/h TE ≥ 82%
SL ≤ (Q/800+110√Vr)
Residential duty commercial oil-fired storage water heater ≥105,000 Btu/h and <140,000 Btu/h UEF ≥ 0.6740 – (0.0013 x Vr)
Commercial oil-fired storage water heater ≥140,000 Btu/h TE ≥ 80%
SL ≤ Q/800+110√Vr
Commercial gas-fired instantaneous water heater ≥200,000 Btu/h TE ≥ 94%

UEF is the uniform energy factor
Vr is rated volume (gal)
TE is thermal efficiency
SL is standby loss (Btu/h)
Q is input rate (Btu/h)

Important dates

These regulations would come into force six months after the date of publication in the Canada Gazette, Part II.

NRCan is considering applying the new standards to commercial gas- and oil-fired water heaters manufactured on or after January 1, 2020.

Verification requirements

NRCan would require that these products carry a third party verification mark indicating that the product mets the MEPS and that information to be reported has been verified.

The verification mark is the mark of a Standards Council of Canada accredited certification body that operates an energy efficiency certification program for the product.

Reporting requirements

Energy efficiency report

The energy efficiency report required for commercial water heaters would include the following information:

  • name of product (i.e. commercial water heater)
  • brand name
  • model number
  • name of the manufacturer
  • name of the certification body whose verification mark would be affixed to the product
  • input rate, in kW
  • uniform energy factor or thermal efficiency
  • if applicable, the standby loss
  • volume of storage tank, in litres
  • maximum flow rate

The Regulations apply to products imported or shipped inter-provincially for sale or lease in Canada. This report must be submitted, by the dealer, to NRCan before the product is imported into Canada or traded inter-provincially for the first time.

Import report

A dealer who imports these products into Canada would include the following information on the customs release document:

  • name of product
  • model number
  • brand name
  • address of the dealer importing the product
  • purpose for which the product is being imported (i.e. for sale or lease in Canada without modification; for sale or lease in Canada after modification to comply with energy efficiency standards; or for use as a component in a product being exported from Canada)

Comments invited

The purpose of this bulletin is to provide stakeholders with the technical detail required to comment on the requirements under consideration for commercial water heating. 

NRCan requests any feedback concerning:

  • the UEF equivalencies calculated for residential-duty commercial gas- and oil-fired storage water heaters

Additional information on Canada’s Energy Efficiency Regulations including a current list of Standards Council of Canada accredited certification bodies can be found in the Department’s website.

We welcome your comments by September 7, 2017. All correspondence should be forwarded to:

Natural Resources Canada
Office of Energy Efficiency
580 Booth Street
Ottawa, ON, K1A 0E4
E-mail: nrcan.equipment.rncan@canada.ca