Organisation: INFORSE-Europe and ECOS Name: Gunnar Boye Olesen and Stamatis Sivitos Date: May 4, 2012 ENER Lot 20: Local room heating products Document Section in Page Topic Comment Proposed change comment document number relates to Room heaters are converting a large share of All n.a. n.a. General See following proposals 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 Task 5 5.1.4 14ff Energy Efficiency calculations for room heaters are efficiency of room heaters in the preparatory report and Consumption changed to seasonal efficiencies for all studies are not based on a seasonal following calculation products covered (all base cases). The method efficiency and are not harmonised among the must include the effects of controls including base cases with a similar function (such as different thermostats. residential space heating ). The lack of a coherent and adequate methodology Where test and calculation standards are not in weakens the identification of improvement place for seasonal efficiency (including options and comparison of the different room load testing), the preparatory study shall heating technologies. We therefore propose highlight the missing standards and propose to use seasonal efficiency for the transitional measures until standards can be in
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 Comment Proposed change All n.a. n.a. General 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. See following proposals Task 5 report and following 5.1.4 14ff Energy Consumption calculation 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 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 testing), the preparatory study shall highlight the missing standards and propose transitional measures until standards can be in load
BIO_Eup_ENER_Lot_20_stakeholder_comments_final-INFORSE-ECOS.docx