Attachment D – Consultations Over the past six years, E3 has liaised extensively with stakeholders regarding alignment to existing international energy efficiency and product testing standards. This work has focused on potentially aligning MEPS for refrigerators and freezers, currently at MEPS2, with those implemented by the US in September 2014, known as MEPS3. This work also includes potentially adopting the IEC test method for domestic refrigerators and freezers. Details concerning consultations relating to proposed changes outlined in this document are detailed below. Date Item Details Issues Raised Actions October 2011 Whitegoods Forum Melbourne Issues papers released E3 officials announced that Australia and New Zealand intended to align with US 2014 MEPS levels for refrigerators and freezers. Release of papers that set out technical aspects of the US regulatory requirements and the MEPS proposal. Paper 1 - MEPS for Household Refrigeration: Summary of new MEPS levels in the USA, October 2011 Paper 2 - MEPS for Household Refrigeration: Roadmap for MEPS 3 in Australia and New Zealand, October 2011 August 2012 Issues and discussion papers released Release of papers setting out more details of the proposal and E3 position paper. Paper 3 - Household Refrigeration: MEPS3 in Australia and New Zealand – Preliminary Impact Assessment of New MEPS Levels in 2015, August 2012 Paper 4 - Household Refrigeration: Technical Support Document on MEPS and Labelling for 2015 for Refrigeration Equipment, August 2012 Regulatory Discussion Document – Government agency proposed pathway to regulate refrigeration equipment sold to consumers in Australia and New Zealand from about April 2015, October 2012
March 2013 (cont.) Whitegoods Forum Officials sought stakeholder views on linking future MEPS for refrigerators and freezers to future MEPS changes within the US. Industry agreed that officials present E3 a consensus that refrigeration products regulation should be linked to US developments in the future Stakeholders sought more opportunities to input to future RIS processes Participants sought commitment from officials to have Australian representation at IEC refrigerator committee meetings by experts from our region Various technical issues were discussed Agreed by all parties to have both government and industry representation April 2013 Invitation for formal stakeholder submissions Submissions requested to support verbal positions from Whitegoods Forum. Three industry stakeholder submissions received: Electrolux Home Appliances Australia Fisher and Paykel Appliances Australian Industry Group (AIG) Submissions requested sufficient formal notice regarding regulatory changes – project milestones and project planning considered important so that industry can securely make large investments required to meet new MEPS levels Government requested to provide adequate resources to support proposed labelling transition – including adequate communication and marketing Cautious but not opposed to adoption of testing standard IEC62552 Supportive of a more realistic energy value on label Technical input received Technical Issues raised humidity testing analysis labelling algorithm May 2013 IEC released draft refrigerator test method for voting Draft voting open for three months Comments and votes closed on 16 August 2013 Australia submitted positive votes plus 74 written comments
July 2013 Stakeholder Workshop Six papers circulated: Paper 1 - Refrigerator and Freezer MEPS3 and IEC Migration Documentation (recap of documents to date) Paper 2 - IEC Migration Position Differences – CESA and AIG Paper 3 - AS/NZS 4474.2 (V0.5) – incorporating whitegoods forum discussions and industry submission from April 2013 Paper 3a - Summary of the edits undertaken on AS/NZS 4474.2 (V0.5) Paper 4 - Refrigerator Round Robin Testing – First Concept Draft Paper 5 - How does the energy efficiency of Australian whitegoods compare internationally? Paper 6 - Guide to undertaking tests to IEC SC59M/24/NP – Energy Consumption of Household Refrigerators Key task was to review part 2 Version 0.5 Review of draft of AS/NZS 4474.2:2015 Performance of household electrical appliances – Refrigerating appliances, Part 2 Consensus on most points Some issues on algorithms and load processing need further work Technical advisory group to consider Stakeholders agreed on value of round robin testing Supported by officials August 2013 Round robin of test laboratories commences Government sponsored laboratory testing of two specified model refrigerators to the IEC test standard Checked that requirements of the standards (both IEC and AS/NZS 4474 draft) were clear, unambiguous and not onerous Purpose of testing is to support adoption of IEC test method IEC62552 in Australia and New Zealand as well as preparing testing facilities to adapt to testing to support the new regulatory requirements in 2017 through the requirements of AS/NZS 4474.2 Six test laboratories contracted including two manufacturers’ laboratories (one in Australia and one in New Zealand) and four independent accredited laboratories in Australia Testing was conducted over the period August 2013 to January 2014 E3 prepared detailed technical comments about specific issues identified with the IEC standard aimed at making the test method more practical and workable
June 2015 Options paper released to whitegoods stakeholders Options paper outlining four potential algorithms that could use the IEC 62552 test standard when determining rating for ERL was circulated for consideration October 2014 FDIS released FDIS standards of IEC62552-1, IEC62552-2 and IEC625523 were released for vote None February 2015 IEC standard published IEC62552-1, IEC62552-2 and IEC62552-3 published Unanimous ‘Yes’ vote from National Committees August 2015 Whitegoods stakeholder meeting Discussion of algorithm options outlined in June 2015 General stakeholder consensus on the preferred algorithm option that has been included in this RIS November 2016 Stakeholder Meetings Discussions on capital and other costs and assumptions used in modelling April 2017 Consultation RIS released Six week public consultation period Issues summarised in May-June 2017 Public consultation meetings RIS overview presented RIS modelling assumptions presented Question and answer session August 2017 RIS Issues Meeting RIS Issues Discussion Paper circulated to stakeholders Discussed issues raised by stakeholders in consultation RIS submissions Suppliers unanimously supported adoption of IEC62552 Suppliers unanimously supported adoption of MEPS3 levels E3 confirmed it would continue to work with stakeholders to resolve issues via:
Ahead of mandated MEPS3 levels commencing, do stakeholders support proposed provisions to allow the registration of MEPS3-compliant products using the IEC test method and the new algorithm. Do stakeholders support proposed changes to the ERL design? If not then please outline what would be a preferable design. Do stakeholders agree with the proposed timing for the introduction of MEPS3? If not, please advise of alternative timing with detailed, supporting rationale. Table 34 provides a summary of public submissions that are accessible online on the website. Table 34: Summary of Stakeholder Submissions Choice CESA F&P Electrolux Ai Group Sharp NZ 1. Support status quo? N N N N - - 2. Pros and cons of incorporating contents of AS/NZS 4474.1 into Determination Regulations updated less frequently than standards 1. No advantage in change 2. Determination format not appropriate for technical content 3. Standards processes are consensus based that include public comment 1. Determinations written in a very legalistic way making them very difficult to understand 2. A standard represents consensus on a wide range of issues and is written in a language that engineers and technicians understand 3. Determinations lead to a mismatch between Australian and New Zealand regulations 1. Standards Australia have a proven, consensus based process for providing effective MEPS and energy efficiency labelling requirements 2. Standards process is an appropriate approach for drafting complex technical requirements in which expert opinion is required and is publically scrutinised Need to maintain processes equivalent to those currently used in standards processes including a consensus based approach 1. The standards or the Determination should be created as a standalone document written in easily understood English 2. The Determination should not be accepted until it has been formally accepted at an industry meeting and/or emailed to interested stakeholders 3. Support Determination or standards approach Standards Standards Standards Standards Standards - 4. Support Option B? Y N - - - -
Other Comments 1) Streamline registration process to only require information that confirms compliance with GEMS requirements 2) Need to use up-to-date price coefficients and sales data for the decision RIS modelling 3) Need to provide basis for 15 year refrigerator lifetime assumption 4) Modelling has not included sensitivity analysis of electricity prices nor product lifetimes 5) Regulator should consider automatic recognition of registered products that meet MEPS3 6) Need to include 'other beverage coolers' in exclusions 7) Multiple tests are required to understand product variability 8) Support retaining pulldown test 9) Need to define defrost temperature excursions as in AS/NZS 4474.1 Clause 3.7.3 10) Define volume tolerances 11) Review check testing tolerances 12) Repeatability/accuracy of the load processing test questioned 1) Load processing test is not sufficiently mature to be used: results variable; refrigerator defrost unpredictable; freezer results also variable; IEC does not cover how to deal with defrost during load processing; allowing different set points may provide gaming opportunity. Exclude load processing for ERL until issues resolved. 2) 16C test results are too variable. Suggest using a fixed ‘average’ figure as a placeholder 3) Consider defining adjustment factor for defrost at 230v cw 220v 4) Checktest tolerance needs to be reviewed 5) Support retaining pulldown test 1) Do not support load processing test 2) Maintain requirement for test report for three appliances 3) Revise CBA for higher testing and development costs 4) Exclude beverage coolers 5) Define parameters enabling voluntary wine cabinet labelling 6) Use recent sales data in decision RIS 7) Revise RIS to reflect that retail prices do not correlate with energy efficiency but high efficiency products cost more to produce 8) Confirm MEPS levels during the development of the decision RIS 9) Support retaining pulldown test - 1) Regardless whether a standard or determination approach is adopted, the document should be stand alone and not reference other standards or documents and be written in easily understood English 2) The Determination should not be accepted until it has been formally accepted at an industry meeting and/or emailed to interested stakeholders 3) Stakeholders should have a timeline in which they can "Return for rewrite" until it is deemed accepted