Transitionto)low Aemission HVAC&R:(Issues(andsolutions · 2016. 9. 17. · Claim!thesustainabilityspace!!!! TransitiontolowAemission)HVAC&R:)Issues)and)solutions)|March)2013) Page5!of!162!

Transition to low emission HVAC&R: Issues and solutions| March 2013

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Discussion paper

Transition to low-‐emission HVAC&R: Issues and solutions

Prepared by:

The Australian Institute of Refrigeration Air Conditioning and Heating

AIRAH Strategic aim #1 -‐ Claim the sustainability space

March 2013

Claim the sustainability space

Transition to low-‐emission HVAC&R: Issues and solutions | March 2013

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Prepared and Co-‐ordinated by

Vincent Aherne M.AIRAH

Australian Institute of Refrigeration Air Conditioning and Heating (AIRAH)

Level 3/1 Elizabeth Street, Melbourne, VIC 3000

Tel: 03 8623 3000 | www.airah.org.au | email: [email protected]

About AIRAH

AIRAH is the recognised voice of the Australian air conditioning, refrigeration and heating industry. We aim to minimise the environmental footprint of our vital sector through communication, education and encouraging best practice.

AIRAH – Strategic Aims

Claim the sustainability space Through its conferences, publications, manuals and training, AIRAH will educate and motivate the HVAC&R industry and related fields about achieving sustainability. Many organisations talk about sustainability as a concept. Our aim is to be the HVAC&R organisation whose values are aligned with sustainability in a practical sense

Close the skills gaps At a time of rapid change of new technology and standards and a shifting regulatory landscape, AIRAH will provide appropriate and relevant professional development for HVAC&R industry personnel, and work alongside government and other providers to ensure the voids, where they exist in formal training, are filled.

Inform regulation and policy decisions As the key industry organisation representing HVAC&R in Australia, it is essential AIRAH collaborate with government at both the state and federal levels. In this way the collective skills and specialist knowledge contained with the Institute can better inform the decisions that affect society in general and the HVAC&R industry in particular. Build and engage membership AIRAH will become the institute of choice for HVAC&R professionals in Australia. This means ensuring that formal connection with AIRAH provides benefits – actual and intangible – that are valuable, worthwhile and attractive to our members throughout their professional lives.



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Disclaimer

Information contained in this discussion paper may be copied or reproduced for study, research, information or educational purposes, subject to inclusion of an acknowledgment of the source.

While reasonable efforts have been made to ensure that as many opinions and solutions have been canvassed AIRAH does not accept responsibility for the accuracy or completeness of the contents, and shall not be liable for any loss or damage that may be occasioned directly or indirectly through the use of, or reliance on, the contents of this publication.

© AIRAH 2013



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Acknowledgements

AIRAH has not completed this work alone. All relevant government, industry, education and end-‐user stakeholders in Australia were identified and invited to contribute to the discussion paper. AIRAH also engaged via its international networks such as the United Nations Environment Program (UNEP); International Institute of Refrigeration (IIR); American Society of Heating, Refrigeration and Air conditioning engineers (ASHRAE). Refer to Appendix A for the full list of stakeholders and supporters. AIRAH would like to specifically thank the following people and organisations who have contributed to the development of this discussion paper at one or more stages:

Vince Aherne, M.AIRAH – AIRAH Dr Ghulam Q. Amur – NSW Department of Premier and Cabinet -‐ Office of Environment and Heritage Steve Anderson – Refrigerants Australia, AREMA Steve Atherton, M.AIRAH – Air Change Australia Greg Atkinson, M.AIRAH – Tri Tech Refrigeration Australia Maria Atkinson – XOCO Bruce Badger – International Institute of Ammonia Refrigeration Leigh Baker – Balance3

Dr Paul Bannister, M.AIRAH – Exergy Australia Michael Bennett – Refrigerant Reclaim Australia Graham Boyle, M.AIRAH – Polytechnic West Martin Bruekers, M.AIRAH – Department of Lands, Planning and Environment, NT Shane Carmichael, M.AIRAH – Air Change Australia Graham Carter, M.AIRAH – Lend lease Prof. Florea Chiriac– Romanian Association for Refrigeration and Cryogenics Mark Christoffersen – Gordon Brothers Industries John W Clark – HyChill Australia Don Cleland, HM.AIRAH – Massey University, NZ Neil Cox – AIRAH David Crossley – Australian Industry Group Jonathan Dalton – Viridis

Carolyn Davis -‐ Australian Chamber of Commerce and Industry Michael Deru – National Renewable Energy Laboratory (USA) Cornelis De Groot – Gas Technical Regulators Council Frouke de Reuver – NSW Department of Premier and Cabinet -‐ Office of Environment and Heritage Sven Denton , M.AIRAH – AquaKlar Analytical Services Sabina Douglas-‐Hill – DMITRE, SA Glenne Drover – Department of Business and Innovation, Victoria Rick Duynhoven – TAFE NSW – Sydney Institute Tim Edwards – Australian Refrigeration Association Jay Eldridge – Daikin McQuay (USA) Kim Fare – National Occupational Licensing Authority Kylie Farrelley – Arkema Phillip Farrell – City West Water John Fawcett – City West Water Dario Ferlin – Woolworths Jonathon Fryer, M.AIRAH – ISECO Engineering Services Fred Glavimans, M.AIRAH – King Air Paul Graham, M.AIRAH – Paul Graham and associates Sean Hanrahan – City West Water Gerard Healey, Affil.AIRAH – ARUP



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Mark Henderson, M.AIRAH – SEiD Dr Dominique Hes, M.AIRAH – University of Melbourne Gabor Hilton, M.AIRAH – Refrigerated Warehouse & Transport Association of Australia Simon Ho, M.AIRAH – Ingersoll Rand Climate Solutions Jessica Holz, M.AIRAH – Umow Lai Noel Irwin – Moreland City Council Des Jackson, M.AIRAH – Ergon Energy Stefan Jensen, F.AIRAH – Scantec Refrigeration Peter Kikos – MPMSAA Peter Kinsella – AE Smith Shayne La Combre – Plumbing Industry Climate Action Centre Lasath Lecamwasam, M.AIRAH – GHD Kevin Lee, M.AIRAH – Heatcraft Australia Dan Linsell – CSIRO Jürgen M Lobert – Entegris (USA) Terry Mahoney – Australian Institute for Building Performance Research Carolyn Marshall – Building Research and Technical Services, Department of Finance WA Michael McCann – Thinkwell Mark M MacCracken – CALMAC Manufacturing Corporation (USA) Ian McNicol – Sustainability Victoria Mark Mitchell – VASA Kevin Moon, M.AIRAH – Luxira Richard Mulcahy, M.AIRAH – AUSVEG Noel Munkman – E-‐Oz Energy Skills Australia Ashak Nathwani – The University of Sydney Stuart Nesbitt – Moreland City Council Angeline Nicholas – Supplier Advocates Program, DIISRTE Sumit Oberoi – Air Conditioning and Mechanical Contractors' Association Alan Obrart, M.AIRAH – Obrart and Co Graham Palmer – Australian Duct Manufacturer's Alliance

David Parken – Australian Institute of Architects Bob Paton – Manufacturing Skills Australia (MSA) Ian Paul – RACCA Alan Pears – Consultant Bryon Price, M.AIRAH – A G Coombs Amir Radfar – United Nations Environment Program Brian Rees – McAlpine Hussmann Louise Rhodes – Metcash Trading Monica Richter – Australian Conservation Foundation Craig Roussac – Buildings Alive Keith Sanders – Pump Industry Australia Neil Sheehan, M.AIRAH – DMITRE, SA Tina Shilleto – Reform & Legislative Services Building Codes Queensland Robin Shreeve – Australian Workforce and Productivity Agency R.V.Simha – HVAC Consultant, India Belinda Strickland – Australian Institute of Architects -‐ Victorian Chapter Roger Stringer, Ass.AIRAH – Actrol Ken Thomson, M.AIRAH – Crone Partners Thinh Tran – Plumbing Industry Commission Tristram Travers -‐ Enterprise Connect, DIISRTE Matthew Trigg – Facility Management Association of Australia Ian Tuena, M.AIRAH – CA group services Jason Van Ballegooyen – DIISRTE Sietze van der Sluis – IEA Heat Pump Centre Ché Wall – XOCO Dr Josh Wall, M.AIRAH – CSIRO Lyndon Watson – Don Watson Transport & Coldstores Dr Stephen White, M.AIRAH – CSIRO Peter Whittle – City of Yarra Jock Wigan – ALDI Stores Phil Wilkinson, M.AIRAH – AIRAH Robert Wilson – Ergon Energy Paul Wiszniak – Wattwatcher



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TRANSITION TO LOW-‐EMISSION HVAC&R

ISSUES AND SOLUTIONS

TABLE OF CONTENTS EXECUTIVE SUMMARY ................................................................................................................. 14

1 -‐ SCOPE ...................................................................................................................................... 19 1.1. INTRODUCTION .......................................................................................................................... 19 1.2. NEED ....................................................................................................................................... 19 1.3. PURPOSE .................................................................................................................................. 21 1.4. PROJECT OBJECTIVES .................................................................................................................. 21 1.5. APPROACH ............................................................................................................................... 22 1.5.1. Consultation process ...................................................................................................... 22 1.5.2. Structure of the paper .................................................................................................... 22 1.5.3. Assessment of solutions ................................................................................................. 23

2. INDUSTRY CONTEXT .............................................................................................................. 24 2.1. THE HVAC&R INDUSTRY ............................................................................................................ 24 2.2. PUBLIC PERCEPTION ................................................................................................................... 24 2.3. REGULATORY ENVIRONMENT ....................................................................................................... 25 2.4. GOVERNMENT POLICY, ENERGY EFFICIENCY AND HVAC&R ............................................................... 25 2.4.1. National Construction Code (NCC) ................................................................................. 26 2.4.2. HVAC HESS ..................................................................................................................... 26 2.4.3. Refrigeration – In from the Cold ..................................................................................... 27 2.4.4. Minimum Energy Performance Standards (MEPS) ......................................................... 27 2.4.5. Energy rating labels ........................................................................................................ 28 2.4.6. Other government energy efficiency policy drivers ........................................................ 28

2.5. GOVERNMENT INCENTIVES .......................................................................................................... 29 2.6. SPLIT INCENTIVES ....................................................................................................................... 30 2.7. FINANCING ENERGY-‐EFFICIENCY INTERVENTIONS .............................................................................. 30 2.7.1. Financing interventions .................................................................................................. 30 2.7.2. Quantifying costs and benefits ....................................................................................... 31 2.7.3. CTIP funding ................................................................................................................... 31

2.8. GREEN BUILDING ....................................................................................................................... 31



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2.9. COMMERCIAL LEASING ................................................................................................................ 32 2.10. PASSIVE DESIGN ....................................................................................................................... 32 2.11. THE NEED FOR HVAC&R .......................................................................................................... 33 2.12. INTEGRATING HVAC&R DESIGN INTO THE BUILDING DESIGN PROCESS .............................................. 34 2.13. CONTRACTS ............................................................................................................................ 34 2.14. HVAC&R DESIGN CONDITIONS .................................................................................................. 35 2.15. DESIGN AND CONTROL STRATEGIES ............................................................................................. 35 2.16. SYSTEM AND BUILDING COMMISSIONING ..................................................................................... 36 2.17. BUILDING MANAGEMENT AND CONTROL SYSTEMS ......................................................................... 36 2.18. BUILDING INFORMATION MODELLING/MANAGEMENT .................................................................... 37 2.19. INTERNATIONAL DEVELOPMENTS IN REFRIGERATION ....................................................................... 37 2.19.1. Refrigerant leakage ..................................................................................................... 38 2.19.2. HFC Bans/Restrictions .................................................................................................. 38 2.19.3. Tools ............................................................................................................................. 38 2.19.4. Refrigerant and equipment manufacture .................................................................... 38

2.20. ENERGY PRICES AND PRICING POLICY ........................................................................................... 39 2.21. CARBON INTENSITY OF THE “GRID” ............................................................................................. 40 2.22. HVAC&R INTERACTIONS WITH THE “GRID” .................................................................................. 41 2.22.1. Demand management ................................................................................................. 41 2.22.2. Co-‐generation and tri-‐generation systems .................................................................. 41 2.22.3. Energy storage ............................................................................................................. 42 2.22.4. Phase-‐change materials ............................................................................................... 42 2.22.5. Alternative technologies .............................................................................................. 42

3. THE HEADLINE ISSUES ............................................................................................................ 44 3.1. SECTION INTRODUCTION ............................................................................................................. 44 3.2. REFRIGERATION SAFETY ISSUES ..................................................................................................... 44 3.2.1. Refrigerant classification ................................................................................................ 44 3.2.2. Design safety standard ................................................................................................... 45 3.2.3. Product standards .......................................................................................................... 46 3.2.4. Gas regulations .............................................................................................................. 46 3.2.5. Industry Code of Practice ............................................................................................... 46 3.2.6. Refrigerant trade-‐offs .................................................................................................... 47

3.3. ENVIRONMENTAL ISSUES ............................................................................................................. 47 3.3.1. Emissions versus energy efficiency ................................................................................. 47 3.3.2. Energy efficiency versus energy consumption ................................................................ 48 3.3.3. ODP versus GWP ............................................................................................................ 48 3.3.4. Environmental degradation/impact ............................................................................... 48 3.3.5. Environmental performance .......................................................................................... 49

3.4. ENERGY EFFICIENCY DESIGN ISSUES ................................................................................................ 50 3.4.1. Energy intensity .............................................................................................................. 50 3.4.2. Rating ............................................................................................................................. 50 3.4.3. System capacity .............................................................................................................. 51



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3.4.4. System design ................................................................................................................. 52 3.4.5. Heat rejection ................................................................................................................. 52 3.4.6. Heat recovery ................................................................................................................. 53 3.4.7. System installation ......................................................................................................... 54 3.4.8. Infiltration and building sealing ..................................................................................... 54

3.5. ENERGY EFFICIENCY OPERATIONAL ISSUES ....................................................................................... 54 3.5.1. Operation ....................................................................................................................... 54 3.5.2. System control ................................................................................................................ 55 3.5.3. System documentation ................................................................................................... 55 3.5.4. Monitoring ..................................................................................................................... 56 3.5.5. Maintenance .................................................................................................................. 56 3.5.6. Upgrade or replacement ................................................................................................ 58

3.6. LOW-‐GWP REFRIGERANTS .......................................................................................................... 59 3.6.1. What are low-‐GWP refrigerants .................................................................................... 59 3.6.2. Barriers to low-‐GWP refrigerants ................................................................................... 59

3.7. REFRIGERANT CONTAINMENT ISSUES ............................................................................................. 60 3.7.1. Construction standards .................................................................................................. 61 3.7.2. Leak-‐containment technologies ..................................................................................... 62 3.7.3. Leak-‐management practices .......................................................................................... 63 3.7.4. Automatic leak detection ............................................................................................... 63 3.7.5. Charge reduction ............................................................................................................ 64 3.7.6. Tracking refrigerant emissions ....................................................................................... 64

3.8. PRODUCT STEWARDSHIP ............................................................................................................. 64 3.8.1. Refrigerants .................................................................................................................... 64 3.8.2. Plant and equipment ...................................................................................................... 66

3.9. RESEARCH, DEVELOPMENT, INNOVATION AND COMMERCIALISATION ................................................... 66 3.10. WORKFORCE DEVELOPMENT ...................................................................................................... 66 3.11. SKILLS AND TRAINING ISSUES ...................................................................................................... 67 3.11.1. University training ........................................................................................................ 68 3.11.2. VET/TAFE trade training .............................................................................................. 68 3.11.3. Continuing professional development/skills maintenance .......................................... 70 3.11.4. Design training ............................................................................................................. 70 3.11.5. Energy efficiency training ............................................................................................. 71 3.11.6. Installation training ...................................................................................................... 71 3.11.7. Commissioning training ............................................................................................... 71 3.11.8. Operational training .................................................................................................... 72 3.11.9. Maintenance training .................................................................................................. 72 3.11.10. Decommissioning ....................................................................................................... 72 3.11.11. Current developments in skills and training ............................................................... 72

3.12. LICENSING AND REGISTRATION ................................................................................................... 73 3.12.1. Technician licensing ..................................................................................................... 73 3.12.2. Professional registration .............................................................................................. 74



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4. THE MAJOR SECTORS ............................................................................................................. 75 4.1. SECTION INTRODUCTION ............................................................................................................. 75 4.2. COMMERCIAL AIR CONDITIONING ................................................................................................. 75 4.2.1. Energy intensity .............................................................................................................. 75 4.2.2. Energy efficiency ............................................................................................................ 76 4.2.3. Refrigerant leakage ........................................................................................................ 77 4.2.4. Maintenance .................................................................................................................. 77 4.2.5. Building tuning, recommissioning and retrocommissioning .......................................... 77 4.2.6. Fault detection and diagnostics (FDD) ........................................................................... 78

4.3. RESIDENTIAL AIR CONDITIONING ................................................................................................... 79 4.3.1. Energy intensity .............................................................................................................. 79 4.3.2. Energy efficiency ............................................................................................................ 80 4.3.3. Operation ....................................................................................................................... 81 4.3.4. Refrigerant leakage ........................................................................................................ 81 4.3.5. Maintenance .................................................................................................................. 81 4.3.6. Low-‐GWP refrigerants .................................................................................................... 82 4.3.7. Training and licensing .................................................................................................... 82 4.3.8. Strata title residential buildings ..................................................................................... 82

4.4. VEHICLE AIR CONDITIONING ......................................................................................................... 82 4.4.1. Design safety standards ................................................................................................. 84 4.4.2. Energy intensity .............................................................................................................. 84 4.4.3. Energy efficiency ............................................................................................................ 84 4.4.4. Refrigerant leakage ........................................................................................................ 84 4.4.5. Maintenance .................................................................................................................. 85

4.5. COMMERCIAL REFRIGERATION ...................................................................................................... 85 4.5.1. Supermarket and displays .............................................................................................. 85 4.5.2. Low-‐GWP refrigerant solutions ...................................................................................... 87 4.5.3. The total-‐system approach to design ............................................................................. 87 4.5.4. Refrigerated warehouse/storage facilities ..................................................................... 88 4.5.5. Cold rooms/freezer rooms .............................................................................................. 91

4.6. INDUSTRIAL REFRIGERATION ......................................................................................................... 92 4.7. REFRIGERATED TRANSPORT .......................................................................................................... 94 4.7.1. Refrigerant ..................................................................................................................... 94 4.7.2. Energy intensity .............................................................................................................. 95

4.8. OTHER SECTORS ......................................................................................................................... 96 4.8.1. Residential refrigeration ................................................................................................. 96 4.8.2. H is for Heating .............................................................................................................. 97 4.8.3. Hot water heat pumps ................................................................................................... 98

5. PROPOSED SOLUTIONS .......................................................................................................... 99 5.1. SECTION INTRODUCTION ............................................................................................................. 99 5.2. PROFESSIONALISM ..................................................................................................................... 99 5.2.1. An HVAC&R industry council .......................................................................................... 99



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5.2.2. Objectives of low-‐emission HVAC&R Roadmap .............................................................. 99 5.2.3. Funding and resources ................................................................................................. 100 5.2.4. Industry data ................................................................................................................ 101 5.2.5. Sharing data and collaboration .................................................................................... 102 5.2.6. International experience .............................................................................................. 102 5.2.7. Low-‐emission HVAC&R defined .................................................................................... 102 5.2.8. Fee structures ............................................................................................................... 103 5.2.9. Design engagement and feedback ............................................................................... 103 5.2.10. Trade training ............................................................................................................ 103 5.2.11. University training ...................................................................................................... 105 5.2.12. CPD training ............................................................................................................... 106 5.2.13. Trade licensing ........................................................................................................... 106 5.2.14. Professional registration ............................................................................................ 106

5.3. REGULATIONS, STANDARDS AND GOVERNMENT PROGRAMS ............................................................ 107 5.3.1. Measuring success ....................................................................................................... 107 5.3.2. Intellectual property ..................................................................................................... 107 5.3.3. National Construction Code ......................................................................................... 107 5.3.4. Mandatory commissioning ........................................................................................... 108 5.3.5. Mandatory submetering and monitoring ..................................................................... 108 5.3.6. Mandatory energy efficiency maintenance .................................................................. 108 5.3.7. Building air tightness .................................................................................................... 108 5.3.8. Upgrades and minor works .......................................................................................... 109 5.3.9. Documentation standards ............................................................................................ 109 5.3.10. Facilities for maintenance .......................................................................................... 110 5.3.11. CTIP finance ............................................................................................................... 110 5.3.12. Refrigeration safety standards ................................................................................... 110 5.3.13. CoP for flammable refrigerants .................................................................................. 111 5.3.14. CoP for HFC refrigerants ............................................................................................ 111 5.3.15. Refrigerant handling .................................................................................................. 112 5.3.16. System age ................................................................................................................. 112 5.3.17. Government programs – MEPS .................................................................................. 112 5.3.18. Government programs – HVAC HESS ......................................................................... 113 5.3.19. Government programs – In from the Cold ................................................................. 113 5.3.20. Government programs – Mandatory disclosure ........................................................ 114 5.3.21. Government programs – NGER scheme ..................................................................... 114 5.3.22. HVAC&R design standards ......................................................................................... 114 5.3.23. Cool/Cold rooms design standard .............................................................................. 115 5.3.24. Commercial HVAC&R demand management ............................................................. 115 5.3.25. Residential air conditioning design and installation standard ................................... 115 5.3.26. Residential air conditioning demand management ................................................... 115

5.4. INFORMATION ......................................................................................................................... 115 5.4.1. Industry information and online repository .................................................................. 115



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5.4.2. The value of HVAC&R ................................................................................................... 116 5.4.3. Grants and incentives ................................................................................................... 116 5.4.4. Fee structures ............................................................................................................... 116 5.4.5. HVAC&R design data .................................................................................................... 117 5.4.6. Internal design/comfort conditions .............................................................................. 117 5.4.7. Air-‐cooled/water-‐cooled cost analysis ......................................................................... 118 5.4.8. Commercial refrigeration design approach .................................................................. 118 5.4.9. Co-‐generation/Tri-‐generation ...................................................................................... 118 5.4.10. Alternative technologies and practices ...................................................................... 119 5.4.11. CPD training ............................................................................................................... 119 5.4.12. End user information and awareness ........................................................................ 121 5.4.13. myHVAC&Rsystem.com.au ........................................................................................ 122 5.4.14. Natural refrigerants ................................................................................................... 122 5.4.15. Ammonia refrigerants ................................................................................................ 123 5.4.16. Passive design ............................................................................................................ 123 5.4.17. Best-‐practice HVAC&R installation ............................................................................ 123 5.4.18. Building tuning and recommissioning ........................................................................ 124 5.4.19. Commercial refrigeration ........................................................................................... 124 5.4.20. System age ................................................................................................................. 124 5.4.21. Optimising and maintaining efficiency ...................................................................... 124 5.4.22. Maintenance for energy efficiency ............................................................................. 124 5.4.23. Residential air conditioning design and installation standard ................................... 126 5.4.24. Residential air conditioning demand management ................................................... 126 5.4.25. Residential maintenance ............................................................................................ 126

5.5. MEASUREMENT ....................................................................................................................... 126 5.5.1. HVAC system rating ...................................................................................................... 126 5.5.2. Refrigeration system rating .......................................................................................... 127 5.5.3. Water rating ................................................................................................................. 128 5.5.4. Validation of product claims ........................................................................................ 128 5.5.5. Technology comparison tool ........................................................................................ 128 5.5.6. Benchmarking existing systems ................................................................................... 129 5.5.7. Metering and monitoring ............................................................................................. 129 5.5.8. Maintenance records ................................................................................................... 130 5.5.9. Fault detection and diagnosis ...................................................................................... 130 5.5.10. Cool/cold rooms design standard .............................................................................. 130 5.5.11. Benchmarking electricity use ..................................................................................... 131 5.5.12. Managing consumption ............................................................................................. 131

5.6. EMISSION ABATEMENT .............................................................................................................. 131 5.6.1. Product stewardship .................................................................................................... 131 5.6.2. Quality/design assurance ............................................................................................. 132 5.6.3. Research, development, innovation and commercialisation ........................................ 132 5.6.4. Innovation showcase .................................................................................................... 133



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5.6.5. Incentive schemes/trials for new technologies ............................................................ 133 5.6.6. Targeting implementation of innovative technologies ................................................ 134 5.6.7. Government procurement ............................................................................................ 134 5.6.8. Commercial refrigeration design approach .................................................................. 134 5.6.9. Best-‐practice HVAC&R installation ............................................................................... 135 5.6.10. Commissioning Guarantee scheme ............................................................................ 135 5.6.11. Residential air conditioning design and installation register ..................................... 135 5.6.12. Residential installers guarantee scheme .................................................................... 135 5.6.13. Co-‐generation/tri-‐generation .................................................................................... 135 5.6.14. Commercial refrigeration ........................................................................................... 136 5.6.15. Existing systems in existing buildings ......................................................................... 136 5.6.16. Incentivising energy-‐efficiency interventions in existing buildings ............................. 137 5.6.17. Incentives for commercial maintenance .................................................................... 137 5.6.18. Residential Maintenance ........................................................................................... 137 5.6.19. Incentives for replacing inefficient residential systems .............................................. 137 5.6.20. Direct refrigerant leakage .......................................................................................... 138 5.6.21. Leakage monitoring ................................................................................................... 139 5.6.22. Leakage testing .......................................................................................................... 139 5.6.23. Refrigerant containment ............................................................................................ 139 5.6.24. Maintenance for leak minimisation ........................................................................... 140 5.6.25. Refrigerant logging .................................................................................................... 140 5.6.26. Refrigerant reclamation and recycling ....................................................................... 140 5.6.27. Refrigerant leakage ................................................................................................... 141 5.6.28. End-‐of-‐lifeleakage ...................................................................................................... 141 5.6.29. Commercial leasing .................................................................................................... 141 5.6.30. Evaporative air cooling .............................................................................................. 142 5.6.31. Hot water heat pumps ............................................................................................... 142 5.6.32. Residential refrigeration upgrade and replacement .................................................. 142

5.7. OTHER SECTOR SOLUTIONS NOT INCLUDED IN THE ROADMAP ........................................................... 142 5.7.1. Vehicle air conditioning ................................................................................................ 142 5.7.2. Transport refrigeration ................................................................................................ 143

5.8. COMPLEMENTARY ACTIONS ....................................................................................................... 143 5.8.1. Workforce development ............................................................................................... 143 5.8.2. The Clean Technologies Supplier Advocate .................................................................. 143 5.8.3. Building information modelling .................................................................................... 144 5.8.4. Harmonisation .............................................................................................................. 144

6. MANAGING THE TRANSITION .............................................................................................. 146 6.1. WORKING WITH GOVERNMENT/ INDUSTRY STAKEHOLDERS ............................................................. 146 6.2. CURRENT TOOLS ...................................................................................................................... 146 6.3. PSYCHOLOGICAL AND SOCIOLOGICAL FACTORS .............................................................................. 146 6.4. CHANGING ENTRENCHED INDUSTRY ATTITUDES ............................................................................. 147 6.5. LESSONS LEARNED FROM OVERSEAS EXPERIENCES .......................................................................... 147



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6.6. OPPORTUNITIES FOR THE HVAC&R INDUSTRY .............................................................................. 147 6.6.1. Low-‐carbon consultants ............................................................................................... 147 6.6.2. Maintenance for energy efficiency ............................................................................... 148 6.6.3. Maintenance for leak minimisation ............................................................................. 148 6.6.4. System upgrades for energy efficiency ......................................................................... 148 6.6.5. System retrofitting for low-‐GWP refrigerants .............................................................. 148 6.6.6. Identifying incentives and finance opportunities ......................................................... 148

6.7. DEMAND AND SUPPLY AND DEMAND ........................................................................................... 148 6.8. INTELLECTUAL PROPERTY AND KNOWLEDGE TRANSFER .................................................................... 149 6.9. SMALL AND MEDIUM ENTERPRISES SMES ..................................................................................... 149 6.9.1. SME end users .............................................................................................................. 149 6.9.2. SME technical service providers ................................................................................... 150

7. INDUSTRY TRANSITION ACTION ROADMAPS ....................................................................... 151 7.1. SECTION INTRODUCTION ........................................................................................................... 151 7.2. ROADMAP .............................................................................................................................. 152 7.3. PROFESSIONALISM SOLUTIONS ................................................................................................... 153 7.4. REGULATORY SOLUTIONS ........................................................................................................... 154 7.5. INFORMATION SOLUTIONS ......................................................................................................... 155 7.6. MEASUREMENT SOLUTIONS ....................................................................................................... 156 7.7. EMISSION REDUCTION SOLUTIONS ............................................................................................... 157 7.8. COMPLEMENTARY SOLUTIONS .................................................................................................... 158



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EXECUTIVE SUMMARY AIRAH undertook this project on behalf of the whole of industry to provide a forum or mechanism whereby the transition to low-‐emission HVAC&R practices and technologies could be discussed openly and transparently. The topic is broad and the views are varied and often conflicting. The content of this paper is based on submissions received from industry stakeholders. Hence, many statements and conclusions are not referenced to published documents. This is neither a research paper nor a definitive situational analysis; this paper simply documents an industry discussion.

Some criticisms have suggested the industry cannot have this discussion until all of the data relating to the situation is defined and known. However, others have noted the idiom, “When is the best time to plant a commercial forest? Twenty years ago. But if you haven't done it yet: now!”

In a way the industry is trying to rebuild or modify the aeroplane while flying it – not an ideal situation but really the only practical approach, particularly if the aeroplane is not allowed to land.

Another criticism is that the project is very large – too large – and the scope needs to be reduced, and the project broken down into much smaller steps. Again an idiom is offered, “How do you eat an elephant? One bite at a time.” That has been the approach taken by AIRAH: one step at a time.

The AIRAH-‐proposed roadmap consists of five pillars underpinning the transition: Professionalism, Regulation, Information, Measurement, and Emission abatement (PRIME). Each represents a different pathway, and all of the eventual industry-‐endorsed solutions can be listed in one of those categories.

The pathways that have emerged are presented as follows:

Professionalism – The things that help to set the industry objectives and process for transition, including funding and engagement; strategy and policy; compiling and sharing data; and professionalising the industry through skills, training, licensing and registration.

Regulating – The things that relate to helping the HVAC&R industry to inform government policy and regulations, industry Codes, Australian Standards, and government programs.

Information – The things that relate to the information that can be provided to educate and inform end users and technical service providers about skills relating to energy efficiency and reducing emissions, knowledge, technologies, fee structures, design practices, and maintenance imperatives.

Measurement – The things that relate to helping industry and end users monitor, measure, rate, and benchmark HVAC&R performance, validate efficiency claims, and compare technology solutions,

Emission abatement – The practical things that are done to reduce emissions. These include product stewardship, incentives for new technology and innovation, system procurement, good/best-‐ practice accreditation, incentivising low-‐emission interventions, maintenance for energy efficiency, and refrigerant containment.



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All of these pathways and many of the proposed solutions are interrelated. Some will only be possible if others are accepted.

PRIME: One of the meanings of the word “prime” is to prepare, to get ready, to brief, to train and

to prepare something for operation. It is also used to designate importance. In the context of the industry roadmap the word “prime” seems an appropriate term to use. PRIME means putting in the right effort and groundwork before you start to ensure you get a good outcome.

Therefore the Draft HVAC&R Industry Roadmap looks something like this:

DRAFT ROADMAP – Transition to low-‐emission HVAC&R

Overall objective or

Vision A highly skilled and professional Australian HVAC&R industry that is safe, cost-‐effective and environmentally effective.

Pathways – to low-‐emission HVAC&R

Professionalism Skills and training, licensing, professional registration, tertiary education and an industry council or forum to consider strategy, policy, information sharing, and industry practices.

Regulating Inform government policy and regulations, industry Codes and Australian Standards, including validation, regulatory data, and enforcement.

Information Educate and inform end users, disseminate low-‐emission skills and knowledge, technologies, design practices, convert data to information.

Measurement Measure and benchmark HVAC&R performance using system rating tools, industry metrics, building tuning, system optimisation, validated efficiency claims, and technology-‐comparison tools.

Emission abatement Product stewardship, new technologies, work-‐practice accreditation, incentivising low-‐emission interventions, maintenance for energy efficiency, and refrigerant containment.



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This discussion paper is a report on the industry views on low-‐emission HVAC&R, at least to the extent that AIRAH has been able to define them. The paper has been developed as an open-‐source document, with extensive consultation with industry stakeholders, including government and end users.

At each iteration invitations were sent out to comment and provide feedback about the draft document. AIRAH thanks the authors – the many individuals and organisations that have been able to participate in this process.

The primary purpose is to facilitate the low-‐emission discussion and to tease out of industry stakeholders their views on the solutions and actions that need to be implemented to assist the transition. There are several recurring themes: interaction with government, skills and training, licensing and registration, measurement and benchmarking, information validation and sharing. It’s generally agreed that professionalising the sector will improve the sector’s performance in terms of both economic, environmental sustainability and professional satisfaction.

There is a consensus that the HVAC&R industry could improve the pathways for emerging technologies. There are solutions proposed for new technology, but the industry also needs to address getting the most out of existing technologies, whether already installed, or for new projects. A validation of efficiency claims and comparison tools for new and existing technology are proposed.

System measurement, rating and benchmarking are heavily supported in the proposed solutions. Industry needs to use common (but sector-‐specific) measurement and performance rating tools and metrics so that designers and end users are able to compare system alternatives. Ratings need to be based on life-‐cycle assessments where practical. Better tools based on research and proven models will help position the industry as both forward-‐thinking and science-‐based.

Providing information to end users, HVAC&R technical service providers and related building trades and professionals is also the basis of many of the solutions proposed.

There is a significant role for government in developing evidence-‐based regulations and incentives. However, industry cautions that any government intervention must be evaluated and justified after its implementation. Licensing for trades and professional registration for engineers is also proposed as a pathway for professionalising the industry.

Many solutions suggest a need for improved formal training for new industry entrants (at both TAFE/VET and university level) plus specific, technology-‐focused courses provided by industry, possibly with government support, for existing workers. Subsidised energy efficiency up-‐skilling, for professionals and technicians, must be delivered to industry. This up-‐skilling should be based on open-‐access competencies that focus on the energy efficiency of HVAC&R services.

The training system responds to several market pressures, including perceived demand and available incentives. The demand for training must exist in order to justify supply. There is a strong role seen for industry bodies to provide training and continuing professional development. Industry-‐provided educational information and training through industry bodies, manufacturers and suppliers, training



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websites, collaboration with RTOs, as well as the development of “applications”, computer software and other helpful tools are all seen as potential paths for industry participation in the training and education issue.

AIRAH has listed all of the suggested solutions within Section 5, and with something in excess of 200 individual solutions, some rationalisation is required. The next step in this project is to ask key industry stakeholders to assess and prioritise individual solutions so that the hard work of development and implementation can begin.

Perhaps the most important consideration will be the resourcing of any new initiatives. Ultimately, each endorsed solution needs to be turned into a project plan, with resources, costs and timelines estimated.

Vince Aherne, M.AIRAH

Project manager and technical editor



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ACRONYMS used in this document: AHRI Air Conditioning, Heating and Refrigeration Institute BCA Building Code of Australia CEF Clean Energy Future CFC Chlorofluorocarbon COAG Council of Australian Governments CoP Code of practice COP Coefficient of performance CPD Continuing professional development CPI Consumer price index CTIP Clean Technology Investment Program DCCEE Department of Climate Change and Energy Efficiency DRED Demand-‐response-‐enabling devices DSEWPaC Department of Sustainability, Environment, Water, Population and Community EER Energy efficiency ratio ESD Environmentally sustainable design EUA Environmental upgrade agreement GDP Gross domestic product GWP Global warming potential HC Hydrocarbon HCFC Hydrochlorofluorocarbon HFC Hydrofluorocarbon HFO Hydrofluoro-‐olefin HVAC&R Heating, ventilation, air conditioning and refrigeration HVAC HESS Heating, Ventilation and Air Conditioning High Efficiency Systems Strategy IPLV Integrated part-‐load value IEER Integrated energy efficiency ratio IRR Internal rate of return LCA Life-‐cycle analysis LCC Life-‐cycle costing LEL Lower explosive limit MEPS Minimum Energy Performance Standards NABERS National Australian Built Environment Rating Scheme NCC National Construction Code NEBB National Environmental Balancing Bureau NFEE National Framework on Energy Efficiency

NSEE National Strategy on Energy efficiency NGER National Greenhouse and Energy Reporting NGO Non-‐government organisation NPV Net present value ODP Ozone-‐depletion potential OEH Office of Environment and Heritage (NSW) OEM Original equipment manufacturer PV Photovoltaic R&D Research and development ROI Return on investment RTO Registered training organisation SGG Synthetic greenhouse gas SME Small or medium enterprise VEET Victorian Energy Efficiency Target (Vic) TAFE Technical and further education VET Vocational education and training



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1 -‐ Scope

1.1. Introduction This paper has been prepared to facilitate industry discussions about the steps that need to be taken to help transition the Australian heating, ventilation, air conditioning and refrigeration (HVAC&R) industry to a low-‐emission future.

Emissions from HVAC&R include both the direct and indirect components associated with energy consumption, refrigerant escape to atmosphere and energy embodied in the system. When we talk about emissions we are talking about carbon dioxide (CO2) emissions or CO2 equivalent (CO2-‐e) emissions. The two broad categories of “emissions” from HVAC&R systems are:

• Direct emissions – This is the mass of CO2 emitted or CO2-‐e arising from emissions of refrigerant or any other greenhouse gas from the HVAC&R equipment, over its lifetime (Units: kg CO2, Scope 1 emissions).

• Indirect emissions – This is the mass of CO2 or CO2-‐e emitted by the power generator per kWh of electrical energy supplied to HVAC&R equipment taking into account efficiency losses in generation and distribution including the embodied emissions in the fuel (Units: kg CO2/kWh, Scope 2 emissions). Some life-‐cycle calculations include the energy consumption/emissions and embodied energy associated with the manufacture, transport and installation of components and working fluids (Scope 3 emissions).

Given the national and international concern regarding CO2 and CO2-‐e emissions and the resulting atmospheric effects, there is growing regulatory, financial and community pressure for the HVAC&R industry to reduce its emissions, from both direct and indirect sources. In the context of increasing energy prices and increasing refrigerant prices, “transition” means a highly skilled and professional HVAC&R industry that is both cost-‐effective and environmentally effective.

There are essentially three main factors that affect indirect emissions from HVAC&R systems: • System efficiency – influenced by design, installation, operation and maintenance. • System load and energy consumption – influenced by architectural design (R-‐value of walls,

floors and walls, and, solar gain), system design, characteristics of installed equipment, any local microclimate effects, air and moisture sealing, process efficiency, comfort preferences, time of use, and the modes and methods of operation and control.

• Carbon intensity of energy source – influenced by fuel source for electricity generation (solar, coal, gas, etc) and by fuel type used on site (electricity, gas).

Direct emissions are primarily influenced by fugitive emissions during installation and maintenance, catastrophic leakage events, and emissions at end of life.

There is scope for industry stakeholders to influence all of these contributors.

1.2. Need The HVAC&R industry includes commercial air conditioning, residential air conditioning, commercial refrigeration and industrial refrigeration, vehicle air conditioning and refrigerated transport



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applications. Domestic refrigeration consumer appliances (refrigerators and freezers), non air conditioning space-‐heating systems and heat pumps for water heating and cooling could also be considered part of this sector, as could specialised and industrial ventilation.

Following on from the phase-‐out of CFC and imminent phase-‐out of HCFC refrigerant gasses, Australian government legislation has been introduced to impose an equivalent carbon price on synthetic greenhouse gases (SGG) controlled by the Kyoto Protocol from 1 July 2012. This includes many synthetic gases manufactured and applied as hydrofluorocarbon (HFC) refrigerants. This has imposed significant new charges on many HFC refrigerants that have high global warming potential (GWP). The phase-‐out of hydrochlorofluorocarbon (HCFC) refrigerants is also causing refrigerant price increases.

These regulatory impacts have been exacerbated by high domestic and international demand for refrigerant and raw material shortages, which have all contributed to significant rises in the cost of refrigerants. At the same time electricity costs are also rising due to increasing demand, the rising costs of fuels, increasing generation costs, increasing network costs, renewable energy target costs, and the effect of carbon pricing. The extent of penetration of low-‐GWP refrigerants into the market has the potential to reduce some of these costs.

It may take some time (years) for the HVAC&R market to fully adapt to these cost increases. There is also a considerable amount of uncertainty regarding the future status of the SGG equivalent carbon price in terms of the potential for a change in government (and policy) in 2013 and in terms of the planned move to a market-‐based carbon price in 2015 under the current legislation.

The direct emissions component of HVAC&R systems is being addressed by ozone protection and SGG management legislation and the equivalent carbon price on refrigerants. The indirect emissions of HVAC&R systems are being addressed by encouraging improved energy efficiency and reduced electricity use through carbon pricing. In addition to the rising costs of energy and refrigerants there are many other drivers for low-‐emission HVAC&R, including the minimum energy efficiency standards of the NCC, the NABERS Energy rating scheme, mandatory disclosure, and Green Building rating schemes.

These changes in the market, and the new regulatory environment ushered in with the Clean Energy Future (CEF) legislation and the SGG equivalent carbon price legislation, provide strong motivation for the industry to improve its performance in regard to direct and indirect emissions, and to develop the tools, information and pathways required to deliver lower emission services.

Industry attitudes, practices and technologies will need to change. It is the implementation of these changes that we refer to when using the term “industry transition”. This discussion paper and the subsequent industry summit and roadmap development process will provide a format in which these issues can be explored by industry, and where priority actions can be identified and agreed. Appropriate “lead” organisations and support organisations can then work together to achieve a cohesive outcome for industry, government, the community and the environment.



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1.3. Purpose Saving energy is recognised as one of the biggest energy "sources" of any developed country. The HVAC&R industry has a huge opportunity to take a lead to promote energy-‐saving practices, by educating end users on the best (as well as aggressive) practices on how to correctly utilise existing and new equipment to support this effort. This could include ROI and amortisation estimates, but should also be based on environmental concerns. A bonus would be to drive the industry itself to provide more ecologically sound solutions.

Creating a public, commercial and industrial perception that saving energy keeps long-‐term costs down would be a significant step toward low-‐emission HVAC&R. The industry needs to make this transition to low-‐emission practices and technologies because governments are demanding it, the environment needs it, and society is expecting it. The sector is a major consumer of energy and a substantial contributor to GHG emissions. The industry has an obligation to address the guiding principles of sustainability.

The purpose of this discussion paper is to canvass industry stakeholders and help build consensus on the best ways to help the industry make the transition to low-‐emission practices and technology. This discussion paper will form the basis of an industry summit to be held to consider the key issues, solutions and actions that need to be taken to make that transition.

It is not the purpose of this discussion paper to immediately solve all of the issues faced by the industry or to mandate the essential steps that the industry must take to be environmentally and commercially effective. The purpose of this discussion paper is to provide industry stakeholders with a mechanism within which they can identify the main issues faced by their sector, share ideas and suggest some solutions that can be implemented to address those issues.

1.4. Project objectives The strategic objectives of this project are to:

1. Facilitate an industry-‐ and government-‐wide discussion on the practical steps that need to be taken to assist with the transition to a low-‐emission HVAC&R industry.

2. Help the HVAC&R industry develop a vision of what a low-‐emission future looks like and develop a pathway to achieve that vision.

3. Identify practical actions that can help technical service providers and end users transition to low-‐emission practices.

4. Identify the areas and priorities on which industry can and cannot find consensus. 5. Secure a mandate from industry on those areas and sectors of the industry that require

significant reform. The project is also intended to:

• Consider direct and indirect emissions as part of an HVAC&R system. • Prevent duplication of effort within industry and government, both in Australia and

overseas. • Identify areas already being addressed by existing programs/actions and work on ways to

raise awareness of these and create linkages.



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• Identify gaps in data, skills and knowledge. • Identify gaps where issues are not being addressed. • Identify sector-‐specific issues and those issues that impact across sectors.

1.5. Approach The approach to the development of the discussion paper has been open and transparent, encouraging broad and robust consultation with industry, government and end users.

1.5.1. Consultation process Multiple industry stakeholders were engaged with throughout the development of this discussion paper in a three-‐stage consultation process:

1. The industry was initially canvassed to identify priority issues and known barriers to the transition to a low-‐emission HVAC&R future. This resulted in a bare-‐bones discussion paper.

2. The bare-‐bones discussion paper was formally issued to all industry stakeholders for review and comment. All stakeholder feedback and comment was considered and incorporated where possible in the development of the public review draft.

3. This draft discussion paper was formally issued for a public/industry review and comment process. Stakeholders, industry interests and the public had the opportunity to review the draft paper and provide feedback and comment. All industry feedback and comment was considered for incorporation into the final discussion paper.

Figure 1 – Process to develop Roadmap and pathways

1.5.2. Structure of the paper The discussion paper has been structured in the following format:

Step 1 -‐ First draq – input from HVAC&R key stakeholders

Step 2 -‐ Bare bones issued to level one stakeholders

Step 3 -‐ Discussion paper – public draq version

Step 4 -‐ Discussion paper finalised. HVAC&R industry associakons to vote on solukons.

Step 5 -‐ AIRAH Summit – March 27th 2013

Step 6 -‐ Development of roadmap and pathways



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• Section 1: Introduction and general material • Section 2: Context – background on the environment in which the industry operates • Section 3: The headline issues – Including discussion points on particular issues • Section 4: The issues by sector – Including discussion points on particular issues • Section 5: The proposed solutions grouped by pathway –Actions on particular issues • Section 6: Managing the transition – Including discussion points on transition issues • Section 7: The draft roadmap – Including 5 pathways and solution matrices and identifying

complementary actions that are already happening or by others.

In the early stages of development the discussion paper had many questions relating to discussion points in Sections 2, 3 and 4 and few or no recommended actions in Sections 5. As the project progressed the questions were removed and the proposed solutions were included in Section 5. Section 6 outlines some of the issues associated with transition not covered elsewhere. Section 7 summarises the draft roadmap and associated pathways for transition. The next step is to assess and approve solutions and prioritise actions.

1.5.3. Assessment of solutions Once a suite of potential solutions has been identified the ambitious part of this project begins. Industry stakeholders need not only to agree to collaborate on potential solutions but also need to achieve consensus on how best to prioritise those solutions, decide who should implement them, and how this implementation could be funded.

The final recommended solutions of the discussion paper are listed in Section 5, and will be assessed by industry based on priority and practicality. Priority and practicality will be determined by a survey of key industry stakeholders. The roadmap will then be discussed, endorsed or revised, milestones set and responsibilities for particular actions designated to individual task groups of stakeholders at the AIRAH Industry Summit 2013.



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2. Industry context

2.1. The HVAC&R industry The HVAC&R industry is essential for buildings, the cold chain, food production, health care, manufacturing and agricultural industries, and industrial processing. Refrigeration and air conditioning systems are embedded into every part of the Australian economy and society. The Cold Hard Facts report estimated that in 2007 the HVAC&R industry involved direct spending of more than 1.7% of GDP, employed at least 163,000 people, consumed as much as 45,000 GWh of electricity and resulted in 7% of all Australian greenhouse gas emissions of that year. http://www.environment.gov.au/atmosphere/ozone/publications/pubs/cold-‐hard-‐facts.pdf

However, the industry is highly diverse and fragmented, and does not generally respond to issues with a single voice or a unified position. Views are diverse and the industry is highly competitive and cost-‐driven, and suffers from skills shortages in several key areas.

There are also, however, many ways in which the industry collaborates and coordinates. The industry will need to establish a coordinated strategy for the transition to low-‐emission practices in association with the many stakeholders, including government at three levels, NGOs, the various industries served, educational and research institutions, as well as the HVAC&R industry workforce and the organisations and associations that represent them.

The fragmentation of the HVAC&R industry results in poor cohesion and alignment among the main representative bodies and industry organisations. There is no single entity that can be considered to provide the HVAC&R industry consensus viewpoint. This makes the industry difficult to deal with from a government policy point of view.

2.2. Public perception The Australian public and governments generally have a very low level of awareness about the HVAC&R sector, despite it being integrated into almost every facet of daily life. Shelter, food, safety, productivity, medical, education – in fact all of the fundamental requisites for modern life – depend on the HVAC&R industry to some extent.

Most end users do not fully understand what HVAC&R is and does and to what extent day-‐to-‐day decisions and behavioural patterns can influence the environmental impact of the refrigeration and air conditioning services we all take for granted. For example, commercial building lease agreements may specify very tight temperature control, unrelated to real comfort needs. Similarly, the proliferation of household air conditioning in Australia has been considerable. The time has come where growing demand for electricity is forcing a prioritisation of uses and forcing changes to access arrangements. Mandatory demand management schemes for residential air conditioners are an example of this.

Energy shortages and rising energy costs may force prioritisations like these to be taken more often. This is an important issue for stakeholders to think about. Energy costs will affect everything we do and will impact on the bottom line of many businesses. If government, HVAC&R consumers and the



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general public can be educated to think about HVAC&R in a more holistic sense then the industry will be more successful in providing improved environmental solutions which may have higher capital costs but lower life-‐cycle-‐costs, including lower operating costs.

2.3. Regulatory environment The HVAC&R industry already operates under a large range of commonwealth and state regulatory instruments including the National Construction Code (BCA), Work Health and Safety, ozone protection and synthetic greenhouse gas management legislation (including SGG equivalent carbon price), MEPS, and the like.

The interaction and sheer volume of these numerous regulatory controls does not support uniform and national industry action. A review of the regulatory environment may ultimately be required to remove conflict, duplication and ease the regulatory load on an industry facing a future where flexible responses to a changed market place will be required.

It is also possible that additional regulations may be imposed on an industry that is seen by the government as not being in a position to lead the transition. Industry stakeholders strongly believe that they are best placed to improve on existing standards and introduce risk-‐management practices that work. Industry stakeholders should be able to design acceptable technical solutions within the limits of government policy and do so at maximum benefit and minimum risk to the public. Industry and government both have a role.

2.4. Government policy, energy efficiency and HVAC&R There is a range of government policies and programs that impact on the HVAC&R industry. In general government policy tends to be fairly wide ranging and covering broad sectors; however, specific energy-‐efficiency policies tend to be more focused to target specific sectors where investment will produce the most results.

Plans to address improving energy efficiency within the HVAC&R industry are identified within the nationally agreed National Strategy for Energy Efficiency (NSEE). All state, territory and the commonwealth governments through the Council of Australian Governments (COAG) agreed to improve minimum standards for energy efficiency and accelerate the introduction of new technologies. This could be achieved through improving regulatory processes and addressing the barriers to uptake of new energy-‐efficient products and technologies in the building and appliance sectors.

The Department of Climate Change and Energy Efficiency is the lead commonwealth agency working with state and territory governments to implement a number of measures identified in the Strategy. The Equipment Energy Efficiency Program (E3) and the Commercial Buildings Committee have a significant role in working to implement energy efficiency measures. These programs have undertaken considerable engagement with industry to date to develop strategies addressing energy efficiency. For example, the Heating, Ventilation and Air Conditioning High Efficiency Systems Strategy (HVAC HESS) is a 10-‐year strategy focused on addressing energy efficiency in HVAC systems.



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The non-‐domestic refrigeration sector has a 10-‐year strategy in place for Australia and New Zealand called In from the Cold. MEPS and the labelling program coordinated through the E3 Program covers a range of appliances, including air conditioning and refrigeration.

The following is a brief summary of some of the government policy/programs particularly relevant to energy efficiency in HVAC&R.

2.4.1. National Construction Code (NCC) The primary building regulation relating to energy use in new and refurbished buildings is the NCC, Volume 2 (particularly Section 3.12) for houses and Volume 1 (particularly Section J) for all other classes of buildings. Energy regulation impacts on HVAC&R through reducing the size of equipment needed. The ways the building regulations are framed and the manner in which building designers adjust designs to comply affect the extent and impact on HVAC&R. For example, smaller areas of glazing exposed to sun, advanced glazing, improved insulation, air sealing, etc., can all change the complexity, controls, size and hours of operation of equipment.

On the other hand, relying for compliance on on-‐site power generation may introduce demand for thermal HVAC systems, or allow envelope design that still creates very high peak cooling and heating loads.

http://www.abcb.gov.au/major-‐initiatives/energy-‐efficiency

2.4.2. HVAC HESS The Heating, Ventilation and Air Conditioning High Efficiency Systems Strategy (HVAC HESS) is a 10-‐year initiative under the National Strategy on Energy Efficiency (NSEE) that aims to drive long-‐term improvements in the energy efficiency of HVAC systems Australia-‐wide, including as a driver for state energy-‐efficiency policy. It takes a whole-‐of-‐life perspective in targeting HVAC efficiency improvement, encompassing the design, manufacture, installation, operation and maintenance stages of the HVAC life-‐cycle. It recognises that large efficiency gains can be achieved through the maintenance and operation of existing systems in existing building stock, and seeks to establish national system standards of documentation for design, installation, operation and maintenance of HVAC equipment/systems. The Australian government consulted broadly with stakeholders on a range of project proposals as part of the implementation of HVAC HESS, and the program captured some of the best solutions available at the time to drive high-‐efficiency systems.

http://www.climatechange.gov.au/government/initiatives/hvac-‐hess.aspx.

Since 2007 HVAC HESS has delivered the following two projects:

1. The Guide to Best-‐practice Maintenance & Operation of HVAC Systems for Energy Efficiency has been published.

2. The report Wireless Metering reviews the suitability of electrical sub-‐metering and wireless sensor technologies for retrofit applications to older HVAC systems has also been published.

Note: All projects under the “HVAC HESS” strategy are subject to a funding and prioritisation review.



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2.4.3. Refrigeration – In from the Cold The “In from the Cold – Strategies to Increase Energy Efficiency of Non-‐Domestic Refrigeration in Australia and New Zealand” program is a 10-‐year government strategy that addresses energy efficiency within the commercial refrigeration sector. The Australian government consulted broadly with stakeholders on a range of project proposals as part of the implementation of In from the Cold. The principal focus of the current commercial refrigeration energy-‐efficiency program is developing MEPS for commercial refrigeration products. In this regard, the process has commenced a review of the existing MEPS for refrigerated display cabinets. The progress of other projects in the strategy is now subject to review. Funding and resources required to undertake the projects are limited. Funding discussions with states and territories are expected to inform the priority order of future projects. In from the Cold did not consider emission-‐reduction strategies including the direct emissions issues, the use of natural refrigerants or focus on systems design and energy performance benchmarking.

http://www.energyrating.com.au/Library/details200912-‐in-‐from-‐the-‐cold.html .

Note: All projects under the In from the Cold strategy are subject to a funding and prioritisation review.

2.4.4. Minimum Energy Performance Standards (MEPS) The aim of the MEPS program is to increase the average energy efficiency of equipment sold in Australia by blocking market access to inefficient products, thereby increasing energy productivity and therefore competitiveness, reducing energy bills for consumers, and reducing greenhouse and other environmental emissions. MEPS programs are mandatory in Australia and New Zealand. For the HVAC&R industry MEPS have been introduced for: • Refrigerators and freezers • Mains-‐pressure electric-‐storage water heaters • Three-‐phase electric motors (0.73kW to <185kW) • Single-‐phase air conditioners • Three-‐phase air conditioners up to 65kW cooling capacity • Commercial refrigeration • Commercial building chillers • Close-‐control air conditioners.

http://www.energyrating.gov.au/programs/e3-‐program/meps/about/.

One of the perverse outcomes of the MEPS program has been a resulting consumer and designer focus on equipment rather than systems. Energy efficiency has to focus on systems and sites rather than individual components, although individual equipment efficiency is part of the energy efficiency puzzle.

The level of check testing applied within the MEPS program, and the level of exemptions from the program, (many new technologies are not catered for within MEPS test methods), have also been highlighted as areas where this program can be improved.



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In the residential air conditioner online search tool there are a very limited amount of MEPS qualified models available compared to models available in the market. Getting more air conditioner models certified is important. The Greenhouse and Minimum Energy Standards (GEMS) program aims to create a national framework for MEPS, which will replace state-based MEPS regulations. Note: MEPS for fans is under development and to be based on the EU system and ISO test standards. A product profile was published. The MEPS for pumps program is in the early stages of development. A product profile is being developed.

2.4.5. Energy rating labels Similar to MEPS but targeted at the consumer market is the energy star rating label program for consumer appliances. Single-‐phase non-‐ducted air conditioners for household use are required to carry an energy label in Australia and New Zealand.

For air conditioners, the measure of energy efficiency is the energy efficiency ratio (EER) for cooling, and the coefficient of performance (COP) for heating. The EER and COP are defined as the capacity output divided by the power input based upon the tested power input and the tested capacity output when tested in accordance with AS/NZS 3823. The rating system accounts for standby power and crankcase heating. Other products included in the scheme are domestic refrigerators and freezers.

http://www.energyrating.gov.au/programs/e3-‐program/energy-‐rating-‐labelling/about/.

2.4.6. Other government energy efficiency policy drivers Energy Efficiency in Government Operations (EEGO) – is a government policy that aims to reduce the energy consumption of Australian government operations, with particular emphasis on building energy efficiency. It is unclear to industry how effectively this policy has met its goals.

Energy Efficiency Opportunities (EEO) program – Is a government program that mandates businesses that use more than 0.5 petajoules (PJ) (0.5 x 1015 joules) of energy per year to improve their energy efficiency. It does this by requiring businesses to identify, evaluate and report publicly on cost-‐effective energy savings opportunities leading to:

• Improved identification and uptake of cost-‐effective energy efficiency opportunities • Improved productivity and reduced greenhouse gas emissions • Greater scrutiny of energy use by large energy consumers.

There are more than 220 corporations (incorporating around 1,200 subsidiaries) registered for the Energy Efficiency Opportunities program. This program has been effective at identifying opportunities; however, it is unclear to industry how effectively opportunities have been implemented or the coverage of HVAC&R within the program.

Commercial Building Disclosure (CBD) – is a national program delivered by the Australian government designed to improve the energy efficiency of Australia’s large office buildings. The CBD program was established by the Building Energy Efficiency Disclosure Act 2010 under the NSEE. The governments will consider expanding the program to cover other building types (such as hotels,



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shopping centres and hospitals) from 2014. It is too soon for industry to understand how effectively this policy has met its goals.

Green leases – are a leasing arrangement developed specifically for government agencies. Leases contain mutual obligations for tenants and owners of office buildings to achieve efficiency targets. The lease improves energy efficiency by setting a minimum ongoing operational building energy performance standard. It is unclear to industry how effectively this policy has met its goals.

National Greenhouse and Energy Reporting (NGER) – is a scheme that was introduced to provide data and accounting in relation to greenhouse gas emissions and energy consumption and production. The scheme’s legislated objectives are to:

• Underpin the carbon price mechanism • Inform policy-‐making and the Australian public • Meet Australia’s international reporting obligations • Provide a single national reporting framework for energy and emissions reporting.

The NGER dcheme is used for tracking progress against Australia's emissions targets under the Kyoto Protocol, for both direct and indirect emissions.

2.5. Government incentives Other recent Australian government policies include incentives schemes such as the Green Building Fund and the withdrawn “Tax Breaks for Green Buildings” policy. The government also supports Low Carbon Australia and other low-‐carbon initiatives in the building and other sectors.

For more information on the Green Building Fund see: http://www.ausindustry.gov.au/programs/innovation-‐rd/gbf/Pages/default.aspx

The Clean Technology Investment Program (CTIP) is an $800 million competitive, merit-‐based grants program to support Australian manufacturers to maintain competitiveness in a carbon-‐constrained economy. This program will provide grants for investments in energy-‐efficient capital equipment and low-‐emission technologies, processes and products.

For more information on CTIP see: http://www.ausindustry.gov.au/programs/cleantechnology/cleantechnologyinvestment/Pages/default.aspx.

Government incentive for farmers, food processors and the industries associated with the cold chain to optimise the efficiency of their HVAC&R infrastructure should be sought, as it is vital to a successful transition to a low-‐emission future.

State governent and local government also have policies or schemes in place that impact on HVAC&R including:

• The NSW Office of Environment and Heritage (OEH) Energy Saver scheme • The NSW OEH Energy Efficiency Training Program • The Victorian Energy Efficiency Target (VEET) scheme • The South Australian Residential Energy Efficiency Scheme (REES).



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Note: The DCCEE is examining the feasibility of implementing a national energy efficiency incentives scheme.

http://www.climatechange.gov.au/government/initiatives/energy-‐savings-‐initiative.aspx

Many end users of HVAC&R have advised that the greatest barrier encumbering them from transitioning to low-‐emission technology and practices is the lack of incentives. In order to bypass the issue of government incentives, providing end users with solid and trusted cost-‐benefit analyses, proving the economic merit of optimising and maintaining system efficiency, is crucial.

2.6. Split incentives A significant issue that comes up in some sectors, particularly in the tenanted commercial building market, is the split-‐incentive market failure that commonly occurs when considering energy-‐efficiency interventions. Who pays the cost and who enjoys the benefits? If these two entities are different then a split incentive may occur.

In many scenarios the entity that pays the cost of the intervention (e.g. landlord) is not the entity that benefits from the savings produced (e.g. tenant). As a result there is no or reduced incentive to undertake the work, and the market fails to produce the required outcome. Some schemes have been developed to help overcome these barriers. This market failure is one reason for government intervention.

An emerging tool that has been designed to address the issue of split incentives is the use of “environmental upgrade agreements” (EUAs), which provide a financing mechanism that can be used to split the costs of energy-‐efficiency upgrades between owner and tenant. These agreements provide a finance path to fund the improvements and a mechanism to ensure that the energy savings generated by projects can also be used for funding.

http://www.lowcarbonaustralia.com.au/business/finance-‐solutions/environmental-‐upgrade-‐agreements.aspx

2.7. Financing energy-‐efficiency interventions

2.7.1. Financing interventions One of the biggest barriers to energy-‐efficiency interventions in existing systems and buildings is financial. Some finance models such as Low Carbon Australia and EUAs are available; however, uptake is limited, possibly due to a lack of awareness or to bureaucratic obstacles. If a model can be developed to provide easy access to very low interest (below CPI) finance for energy efficiency projects across the board, then industry uptake would likely be higher.

The Green Building Fund was successful in incentivising energy efficiency upgrades in buildings but the follow-‐up incentive scheme “Tax breaks for green buildings” didn’t eventuate.

Energy performance contracts and/or Environmental performance contracts are an alternative way for owners to offset some of the financial risks associated with energy efficiency upgrades. The relatively small number of contractors offering these services may limit competitiveness.



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http://www.ret.gov.au/energy/Documents/best-‐practice-‐guides/energy_bpg_energy_performance_contracts.pdf

2.7.2. Quantifying costs and benefits In the energy efficiency intervention market, SME clients are reportedly looking for a simple payback period of two to three years, although this can be extended if assistance funding is available. The simple payback method of calculation is easily understood by all parties and provides an easily understandable metric. However, the method is simple and does not take account of issues such as return on investment, the opportunity cost of capital investment alternatives, and the depreciated value of equipment. In some ways the simple payback calculation method may be excluding interventions that can have a positive ROI.

For larger projects and more sophisticated clients the simple payback method may lack the detail to provide realistic advice, and a true ROI calculation must be completed. In these cases a more comprehensive ROI calculation using net present value (NPV), internal rate of return (IRR), life-‐cycle costing (LCC) or life-‐cycle analysis (LCA) methods will provide more accurate financial guidance. Evaluations are time consuming, and constructing good financial arguments are sometimes outside of a design engineer’s comfort zone. Case study and pro-‐forma information could be made available.

2.7.3. CTIP funding The Clean Technology Investment Program (CTIP) is part of the Australian government's Clean Energy Future plan. It is an $800 million competitive, merit-‐based grants program to support Australian manufacturers to maintain competitiveness in a carbon-‐constrained economy. This program will provide grants for investments in energy efficient capital equipment and low-‐emission technologies, processes and products. Refrigerated warehouse and cold chain refrigeration businesses are excluded from the CTIP program.

http://www.ausindustry.gov.au/programs/cleantechnology/cleantechnologyinvestment/Pages/default.aspx

2.8. Green building The Green Building Council of Australia launched the “Green Star environmental rating system” for buildings in 2003. Green Star rating tools help the property industry to reduce the environmental impact of buildings, improve occupant health and productivity and achieve real cost savings, while showcasing innovation in sustainable building practices.

Green Star rating tools are currently available, or in development, for a variety of sectors including, commercial offices (design, construction and interior fit outs), retail centres, schools and universities, multi-‐unit residential buildings, industrial facilities and public buildings and communities. Ratings tools include design rating, as-‐installed rating and an operational performance rating (which is currently under development).

Green Star rating tools can result in increased use of innovative technology and practices which can create a significant learning curve for designers and contractors.



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http://www.gbca.org.au/green-‐star/green-‐star-‐overview/

2.9. Commercial leasing Commercial lease agreements often contain operating requirements that limit a facilities manager’s ability to fully address the energy-‐efficient operation of HVAC&R systems.

Lease agreements often contain mandatory operating hours and temperature set-‐points for HVAC systems, restricting the ability to incorporate energy-‐efficient control algorithms such as optimum start/stop programming, or to allow the widening of dead bands on temperature set-‐points.

Leases that make reference to specifications such as the Property Council of Australia Office Quality Matrix, or specific air conditioning access times or temperature set-‐points may inadvertently limit the ability of a building operator to optimise HVAC energy use. More flexibility may be required within lease agreements.

HVAC&R design must also consider lease-‐specific issues such as how services are supplied and billed. Zoning, timing, and temperature are typical lease-‐stipulated conditions, and service-‐specific clauses from the lease (or pre-‐lease) can influence design considerations.

2.10. Passive design One of the primary mechanisms to reduce demand for heating and cooling within all buildings and structures is the role of good passive design and sustainable engineering techniques. The heating and cooling loads and resultant energy consumption of buildings can be greatly reduced through methods such as increasing insulation, mass and shading, decreasing air loss, natural ventilation, utilising green or white roofs and walls, and a large array of other systems and approaches.

Recognising the role that passive design and technologies can play in reducing the size and hence carbon emissions of an HVAC system is essential in creating a holistic systems approach. Further to this, the recognition that HVAC systems and solutions can also incorporate passive technologies will broaden the approach of the industry. The role of HVAC&R is to support passive design – not to incorporate it or compete with it.

Windows are an important design feature for controlling the amount of light and thermal gain to a building. A properly designed building will be optimised for the climate and latitude to control the thermal gains and maximise the beneficial light, without excessive radiation and glare on the occupants. Harvesting the natural light and controlling electric lighting is very important for minimising the cooling loads. Methods for controlling and optimising natural and hybrid ventilation is another aspect that is often overlooked or underused, yet these approaches can have a huge impact on building cooling and heating loads.

Depending on the sector, it is most likely to be architects, ESD engineers or builders that are designing and specifying passive design features. HVAC&R practitioners are ideally positioned to provide advice on passive design issues, but more importantly to provide quantitative design analysis on the effect of passive design solutions.



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This evidence-‐based validation of passive design and passive technology solutions is what is required for proper integration of passive design techniques and for developing low-‐emission solutions early in the design process. Quantitative design analysis of proposed passive (and active) design solutions appears to be a role well suited to the HVAC&R designer.

There is a split incentive in operation here because HVAC&R designers’ fees are typically related to the size and complexity of the systems. Changes that reduce the size and complexity of HVAC&R equipment will reduce revenue for the industry. Fees for “low carbon” advice and analysis need to be separated from HVAC&R design activities. This is an important issue to consider. If the industry cannot broaden the range of revenue streams, it may attempt to block change, which would increase pressure for regulation.

Partnerships with suppliers of high-‐efficiency building products, materials and low-‐heat-‐generation equipment, energy storage and management systems – as well as development of more advanced design capabilities and cross-‐disciplinary processes that can be charged for – could contribute to replacing lost revenues.

Passive design is generally required to be considered early in the design, and may require a longer payback for the investment. It requires more education of each participant in the supply chain, including architects, engineers, builders, and even building tenants (e.g. the indoor temperature may fluctuate compared to a fixed temperature in an air conditioning environment).

Providing a comprehensive and accurate ROI calculation method for investors (NPV or IRR) and providing education and training to building occupants (e.g. keeping air pathways unblocked is critical to make some systems work) are important components for successful outcomes.

2.11. The need for HVAC&R Not all spaces need HVAC&R services all the time, and some of the drivers for HVAC&R can be designed out of buildings and spaces, particularly within the residential and light commercial sectors. Some of the key reasons for incorporating HVAC&R in a building or process include:

• Provision of occupant comfort, including temperature, humidity and airflow • Provision of indoor air quality including ventilation and filtration • Code compliance in terms of outdoor air ventilation supply and exhaust of indoor air

contaminants • Building/occupant protection through smoke management and condensation control • Process and equipment cooling, eg data centres, manufacturing, agriculture • Refrigerated food storage, display and the cold chain.

Comfort and indoor air quality are linked to productivity, so HVAC can have a positive economic benefit. Where systems are designed for energy efficiency each component of an HVAC&R system is attempting to achieve optimum energy efficiency so that the overall system energy benefits can be maximised. Individual components include the fans, ducts, pumps, pipes, chillers, boilers, filters, coils, and equally important, the control systems.



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Although individual component performances contribute to the system carbon footprint, it is important to note that it is the selection and operation of the overall type of the HVAC&R system that primarily determines the building’s energy consumption profile. Inevitably the selection of the overall HVAC&R system is based on commercial factors or the ability to achieve a targeted energy rating. Comfort issues are often secondary considerations at the initial phase.

A balance needs to be reached between the adoption of energy efficiency measures and the provision of the required indoor environmental quality (IEQ) for occupied buildings or internal climate/process requirements in refrigeration applications. For instance, the failure to satisfy IEQ standards in occupied buildings may increase resistance to innovative and sustainable buildings in an inherently conservative property development market. HVAC&R cannot simply be wished away.

Most building sustainability indices (NABERS, Green Star, LEED in the USA, and BREAM in the UK) include a substantial number of performance credits for IEQ issues related to passive or active environmental control, such as thermal comfort, temperature, humidity, air movement, air quality, individual occupant control, low polluting materials, etc.

2.12. Integrating HVAC&R design into the building design process It is clear that HVAC&R designers need to engage in early consultation sessions with architects, builders and other designers. This integrated approach to design is equally important in all sectors of the industry but particularly commercial HVAC&R. For example, the development and assessment of passive design strategies and building fabrics have become necessary steps in the very early stages of the design process.

The typical “silo” approach to professional design leaves a lot to be desired in terms of efficiency and sustainability. Methods for integrating design teams are well documented; however, commercial and contractual barriers remain entrenched. This is an issue for all stakeholders in the industry, but it can only primarily be driven by owners and developers through contractual and financial arrangements.

Some of the tools that can improve the integration of design include:

• Building Information modelling/management (BIM) process • Integrated project delivery (IPD) methods • Advanced building performance simulation tools • Best-‐practice building commissioning procedures.

2.13. Contracts Contractual arrangements in building and refurbishment delivery can be a big barrier to change in the building industry. Some standard contract arrangements are simply not compatible with the integrated design process, best-‐practice whole-‐building commissioning, BIM process, etc. Most owners want a single point of responsibility and risk, and the lowest capital cost possible. These objectives are often not compatible with an integrated and collaborative approach to project delivery. Contractual arrangements are well embedded in the industry, and we have no proposed



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solutions for unlocking this area or encouraging contracts to include for sustainability, low-‐emission HVAC&R, whole-‐building commissioning and tuning and the like.

2.14. HVAC&R design conditions Heating and cooling load calculation methods need to be updated to reflect the impacts of improved building design, building fabric performance, modern operation protocols and effect of internal appliances and lighting systems and equipment design, selection and management.

An important aspect of HVAC&R design and application relates to the external design conditions used for the load calculations. Design conditions need to be based on up-‐to-‐date climate data.

There is also the question of future climate conditions. An HVAC&R system could be expected to last a minimum of 20 years in operation in many applications. Should HVAC&R design engineers be morphing climate data to climate change scenarios to account for future external design conditions? Passive solutions, future operator and occupant behaviour and future comfort expectations in a warmer world with peak/variable energy pricing all need to be considered.

The future carbon intensity of the electricity grid should also be taken into account. Internal cooling loads will be affected by appliances, both fixed and plugged. These appliances are continually becoming more efficient. The practice of oversizing systems also needs to be addressed.

Computer-‐based design, modelling, simulation and rating programs all need to work from a consistent climate database. This is an area of ongoing research and development.

Current design guides, load estimation programs and building simulation programs do not accurately cover the Australian climate, internal heat loads, occupant densities, and design set-‐points. Historical design rules need to be revisited and revised into a load estimation methodology that avoids over sizing. Ultimately, however, load estimation and system sizing are commercial decisions.

2.15. Design and control strategies There are a range of design strategies and tools available to the HVAC&R professional to reduce emissions including mixed mode ventilation, free cooling, pre-‐cooling, advanced control algorithms, low-‐pressure design, and building management and control systems. HVAC&R practitioners should have knowledge of and be able to implement these types of control strategies.

There are some energy-‐efficient HVAC control strategies such as “adaptive comfort” that can vary set-‐points in sympathy with outside temperatures, providing energy benefits. These strategies can be used on buildings to account for operable blinds, openable windows, circulating fans, changing or seasonal dress codes and changing metabolic rates.

Shifting from centralised HVAC&R systems to multiple modular solutions could have huge impacts on the industry, and on energy use. In energy-‐efficient houses, each room now can have quite different cooling loads than other spaces at a given time of day, so the need for local controls or modular units is also emerging. On-‐off control and setbacks also suit multiple modular solutions.



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The trend in recent commercial developments is to have different systems serving the perimeter and the interior zones. Apart from capital cost and energy efficiency there are various issues that need to be taken into account. They include the impact on comfort, maintenance, operating cost, commissioning complexities and ability to meet tenancy fit-‐out scenarios.

The design guides available do not comprehensively cover the low-‐emission HVAC&R design strategies and options, control options, current construction methods, nor do they include evaluation strategies for selecting different types of low-‐emission HVAC&R system approaches.

2.16. System and building commissioning Commissioning is a comprehensive process for the planning, delivery, and verification of buildings and systems. Commissioning involves peer review, quality control and risk management; it assures all systems perform interactively according to the design, specification, and the owners’ (and occupants’) operational needs. Commissioning means integration meetings, system surveys and tests, resolving issues, documenting the process, and verifying and reporting at each stage.

Effective commissioning requires the following fundamental principles to be incorporated: 1. Determine the project performance requirements 2. Plan the commissioning process 3. Complete commissioning in accordance with the plan 4. Document compliance and acceptance.

It is generally recognised in the HVAC&R industry that system and building commissioning is often not performed correctly or optimally. There are many reasons for this that are widely acknowledged, including lack of time, understanding, or empowerment; an emerging skills gap in the industry; and a poor transfer of system knowledge through the entire building design-‐construction-‐handover-‐operation process. Even when performed correctly buildings are often commissioned when empty (unoccupied) and within a single season before the building has settled thermally.

However, if the HVAC&R industry is to be able to meet the energy efficiency and performance expectations of the 21st century this will have to change. The vast majority of the industry agrees that inadequate commissioning of building services is a major barrier to optimising a building’s energy and water efficiency. Legislation is seen by many as the best way to ensure a level playing field for building/system commissioning. Commissioning certification or accreditation schemes have also been suggested.

2.17. Building management and control systems Building management and control systems (BMCS) are a very significant part of the energy efficiency picture. These systems contain the system control protocols and operator interface but can also provide feedback data for monitoring performance, benchmarking energy efficiency, and planning or scheduling maintenance. Although each item of plant within an HVAC&R system should be able to control independently, the understanding of inter-‐dependencies and association is key to both the BMCS control efficiency and a building’s energy efficiency.



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Energy-‐optimisation strategies can substantially reduce energy use, but can also create instability within a system if not implemented correctly. The optimisation of control set-‐points and equipment schedules is typical of an intelligent system. When designing these strategies, the complete system chain must be considered from the source (e.g. central plant) to the destination (e.g. occupied area).

For example, in a typical cooling system, the demand can be influenced by the air temperature, (which is dictated by the chilled water temperature), and the air volume. This system could include a chilled water reset strategy and a supply air temperature reset strategy. Potentially these two control strategies, operating at the same time, could introduce instability into the cooling system. Resets should be biased to which equipment or condition has the greatest energy efficiency impact, and cascaded to negate the possibility of one cancelling out the other.

BMCS provide opportunities to better balance energy efficiency with tenant satisfaction; however, it is important to manage who has access to the BMCS controls and who has authorisation to make any changes.

2.18. Building information modelling/management Building information modelling/management or BIM is a process of digitising and sharing building information throughout the life-‐cycle of a building’s, design, construction, operation and refurbishment. Different stakeholders add information and detail to a common digital model or virtual building which allows all stakeholders in the project to work from the same information in real time.

While still in its infancy within the Australian HVAC&R industry the BIM process promises improved integration of the design/installation process, improved construction efficiencies through new delivery methods, more complete and more accurate building simulations, and better or more complete documentation and information deliverables at project handover and throughout the operational life-‐cycle.

2.19. International developments in refrigeration Australia is not the only country addressing HVAC&R emissions issues. There is growing international support for expanding and adapting the Montréal Protocol on Substances that Deplete the Ozone Layer to control high-‐GWP HFC refrigerant gases. The European Union has announced that it will introduce a phase down of HFCs, independent of, or in advance to, actions through the Montréal Protocol.

Many European countries have introduced legislation to restrict high-‐GWP HFC refrigerant gases. It seems unnecessary for the Australian HVAC&R industry to try to duplicate efforts if there are relevant and tested existing tools and methodologies available from overseas that could be replicated here. Many countries have developed models or programs that could be adapted for Australian use, including:



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2.19.1. Refrigerant leakage • EU – F Gas Regulations – mandatory leak inspection and management. Contractors within

the EU are required to comply with EN378/ISO5149 and be ISO 9001 certified if they deal with refrigerants. EU has just gone through a five year period of introducing uniform rules throughout member countries.

• Netherlands – STEK – a certification system for refrigeration contractors enforced by legislation.

• Germany – leakage limit for supermarket applications of less than 3%/annum (age/size limits).

• Real Zero/Real Europe – A voluntary industry-‐led initiative to reduce refrigerant leakage including a series of “how to” guides, training and certification programs.

2.19.2. HFC Bans/Restrictions • Denmark – HFC banned in new systems with greater than 10kg charge or less than 150g,

plus high-‐GWP refrigerant tax. • Norway – high-‐GWP refrigerants are taxed. • Austria – prohibits the use of HFCs. (However, refrigerant charges to 100kg or 1.5kg per kW

cooling capacity can have limited use). • Switzerland – makes mandatory the use of indirect (secondary heat transfer) systems for

supermarket refrigeration systems with more than 80 kW refrigeration capacity. Also requires registration and leak control for HFC refrigerants. Switzerland has recently introduced HFC bans by sector.

• Sweden – the maximum refrigerant charge allowed in a supermarket refrigeration system was restricted to 20kg for medium-‐temperature applications and 30kg for low-‐temperature applications. The refrigerant charge for any unit was not allowed to exceed 200kg. As a result there are many indirect refrigeration systems installed in supermarkets.

• European Union – proposal to phase down the use of HFCs.

2.19.3. Tools • Denmark – IPU CoolPack is a collection of simulation models for refrigeration systems. The

models each have a specific purpose e.g. cycle analysis, dimensioning of main components, energy analysis, and optimisation.

• EU – ICE–E – provides free information and tools to cold store operators, designers and users to help them reduce energy consumption and carbon emissions.

• Real Europe – Guides and training tools for leak minimisation. • USA – Department of Energy – simulation models for refrigeration systems. • USA – Air Conditioning, Heating and Refrigeration Institute (AHRI) – Life-‐cycle Climate

Performance Model for Residential Heat Pump Systems. • USA – Oak Ridge National Laboratory (ORNL) – A web-‐based life-‐cycle climate performance

design tool calculator for supermarket refrigeration systems.

2.19.4. Refrigerant and equipment manufacture Most refrigeration and air conditioning plant is imported into Australia. There are, however, some notable exceptions where manufacturing is taking place in Australia. Due to the relatively small size of the Australian HVAC&R market, it is unlikely that the international refrigerant or equipment manufacturers will change their development plans in response to Australian carbon pricing



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legislation. In contrast, Europe has exerted significant influence on the market via legislation to encourage adoption of lower-‐GWP, high-‐efficiency systems. Some sectors and countries are moving to low-‐GWP technologies faster than others.

Low-‐GWP solutions for many sectors are already commercialised, but many are not available in Australia or there is insufficient awareness of these options to drive demand. In the overwhelming majority of sectors that lack commercially available low-‐GWP solutions, research and development and commercialisation of low-‐GWP options is already under way. Additionally, there is considerable international technology development that may drive the use of low-‐GWP solutions and new low-‐ GWP refrigerants. The key drivers are economics and legislation.

In Australia the equivalent carbon price for high-‐GWP refrigerants and carbon pricing of energy consumption has increased the operational cost of low-‐efficiency high-‐GWP equipment. There is therefore renewed focus on energy efficient and low-‐GWP/ODS emissions plant. In some cases low-‐GWP solutions require higher capital cost, which is a barrier to uptake despite the total life-‐cycle costs being lower. Economies of scale may act to reduce costs in the future.

http://www.eia-‐international.org/wp-‐content/uploads/EIA_FGas_Report_0412_FINAL_MEDRES_v3.pdf

Through its environment program, the United Nations is actively assisting developing countries transitioning from CFC and HCFC technologies to move directly to low-‐GWP refrigeration and air conditioning solutions, bypassing high-‐GWP refrigerants entirely. Low-‐GWP refrigeration solutions appear to have a clearer path to market in developing countries than in developed countries. There is significant effort in China and India to supply low-‐cost plant into the local HVAC&R market-‐based on locally developed low-‐GWP solutions.

Most of the low-‐GWP refrigeration and air conditioning technology research and development is occurring overseas. For example, the development of low-‐GWP hydrofluoro-‐olefin (HFO) refrigerants is being carried out in Europe and the USA. A range of low-‐GWP natural refrigerant-‐based systems has been developed in Europe and Asia. Energy-‐efficient components and systems are being developed in a range of countries. It is unclear how much research and development is occurring in Australia. However, there is a growing need in the Australian industry for a trusted mechanism that can be used to validate the efficiency, environmental and safety performance claims made by refrigeration and air conditioning technology providers.

Improved “system” efficiencies can be achieved by a range of strategies involving selection of products, system design and installation practices, as well as measures that reduce the extremes of environmental conditions to which HVAC&R equipment is exposed, and how it is operated. Much of this is addressed locally.

2.20. Energy prices and pricing policy Energy pricing is a cost driver for emissions improvements and is used to influence consumer use of HVAC&R. Time-‐of-‐use pricing is being progressively introduced, and is a method used by energy retailers to address peak electricity demand issues. Peak pricing typically occurs at times of the highest cooling and heating demand.



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Energy pricing is often a commercial-‐in-‐confidence agreement between owner and provider; however, this information should be made available to design engineers, as this determines viability and life-‐cycle costs (LCC). More inclusion of HVAC&R designers is required because:

• Mechanical engineers could model system operational performance on power pricing – not just energy consumption evaluation.

• Time-‐of-‐use and similar pricing mechanisms alter LCC analysis markedly. • There are negotiation options within pricing schemes that design engineers can influence.

The models and computer simulation programs that HVAC&R engineers use to calculate system energy and running costs also need to be able to accommodate time-‐of-‐use tariffs. Many HVAC&R technical service providers and end users do not fully understand the impact of time-‐of-‐use tariffs and dynamic peak pricing or how to match their HVAC&R system usage or control settings with this new electricity pricing structure. Education and awareness campaigns are important as consumers will often take the “easiest” option even if it costs more.

General site energy use intensity is another performance indicator that could be provided with utility bills to raise awareness of energy use and energy efficiency opportunities.

Energy pricing will not necessarily be effective in all sectors. An example is the health industry, where energy costs typically represent less than 1% of the annual budget and are therefore a low priority due to lack of capital funding for non-‐clinical uses

2.21. Carbon intensity of the “grid” When we talk about the “grid” we are talking about the national and regional electricity transmission and distribution network. The greening of the grid, or reducing its carbon intensity (grid-‐related CO2/CO2-‐e emissions), is a societal and governmental responsibility.

However, some HVAC&R design decisions are influenced by the carbon intensity of the proposed energy supply. One aspect to consider is the current and future zero and low-‐emission on-‐site energy-‐generation systems and how they can be integrated with HVAC&R. As buildings get more efficient, heating and cooling loads reduce, resulting in smaller HVAC&R systems. These leaner HVAC&R systems may be more compatible with on-‐site low-‐emission energy-‐generation systems. Photovoltaic (PV) systems, increasingly with battery storage and smart controls, and other on-‐site generation solutions are beginning to enter the commercial and industrial markets, and are already established in the residential sector.

The electricity grid is steadily reducing its carbon intensity. At the same time the carbon intensity of alternative fuels and energy sources may actually be increasing. For instance, the natural gas that is extracted from coal seam projects may have a much higher carbon intensity than natural gas extracted from traditional sources due to the extraction processes used. All fossil fuels have extraction-‐related emissions, and as technology empowers deeper extraction and alternative methods the embodied carbon intensity of these fuels may change.



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2.22. HVAC&R interactions with the “grid” There are ways in which the HVAC&R industry can help influence grid emissions intensity, including through active participation in demand-‐side management; the correct implementation of co-‐generation (simultaneous generation of power and heat) and tri-‐generation (simultaneous generation of power, heat and cooling) systems; the use of thermal energy-‐storage systems; and the use of new materials such as phase-‐change materials.

There is also a range of new or alternative technologies that the industry might adopt in the search for low-‐emission engineering solutions for HVAC&R. There will be no single solution to suit all situations, and a variety of technologies, design strategies and implementation techniques will make up the eventual low-‐emission HVAC&R picture.

2.22.1. Demand management Often demand management is seen as a way to manage capacity constraints in the grid. But a more flexible and responsive demand side also helps grid operators to better integrate variable sources of low-‐carbon energy sources such as wind and solar, as well as to delay or avoid expensive network upgrades, which can lead to higher energy costs for consumers. Demand response can be an income stream for a system/building owner. Demand management is not just about avoided costs. Sophisticated demand management solutions typically require complex metering and automation systems, and high-‐quality design and engineering.

Load shifting and peak clipping (or peak lopping) are the primary focus of demand management programs. International and open standards are beginning to emerge (e.g. OpenADR, ZigBee Smart Energy), designed to facilitate demand response programs, events, feedback and reporting through the common two-‐way information exchange between electricity service providers, aggregators, and end users.

2.22.2. Co-‐generation and tri-‐generation systems Co-‐generation and tri-‐generation are other ways that the HVAC&R industry might influence grid emissions intensity. These systems generate power, heat and cooling from a single energy source. These systems are increasingly being used in buildings and in the commercial and industrial sectors. There are a number of industry reports of co-‐generation and tri-‐generation systems that are incorrectly sized or poorly implemented.

The HVAC&R industry needs better information to provide co-‐generation feasibility studies and to plan, design, install and operate systems so that the full benefits can be unlocked. These systems can be complex and expensive to maintain and may have questionable long-‐term benefits in some applications, often only justified by artificial tariff structures or installed to attract rating scheme credits. On the other hand, where existing electricity networks are particularly constrained these systems can offer considerable and immediate benefits.



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The HVAC&R industry can address the design side of the equation by helping to identify and disseminate best-‐practice design processes. The key to any guideline would be to identify the best situations for their use and avoidance, as well as the correct design and maintenance strategies.

2.22.3. Energy storage The use of thermal energy storage is a re-‐emerging technology that the HVAC&R industry can apply to offset a site’s peak electricity demand. Electricity and thermal demands can be decoupled and demands can be balanced across the operating period. These systems store chilled water, ice, glycol, hot water, or specific phase-‐change materials in an insulated reservoir for later use. They are often designed to use cheaper-‐rate night-‐time electricity or to store energy from a process (waste heat) or generator for later use.

Energy-‐storage systems can shift demand away from peaks and provide resilience if power failures occur. Combining renewable or low-‐carbon energy sources with on-‐site thermal storage systems can assist in the overall energy management of the base-‐load power requirements of a site. There is some evidence that traditionally, in Australia, energy storage solutions have not been operated well into the longer term. Correct ongoing operation and maintenance protocols are critical to the long-‐term success of these systems. System owners and operators need to understand this. System designers and installers need to facilitate it.

2.22.4. Phase-‐change materials Phase-‐change materials are substances with high latent heat of fusion properties that are capable of storing and releasing relatively large amounts of energy when they melt or solidify. These phase changes can be engineered to occur at specific temperatures. Heat is absorbed or released during the phase change and correctly applied these materials can store that latent heat.

These materials can be applied in a variety of ways in buildings and HVAC&R systems as passive energy-‐storage systems, enabling heating and cooling demands to be balanced across the operational period.

2.22.5. Alternative technologies In Australia conventional vapour compression-‐based air conditioning and refrigeration using synthetic refrigerants is the most prevalent cooling technology in use across most sectors. The main exception is for industrial refrigeration where ammonia and hydrocarbon-‐based systems are also common. However, there are new and alternative cooling and heating technologies being developed and existing technologies being revisited, some of which do not use refrigerants and some that use refrigerants in different ways. These include:

• Solar and hybrid solar cooling technologies • Absorption and adsorption-‐based systems • Magnetic cooling, thermoelectric cooling • Refrigeration systems driven by solar PV arrays • Systems using CO2 as a primary refrigerant or as a secondary refrigerant • Systems using water and slurry ice as refrigerants/secondary refrigerants



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• Ground source heat pumps • Evaporative air cooling systems • District cooling systems • Passive solutions including thermal massing, white roofs/walls, green roofs/walls, phase-‐

change materials, labyrinth cooling, radiant cooling/heating, natural and hybrid ventilation.

Some of these technologies are commercialised or well advanced into commercialisation while others are just emerging. All of these products and technologies need pathways to enter the relatively conservative and highly competitive HVAC&R market.

Some technologies and equipment being promoted within the industry are being misrepresented with regard to their performance capabilities and emission profiles. Some of the plant and equipment being introduced to the market are inefficient, and their inappropriate use could significantly increase energy costs. Some are not fit for purpose. Many new technologies cannot be rated using existing testing standards or MEPS programs. Many of these products are not independently verified and many suppliers are traders rather than technical service providers

In the highly litigious, low-‐margin and low-‐fee world of HVAC&R, designers tend to be risk averse and avoid systems with which they are not familiar. The resistance to new refrigerants and new technologies is high, throughout the supply chain. Technology and innovation often needs to be driven by the client, generally by accepting some of the risk and providing additional capital expenditure.

For a variety of reasons, some HVAC&R sectors have been slower than others to adopt alternative technologies.



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3. The headline issues

3.1. Section introduction Some of the issues that the HVAC&R industry needs to come to terms with in the transition to a low-‐emission future apply across all sectors of the industry and some issues are specific to individual sectors or portions of the industry. In particular the “headline” issues around safety, environment, energy efficiency, refrigerant leak management, low-‐GWP alternatives, product stewardship, skills and training and the licensing and registration of industry practitioners are of critical importance across all sectors.

This section of the discussion paper attempts to analyse the main headline issues. While these issues may be common to all sectors, specific solutions may differ between sectors.

3.2. Refrigeration safety issues

3.2.1. Refrigerant classification Refrigerants are classified based on their flammability (1, or 2 or 3) and toxicity (A and B) characteristics in accordance with AS/NZS 1677.1. This standard designates refrigerant numbers and is based on and technically equivalent to ISO 817. The method and parameters of classification are determined on the basis of health and safety, consistent with European, USA and International practice, primarily based on flammability and toxicity.

Refrigerants are classified into three flammability groups in AS/NZS 1677.1: Group 1—Non flammable. Group 2—LEL ≥ 3.5% volume. Group 3—LEL < 3.5% volume. LEL is the lower explosive limit, the minimum concentration of the refrigerant that is capable of propagating a flame through a homogeneous mixture of refrigerant and air measured at 21°C and 101 kPa.

Note: ASHRAE standards have included an optional 2L subclass to the existing Class 2 flammability classification, signifying class 2 refrigerants with a burning velocity less than or equal to 10cm/s.

Refrigerants are also classified into two toxicity groups in AS/NZS 1677.1: Group A—LC50 ≥ 10 000 parts per million. Group B—LC50 < 10 000 parts per million. LC50 is the lethal concentration 50, a calculated concentration of a substance in air, exposure to which, for a four-‐hour period of time, is expected to cause the death of 50% of the entire defined experimental (rat) population.

Using this system refrigerant safety classifications consist of two alphanumeric characters (e.g. A2 or B1). The capital letter indicates the toxicity and the numeral denotes the flammability.



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The standard does not classify refrigerants on the basis of their ozone-‐depleting potential (ODP) and global warming potential (GWP); however, information on ODP and GWP is provided and the standard states that these effects are important and makes their consideration mandatory when selecting the refrigerant for a particular application.

Note: Only the “consideration” of the environmental issues is mandatory and there are no mandatory requirements within the standard relating to environmental impacts. While refrigerant environmental information is provided, a mandatory environmental classification system would struggle with the changing terms of reference on what levels of these factors are ‘benign’ to the environment. For example, HFCs were supposed to be more benign to the environment than CFCs and HCFCs however, greenhouse gas concerns now make them look more harmful.

3.2.2. Design safety standard Historically AS/NZS 1677.2 Refrigeration Safety has been the design safety standard that has been applied to refrigeration systems within Australia and New Zealand. This standard, whose current edition is dated 1998, is based on and technically similar to ISO 5149: 1993.

This standard is currently under revision. The Standards Australia committee responsible for the document was intending to adopt the revised ISO 5149 with local amendments. However, the final draft of the ISO standard was not supported by the required majority of ISO member countries and has not been approved for publication.

AS/NZS 1677.2:1998 remains the current design safety standard applicable in Australia. There is considerable uncertainty in industry about how and in what sectors this safety standard is regulated for use. End users stipulate that their safety should be paramount when considering policy amendments.

Significant safety concerns have been raised regarding the application of flammable hydrocarbon refrigerants, flammable synthetic refrigerants, flammable blends of refrigerants and the products of combustion of synthetic refrigerants when burnt. The design aspects of these safety issues are all legitimately included under the terms of reference of the Standards Australia Technical Committee ME–006, which is responsible for the AS/NZS 1677 series of standards.

Government gas regulators advise that using flammable refrigerants means that the HVAC&R industry is moving into an area and safety regime that is already in place for these substances. Skill-‐ sets such as hazardous area engineering and risk management (among others) need to be introduced to provide a standard that it is workable, with methodologies that are defensible in the courts and represent sound gas safety engineering. Gas safety engineering considerations would need to address pooling, ignition opportunities, and energy release in case of deflagration. These risk mitigation techniques require a variety of skills that may not be available in the HVAC&R field. For flammable refrigerants in Groups 2 and 3 there needs to be a greater reliance on indirect systems. Government gas regulators advise against including a performance-‐based approach within AS 1677.2.



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The AS/NZS 1677.1 standard classifies refrigerants and lists information with regard to their environmental impacts including ODP and GWP. The AS/NZS 1677.2 design standard is focused on safety and does not consider environmental impact beyond recommending that these impacts be considered during system design.

3.2.3. Product standards Some refrigeration and air conditioning equipment products are covered by product standards which include requirements that address safety issues.

The AS/NZS60335 series of standards deals with the safety of electrical appliances. Standards relevant to air conditioning and refrigeration include AS/NZS60335.2.24 (ice-‐cream appliances and ice-‐makers), AS/NZS60335.2.40 (electrical heat pumps, air conditioners and dehumidifiers), AS/NZS60335.2.75 (commercial dispensing appliances and vending machines), and AS/NZS60335.2.89 (commercial refrigerating appliances with an incorporated or remote refrigerant condensing unit or compressor). Compliance with these standards is mandatory under the various state electrical regulations.

3.2.4. Gas regulations Gas safety standards and regulations are also relevant to the application of hydrocarbon-‐based refrigerants. If synthetic refrigerants are flammable (group 2 or 3) then they too may be subjected to similar criteria.

Government gas regulators advise that the current states and territory-‐based gas safety regulations that are in place for flammable gases do not always cover refrigerant applications. This is because the regulators may not have envisaged the use of these flammable substances as refrigerants at the time regulations were promulgated. Often the word “fuel” as a use of flammable gas is added. Gas regulators envisage that most states will alter the definition so that all flammable gas uses are covered. Queensland already has a regulatory regime in place that covers flammable refrigerants.

3.2.5. Industry Code of Practice The handling and emergency management aspects of flammable, toxic and other hazardous refrigerants are not covered by system standards AS/NZS 1677.2 or by product standards. In the case of ammonia, a toxic and mildly flammable B2 refrigerant, these issues are covered by an AIRAH industry Code of Practice. In the case of flammable refrigerants (A2 and A3) a national industry Code of Practice is currently under development.

Industry Codes of Practice are practical guides to achieving the standards of health, safety and welfare required under the model Work Health and Safety (WHS) Act 2011 and the model WHS Regulations, as well as any workplace health and safety legislation relevant to the jurisdiction. An approved Code of Practice applies to anyone who has a duty of care in the circumstances described in the Code. In most cases, following an approved Code of Practice would achieve compliance with the health and safety duties in the WHS Act, as well as relevant workplace health and safety legislation in that jurisdiction, in relation to the subject matter of the Code.



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A Code of Practice for this industry could cover the following topics: • Acts and regulations across Australia • Safety requirements for design and modification • Retrofitting protocols and practices for existing systems • Hazard identification, risk assessment and controls • Emergency planning • System maintenance protocols • Placarding (identification) signage • Personal protective equipment • Detection systems • Storage and transport • Training • Auditing.

Like Regulations, Codes of Practice deal with particular issues and do not cover all hazards or risks which may arise. Codes of Practice need to complement the applicable Australian Standards and State and Commonwealth legislation and regulations in order to provide a cohesive, accessible and understandable regulatory structure for the HVAC&R industry.

For industry Codes of Practice for refrigerants, the following status applies:

• Ammonia (R717, B2) – Published Code available – Currently being updated for national use. http://www.airah.org.au/Ammonia_COP2011.pdf

• Flammable refrigerants (A2 and A3) – Code under development – project not fully resourced.

• CO2 as a refrigerant (R744, A1) – Code planned – project not resourced.

3.2.6. Refrigerant trade-‐offs One of the biggest issues not addressed in the industry is the trade-‐offs between safety, environmental impacts and economic considerations. It is widely recognised that there is no perfect refrigerant, although many have their favourites. The best choice for a particular application requires a consideration of the pros and cons of each refrigerant. Unfortunately common metrics for all of the safety, environmental and economic issues are difficult to develop.

For example, how would a designer compare the risk associated with the use of a flammable refrigerant with the economic and environmental benefit that may result if it has higher energy efficiency? Hence the problem is often reduced to the question “What level of risk is acceptable?” Certainly no refrigerant is risk free.

3.3. Environmental issues

3.3.1. Emissions versus energy efficiency Different sectors place different emphasis on emissions and energy efficiency. For instance the NCC minimum standards focus on energy efficiency and reducing energy consumption, while Green Star tools and NABERS Energy also focus on the CO2 generation associated with the energy used.



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In some cases low-‐emission engineering solutions are ruled out because they have high energy intensity, i.e. they use a lot of energy but the energy is from a low-‐emission source.

From an environmental perspective, emissions are the crucial factor. But from an engineering point of view it is often the energy efficiency that is focused on, the carbon intensity of the energy source being sometimes seen as a separate but related issue.

In pursuing the enforcement of lower-‐GWP refrigerants, we should ensure that we counteract the benefits by lower system efficiencies. Applying a refrigerant that has a better direct emissions outcome should not increase the system’s lifetime indirect emissions.

3.3.2. Energy efficiency versus energy consumption Energy efficiency is bound up with evolving notions of comfort and sufficiency. With increasing affluence, some of the efficiency gains are "spent" on larger homes or buildings, lower occupancy rates, and increasing expectations of comfort. These so called "rebound factors" can erode some of the emission abatement achieved through improvements in technical efficiency.

Energy consumption is not always about plant size. There are examples where a larger HVAC plant size enables lower overall energy consumption. For example lower U value glazing may increase peak cooling loads but, due to overnight heat release, actually reduce energy consumed.

Some engineers feel that any design should always be about energy consumption and not about loads, other than to meet instantaneous load. Many HVAC&R engineers focus by default on load and plant efficiency, which may not always represent the best way forward. Designers need to look beyond systems, and consider projects as a whole.

3.3.3. ODP versus GWP The Montreal Protocol mandates a move to zero-‐ODP refrigerants. This has led to the development and application of alternative refrigerants with zero ODP but in some cases high-‐GWP. Is there a case to allow “near zero” ODP refrigerants back onto the market, for example with ODP ratings of less than say 0.03? This might allow some existing low-‐GWP near-‐zero ODP refrigerants to be used more.

If the ozone layer is repairing itself, or if ODP becomes less important than GWP, is near-‐zero ODP worth trading in order to more rapidly transition to low-‐GWP refrigerants? Is the ozone layer repairing itself, and is there any international appetite for “near zero” ODP refrigerants?

In reality it would most likely be difficult to amend the Montreal Protocol to remove some refrigerants from the phase-‐out schedule. Any amendment to the Montreal Protocol would require all 196 parties to the protocol to agree to less stringent control measures.

3.3.4. Environmental degradation/impact Controls for the direct environmental degradation effects of some refrigerants have been imposed by international and national agreements and legislation.



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There is a range of international and national instruments and regulations that are applied to refrigerants, including: Montréal Protocol on Substances that Deplete the Ozone Layer, Kyoto Protocol to the United Nations Framework Convention on Climate Change, Australian ozone protection and synthetic greenhouse gas management legislation (which includes legislation relating to applying the equivalent carbon price for synthetic greenhouse gases as part of the government’s Clean Energy Future policy).

Environmental regulations generally address or limit direct emissions or refrigerant leakage from HVAC&R (other uses are also covered e.g. fire suppression, blowing agents, etc).

Environmental degradation occurs as a result of both direct and indirect emissions. A common estimation of the average breakdown of emissions in a “typical” or notional system is 85% from the indirect energy component and 15% from direct refrigerant leakage, across its entire life-‐cycle. The proportion of the direct and indirect emissions will vary across sector types, system types, application type, refrigerant types and age and efficiency of the system components. Some systems have very high and persistent leakage and some do not. Those that have high leakage introduce both an environmental issue and a commercial issue.

Clearly the indirect emissions arising from the power consumption (the notional 85%) also need to be addressed. This is achieved primarily by addressing the energy efficiency of the system and the environmental effects or carbon intensity of the energy source.

Note: The carbon intensity of the electricity used to power a system is not always in the control of the HVAC&R system designer.

3.3.5. Environmental performance There are at least two published methods for calculating or estimating the relative environmental impact of refrigeration and air conditioning systems.

TEWI – Total equivalent warming impact – The TEWI methodology explicitly seeks to identify both the “direct” effect of greenhouse gas emissions from the product (including end-‐of-‐life losses) and the “indirect” effect of carbon dioxide emissions related to the energy consumption of the system. The TEWI method ignores the energy embodied in the system materials and the greenhouse gas emissions created during refrigerant manufacturing, refining, packaging, transport and handling.

AIRAH has published a best-‐practice guide to TEWI (http://www.airah.org.au/Best_Practice_Tewi_June2012.pdf)

LCCP – Life-‐cycle climate performance – The concept of LCCP is more comprehensive than the TEWI method. The LCCP method calculates the “cradle-‐to-‐grave” climate impacts of the direct and indirect greenhouse gas emissions, and includes the energy embodied in the system materials, the greenhouse gas emissions during refrigerant manufacturing, refining, packaging, transport and handling, and the end-‐of-‐life loss.



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Several LCCP assessment tools have been developed (in USA) including one for residential heat pumps (http://www.ahrinet.org/technical+results.aspx) and one for supermarket systems (http://lccp.umd.edu/ornllccp/)

TEWI, LCCP and other life-‐cycle assessment methodologies require major assumptions to be made and hence absolute accuracy is not possible. The methods are most usefully applied when comparing alternative designs or solutions for particular applications. They are typically applied for rating system designs rather than operating systems.

3.4. Energy efficiency design issues Which refrigerant is the most energy efficient? What type of system/equipment/plant/configuration is the most efficient? Are there too many variables (climate, application, design, charge size, implementation, and costs) to make meaningful comparisons? Due to the many variables a total-‐system comparison needs to be made, especially as incrementally smaller gains in energy efficiency become more important. However, there should also be simpler guides/rules of thumb that can be followed during earlier stages of a project.

The consideration of the energy efficiency of a system is a complex area that covers the whole life-‐cycle of a system and needs to be considered during design, installation, commissioning, operation, and maintenance.

3.4.1. Energy intensity Most designers focus on energy efficiency, with only a few considering how to reduce system loads first. Assessing buildings and systems with a view to reducing heating and cooling loads prior to HVAC&R design is a key function of the low-‐emission designer. Identification of load-‐reduction opportunities is particularly important during the review and upgrade of existing buildings, systems and applications where non-‐HVAC&R energy interventions (sealing, shading, insulation, lighting etc.) should be investigated prior to, or in parallel with, upgrading HVAC&R systems.

3.4.2. Rating A system’s efficiency relates to the efficiency of it parts, i.e. the plant, components, controls, construction quality, operation protocols, maintenance protocols and the environment within which it operates. There are various ways of rating both systems and individual plant items.

TEWI – As above, TEWI rates a system’s environmental performance, including its whole of life energy use, but necessarily uses many assumptions and simplifications. TEWI does not address embodied energy.

Load estimation programs – There are many software programs available to estimate or model the loads on a system. It is unclear how up-‐to-‐date the default data in the load estimation programs are.

COP/IPLV/NPLV – Coefficient of performance (COP) and integrated part-‐load value (IPLV) testing and rating of plant are very useful energy efficiency indicators; they are generally determined for new plant in simulated/laboratory conditions. (COP and IPLV are also termed EER and IEER). There



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can be confusion between tested and verified equipment COP values and eventual system COP outcomes, which are often very different. IPLV, which is a measure of the efficiency of the equipment at part load, is also not fully understood or applied correctly by some engineers and building/system simulators. If plant is designed to operate at different conditions than specified in IPLV, including lower water temperatures or different flow rates, the efficiency is called a NPLV (non-‐standard part-‐load value).

There are also reports of misuse of the IPLV and IEER equipment ratings to represent the same as that of a system rating. IPLV and IEER are descriptors of the standard part load efficiency for a single piece of equipment. System efficiency requires comprehensive analysis of whole system components such as pumps, fans, plant utilisation, control strategies, plant layout, climatic conditions etc. IPLV ratings are not intended to be used to estimate energy consumption of a plant or even a piece of equipment for a specific installation.

MEPS – MEPS Standards are regulated by product and sector; regulations target the poorest performing product. MEPS typically represent minimum standards, not best practice, and are applied to new plant in simulated/laboratory conditions. MEPS do not cover engineered solutions or custom designs.

Energy labels – mandated testing rate appliances based on the appliance energy efficiency and consumption.

Calculating Cool – A project under HVAC HESS (under review) to develop an independent metric or benchmarking tool to produce a generic HVAC system performance indicator.

3.4.3. System capacity The fact that HVAC&R systems tend to be oversized has long been recognised as an issue in many sectors of the industry, including residential and commercial air conditioning and commercial refrigeration. Oversizing often results in an energy penalty as chillers, cooling towers, condensers, fans and pumps operate inefficiently, systems are throttled (restricted) with valves and dampers. Equipment maintenance and failure rates are high. Oversized systems tend to result in a higher energy consumption, increased wear and maintenance and reduced service life. Oversized systems also tend to be less effective at providing the HVAC&R service than a correctly sized system.

There are many reasons driving this tendency to oversize plant and systems including the use of sometimes highly conservative “rules of thumb” design assumptions, the excessive application of safety factors, insufficient or inaccurate design information, a requirement for flexibility in future use or future expansion, building grading systems that require redundancy in the plant, the linkage between project value and fees or profit margins, and the tendency to move up in size when selecting equipment to provide some level of insurance or risk management with regard to system capacity.

End-‐users want systems to operate on the hottest days and, in some cases, users’ expectations may need adjusting.HVAC&R specification and design practices may need to change particularly in the



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light of increased building thermal performance and sealing standards, reduced loads from lighting systems and plug-‐in equipment, reduced loads from system equipment, and the introduction of passive design techniques to reduce heating and cooling requirements.

3.4.4. System design Some designs are more energy efficient than others; however, the question of first cost versus LCC are rarely considered or if they are, good LCC decisions are “value engineered” out of a project at tender/construction stage, due to high discounting of future operating costs or split incentives. How do we ensure that original designs actually get implemented? Often owners and developers are not fully aware of the efficiency difference in the value engineered result versus an original energy efficient design. Education is important.

Owners and developers control overall capital expenditure for HVAC&R. Within these capital limitations, designers and installers often control the potential system operation or life-‐cycle costs. In many sectors the system design and installation decisions are based on purchase and installation cost, with little thought to operational cost aspects. In the residential sector home owners and developers often select based on lowest purchase cost.

System design decisions – Variable refrigerant volume/flow-‐based systems have become popular in commercial air conditioning applications and these systems tend to have a high cumulative refrigerant charge. High-‐charge HFC based systems now contain significant financial and environmental risks due to potential leaks. In response, there may now be a move back to central chillers using secondary coolants and so limiting all refrigerant to the plant room. Alternatively the design response may be to use multiple small and independent systems distributed throughout a space. Multiple small systems can introduce control and energy efficiency issues if not designed and implemented correctly, and may increase maintenance logistics.

Systems and components – using a highly energy-‐efficient component (compressor or chiller) in a poorly implemented system will still lead to poor energy-‐efficiency outcomes. Designers and installers must take a holistic approach to system design for true energy efficiency to be achieved. The focus should be on constructing efficient systems out of efficient components and realising that plant or equipment efficiency rating is only one component in overall system efficiency puzzle. Other important components include

• Application – thermal efficiency of the building or space, and process and practices undertaken by occupants and operators

• Distribution – leakage in ductwork systems, unnecessary resistance within distribution systems, inefficient sizing and routing of distribution lines

• Controls – system operating to design intent and within design parameters.

3.4.5. Heat rejection The selection of the method of heat rejection for HVAC&R systems is an important aspect of system design and energy use. Options for heat rejection typically include wate-‐cooled, air-‐cooled or a hybrid dry/wet system.



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Historically, many of the larger systems used evaporative cooling, with water cooling towers and evaporative condensers. However, in an attempt to minimise exposure to microbial-‐based health risks (Legionella sp.) and the associated costs of managing those risks, there has been a shift in some sectors to air-‐cooled systems.

There is generally an energy penalty for large air-‐cooled plant and a water penalty for water-‐cooled plant, although this can be reduced or optimised by using hybrid systems and dedicated control algorithms. Alternative heat-‐rejection sinks include ground, lake, ocean and river-‐based systems.

The micro-‐climate within which air-‐cooled equipment operates is also a significant issue. Cool roof designs and shading systems can reduce the operating temperature and improve the heat rejection of roof-‐mounted equipment.

Water cooling towers and evaporative systems can become inefficient energy users in high-‐humidity and high-‐temperature conditions (when wet and dry bulb temperatures converge and the energy consumption of the equipment exceeds the heat rejection saving. Cooling towers and the water consumption of evaporative cooling devices is increasingly being considered by Australian water authorities who are looking for ways to reduce water consumption. The rising cost of water consumption also needs to be considered by designers.

The relationship between energy and water consumption, also known as the “water-‐energy nexus”’ is highly relevant to the HVAC&R industry. While energy use and the resulting carbon emissions receive much of the focus, water is also a key input in many systems and potable water also requires energy for its collection and distribution.

The cost of water and energy differ considerably, with energy being more expensive. Therefore, cost should not be the sole determining factor when comparing water-‐cooled and air-‐cooled systems. In this circumstance a small energy use reduction from increased water use will outperform a large decrease in water use with a small increase in energy use.

This may be appropriate in some circumstances; however, it is important to remember not to trade one problem for another. Prioritising energy use ahead of water use due to the associated carbon emissions will negatively impact the creation of holistic HVAC systems. Both water and energy use in HVAC systems can be reduced simultaneously, through recognising the water-‐energy nexus that exists within HVAC systems and researching and innovating accordingly.

Furthermore, using more energy downstream via an air-‐cooled system indirectly increases the need for water cooling at the (largely) thermal power stations producing energy upstream. It is important to take a whole-‐of-‐system approach when calculating the true reductions in energy and water via the installation of an air-‐cooled system.

3.4.6. Heat recovery A related issue is the potential of heat recovery, or making use of the waste heat from systems. Technologies now exist that can turn waste heat into useful energy, including cooling energy. Waste heat is often generated by motors and compressors, electrical equipment and industrial processes,



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and can be reused on site. Heat energy is rarely transportable over long distances but can be stored, or converted to other types of energy.

There are many opportunities for recovery and reuse of waste heat in HVAC&R, particularly in large commercial and industrial refrigeration systems. The HVAC&R industry needs to up-‐skill on methods and technologies to ensure that this energy efficiency opportunity is fully realised.

3.4.7. System installation The quality of installation of the HVAC&R system design can also have a significant impact on the energy use and emission levels. There are a range of installation errors that can impact on the system performance. An example of poor quality installation methods impacting system performance is the level of leakage from installed ductwork. Industry reports that ductwork leakage rates are highly variable and are generally unknown until after installation has been completed. Retrofitting solutions can be complex and expensive. Ductwork leakage is reported as a significant issue in both new and existing buildings.

New standards and regulatory requirements are being introduced to address unacceptable levels of ductwork leakage.

3.4.8. Infiltration and building sealing Infiltration is the uncontrolled movement of outdoor air into a building, exfiltration is the uncontrolled movement of internal air out of a building. The extent and effects of infiltration or exfiltration is poorly understood or evaluated within the HVAC&R industry and among users of HVAC&R services. Therefore attitudes to this issue vary widely. There is a significant variability in building envelope infiltration rates and the effects of these rates are more important in some building types and climates than others.

There is a lack of understanding of how infiltration rates are affected by internal pressures from HVAC systems and by external pressures from wind and solar energy. A lack of understanding generally means the issues will be largely ignored or very roughly addressed in designs.

The way that building infiltration is dealt with in building energy modelling and building/system performance simulation also needs to be better addressed. Different models or protocols allow for different approaches to infiltration air and there needs to be harmonisation of practices.

3.5. Energy efficiency operational issues

3.5.1. Operation We can’t talk about system energy efficiency without talking about operation. Who operates, for what purpose, and to what environmental and safety standards? What about the role of the educated facilities manager or building engineer? Facilities management involves the management, maintenance and operation of Australia’s built environments. As such, facilities management professionals play a central role and responsibility in ensuring HVAC&R systems are maintained and operated effectively.



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Occupant behaviour is also a big part of the operation picture. Does education and awareness have a role to play? Well designed and installed systems are often not operated to their full potential. Occupants should understand the basic intent of the HVAC&R system, even if it is fully automatically controlled, as they can still be affected by occupant behaviour.

The majority of operational procedures and guidelines have traditionally focused on comfort, but more emphasis on energy performance of HVAC&R and related building systems is needed to ensure energy use is minimised. Designs should cover correct automatic control, sensors and set-‐points, so the main energy efficiency aspect of operation is the monitoring and maintenance roles.

Design is based on many assumptionsthat are usually made long before a system is ever turned on. Commissioning attempts to deliver the intent of a system’s design. Providing the original design has been implemented well and the building use is in general accordance with the design, then continual fine tuning is where the operational efficiencies can be maximised.

3.5.2. System control The issue of system control is often inadequately considered in designs or poorly implemented in installation. Poor system control will lead to poor energy efficiency outcomes. There are sophisticated control algorithms available enabling system feedback and control reset or floating control points as opposed to fixed set-‐point control.

Control and operation interfaces between equipment and end users are also very significant. A lack of user friendliness or flexibility in control systems can undermine correct or efficient system management.

Optimal supervisory control strategies are emerging that could provide the key to significant energy savings and more optimised HVAC&R systems. However, supervisory control strategies are often complex, hard to understand and even harder to implement. In order for a greater uptake to occur the industry needs practical guidelines on the supervisory control strategies that are available, the buildings/systems they are best suited to, and examples of practical implementations.

3.5.3. System documentation A constant complaint by building and system operators, maintainers, and auditors is the lack of system documentation available for existing systems. As installed drawings, detailed results from commissioning tests, design intent information, design calculations, system assets lists and monitoring of system key performance indicators are all reported to be poor within all sectors.

It is clear that there is a failure occurring in the system documentation chain. There is no industry standard specifying what information should be captured during the lifecycle of a building or system. The impediments to the collection, management and retention of this information have not been identified or resolved. For instance there is a poor understanding of:

• The role of documentation in system/building management for energy efficiency • What information is needed • What is currently supplied



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• Who should be responsible • What represents a minimum standard or best practice.

Many buildings used to retain (if not update) building information but many managed buildings no longer keep the records and nor do the designers and contractors. Legislating record retention by the building owner and at times of sale could go a long way to addressing this. Chain of custody for documentation and a log book for the building lifecycle were projects identified under the HVAC HESS strategy.

3.5.4. Monitoring Energy management planning is now a key facility management tool. How systems are designed to facilitate these processes (usually metering) is of increasing importance. Metering, sub-‐metering and thermal metering are major considerations for performance monitoring.

Monitoring a system is the first step toward managing a system. In terms of refrigeration and air conditioning emissions, the most important aspects to monitor are energy use, water use and refrigerant leakage. In terms of predictive and preventative maintenance monitoring there are a range of system key performance indicators that can be monitored to ensure optimum operation.

Installing sub-‐metering can provide real time energy usage information, providing operators information on how individual plant is performing. Linking these meters to an automatic control and management system enables the system to automatically respond to energy use.

Effective monitoring is fundamental to achieving and maintaining energy efficiency. Methods to cost-‐effectively monitor system efficiency should be made available to end user operators. In many cases operators don’t have the technical ability to understand even the basics of system performance and operation.

Measuring, monitoring and adjusting performance can be complex and costly, and often seen as an expense rather than a cost saving. Justifying the costs to operators would be a start, then simple easily accessed “how to” guides could be created and made available.

3.5.5. Maintenance The NCC contains mandatory maintenance requirements for buildings and AIRAH DA19 and the HVAC HESS Operation and Maintenance Guide provide good practice and best-‐practice maintenance information. In the HVAC field the primary Standards requiring system maintenance include AS 1851 (fire and smoke control) and AS/NZS 3666 (microbial control).

In the refrigeration field the Australia and New Zealand Refrigerant Handling Code of Practice sets a standard of maintenance for fluorocarbon refrigerant-‐based systems. AS/NZS 1677.2:1998 contains requirements for charging and discharging refrigerants, documentation of operating and maintenance protocols and the personal protective equipment that may be required. It does not cover maintenance procedures per se.



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The standard of maintenance applied to many existing air conditioning and refrigeration systems is reported as poor, ranging from non-‐existent to minimum maintenance regimes. Maintenance is often not procured correctly, and there has traditionally been a poor maintenance culture within the HVAC&R industry.

Maintenance for energy efficiency is not typically practised. It is also not a primary focus in the delivery of TAFE training. The HVAC HESS Maintenance Guide for commercial buildings was created as a driver for improved practices in this area within the commercial building sector. Maintenance for low-‐emissions and leak minimisation has also not historically been a high priority for owners or operators.

The reasons for these maintenance failures are many, and include reluctance on the part of end users to pay the cost of maintenance and a lack of enforcement of government regulations regarding regulated maintenance for energy efficiency (e.g. NCC BCA Section I). The definition of intentional refrigerant leakage may be unclear to owners and operators. If a system leaks a large amount of refrigerant over time this can be discovered, documented and mitigated. The starting point is education and enforcement.

Another issue is that the access and facilities provided for the maintenance of systems is often inadequate. Examples include coils and fans that cannot be reached, where equipment is roof mounted with no safe or WHS compliant access, or where internal plant is installed at high level without access platforms, and where no lighting, power or drainage facilities are provided for maintenance activities.

The design trend for multiple distributed systems as opposed to central systems may be driven by a desire to reduce or diversify maintenance responsibilities. However, the effect of this trend on overall site energy efficiency should also be considered because a move from central to distributed systems often has an energy-‐efficiency or energy-‐use impact.

What does maintenance for energy efficiency look like? – Example activities include assessing actual refrigerant charge against design refrigerant charge, cleaning heat-‐transfer surfaces, review of the installation for deficiencies, sealing of the building envelope and system ductwork, review of design assumptions and calculations for validity, recalibration of controls, logging, and ongoing analysis of monitoring information (energy use, refrigerant leakage rate etc). Some trials undertaken in Australia illustrate that a professional clean of fins and coils of a two-‐year-‐old split system in a commercial property improved energy efficiency by over 30%.

What does maintenance for leakage minimisation look like? Example activities would include an audit and review system, with follow-‐up rectifications and the set up of an ongoing monitoring system (automatic or log based). What should be done to raise the level of awareness and commitment of end users to minimise leakage? It should be possible to identify sources of high-‐ volume leakage via contractor logs. Is this done? Should it be done, and if so by whom? Should end users be held responsible?



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The most important aspect of operation is maintenance for performance, monitoring the degradation over time and ensuring it does not fall below an industry benchmark. Maintenance for energy efficiency and leak minimisation needs to be better defined. The cost-‐benefit outcomes need to be transparent and meaningful.

3.5.6. Upgrade or replacement The cost of repair and maintenance of smaller air conditioners using high-‐GWP refrigerants will increase and it may be more cost effective and energy efficient to replace than repair these systems. Costs will depend on the age and current condition of the system and the type of refrigerant used.

There are many situations where retrofitting makes sense but the process requires standards and training. Even the term “retrofitting” means different things to different people in different sectors. Retrofitting offers a large opportunity for energy efficiency, and the industry needs to better understand when and where (by sector) retrofitting is an appropriate response.

Equipment manufacturers emphasise that because equipment is designed to operate using a specific refrigerant, such equipment should not be converted to operate on a different refrigerant unless the manufacturer has approved the conversion. Unauthorised retrofitting to a different refrigerant will void equipment warranties, but more importantly may involve serious occupational health and safety risks if not implemented correctly. In many cases the issues relate to concerns regarding potential liability due to an implied approval of flammable refrigerant rather than technical problems with the equipment.

There are quick payback times available for energy-‐efficiency interventions in many sectors. While this includes the so-‐called “low hanging fruit” it also includes other interventions and specific proposals need to be evaluated individually.

In the energy efficiency intervention market SME clients are reportedly looking for a simple payback period of two to three years although this can be extended if assistance funding is available. For larger projects and more informed clients the simple payback method may be oversimplified to provide realistic advice. A true ROI calculation based on NPV or IRR needs to be completed to provide an accurate assessment of the costs and benefits.

The availability of skilled individuals and companies who can audit a system, identify a range of improvements, cost the implementation of each improvement, quantify the resulting energy savings and calculate the payback period or other ROI assessment is very limited. The skill sets required for these practices require both training and practical experience with systems design and installation as well as an ability to take a holistic view of systems and sites.

Replacement of old, inefficient, or high-‐GWP systems will most likely be based on a financial and risk analysis, with solutions developed suited to the scale and risk of the application. Where large commercial or industrial air conditioning and refrigeration applications have leak detection and maintenance regimes in place and are reasonably energy efficient, there should be no immediate



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need to upgrade or replace the system. Individual systems will need to be assessed and the risks quantified.

3.6. Low-‐GWP refrigerants

3.6.1. What are low-‐GWP refrigerants What do low-‐GWP refrigerants look like? There is currently no internationally or nationally accepted definition of what low-‐GWP means. Natural refrigerants such as ammonia (GWP of 0) and hydrocarbon-‐based refrigerants (GWP of 3 to 20) have low-‐GWP numbers; CO2 (the GWP reference) is also used as a refrigerant and has a GWP of 1. There are also some low or reduced-‐GWP synthetic refrigerants or blends of refrigerants available. The GWP of the synthetic refrigerants controlled under the Kyoto Protocol range from 150 to many thousands.

3.6.2. Barriers to low-‐GWP refrigerants Low-‐GWP refrigerants not covered by the ozone protection and synthetic greenhouse gas management legislation are not subject to an equivalent carbon levy and so are provided with a significant commercial advantage. However, there are many barriers that remain to the adoption and acceptance of low-‐GWP refrigerants including:

Concerns about safety – many of the low and reduced-‐GWP refrigerants have safety implications including:

• Ammonia (toxicity and flammability) • Hydrocarbons (flammability) • CO2 (operating pressures) • New-‐generation synthetics (flammability and products of combustion) • New reduced-‐GWP synthetic blends (flammability and products of combustion).

Both the trade and end users have concerns regarding these safety issues, which need to be fully addressed by the industry. For example, the safety measures that have been taken by industry in order to raise the safety record of ammonia applications to high levels need to be communicated clearly and widely.

Lack of industry knowledge – the industry has been heavily reliant on high-‐GWP synthetic refrigerants in many sectors for many years. Natural refrigerants and new low-‐GWP synthetics contain different safety and handling issues or risks and different technical application protocols. There are significant knowledge and understanding gaps that need to be addressed, as well as changing attitudes and raising awareness of safe methods to use natural refrigerants. Just knowing where to go (and who to trust) to obtain information on alternatives can prove difficult, the information may already be available, but the potential client or contractor is often unaware of its existence. There is a lack of validation of natural refrigerants claims and a lack of industry capability to provide such validation.



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Commercial barriers – refrigerant supply (for commercial and domestic HVAC&R) has for decades originated from synthetic refrigerant manufacturers. As with any industry that is dominated by a few large players, the supply of alternative products and information faces numerous practical and commercial barriers, which can slow the adoption rate of alternative solutions.

Lack of consumer knowledge – consumers often lack appreciation for the role HVAC&R equipment plays in terms of total energy consumption and environmental emissions. Even if they do appreciate these factors they are often unaware of low-‐GWP and energy-‐efficient alternatives.

Work health and safety conflicts – there is a potential conflict between WHS Acts and Regulations and the application of some natural low-‐GWP refrigerant-‐based solutions.

Lack of awareness of the energy efficiency benefits – many low-‐GWP refrigerants provide superior operating efficiency (all other things being equal). However, this is not well understood or appreciated within the industry or by the end users who pay the system operating costs.

Regulations – local regulations also sometimes exclude low-‐GWP refrigerant-‐based solutions, (e.g. ammonia based systems excluded by local government regulations).

Capital cost – many low-‐GWP refrigerant-‐based solutions are more expensive from a capital cost perspective when compared to traditional refrigeration solutions. Due to safety risk management systems employing ammonia, carbon dioxide and hydrocarbons are typically built to higher quality and engineering standards than fluorocarbon based systems. Life-‐cycle costs for these systems are often lower than the traditional system however high initial capital costs are a barrier to adoption particularly for non owner procurers and small and medium enterprises.

3.7. Refrigerant containment issues It is clear that the traditional attitude to HFC refrigerant leakage within the industry and by end users is changing and the equivalent carbon levy should reinforce this culture change. Leak management, refrigerant containment and refrigerant handling protocols are an issue across all refrigerant types and all sectors. Preventable leaks pose safety and environmental risks and should be minimised for any refrigerant.

The risks associated with leaks are different for different refrigerant types and include toxicity, flammability, asphyxiation, pressure rupture and environmental degradation. The risks arising from leaks are also different depending on the category of the occupancy, (residential, commercial, institutional, industrial) and the context in which the leak occurs, public or private, community or occupational, voluntary or involuntary occupants.

However, all jurisdictions and all sectors agree that leaks are bad – bad for safety, bad for the environment and bad for energy efficiency. Leaks increase operational costs to industry. Intentional leakage is illegal and the fact that this could include known and predictable leakage needs to be recognised by owners and operators.



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Operational leakage control and end-‐of-‐life plant leakage are fundamental issues, minimisation of direct refrigerant emissions is essential. Existing regulations are in place and this may simply be an enforcement issue. The increasing costs of many HFC refrigerants should refocus owner and operator efforts in leak minimisation and this was a stated intention of the equivalent carbon levy.

3.7.1. Construction standards Construction standards and the quality of installation have a significant impact on the likelihood of refrigerant leakage from any given system. Current standards of construction are based on:

• The Australia and New Zealand Refrigerant Handling Code of Practice – which applies to systems containing fluorocarbon refrigerants (parts 1 and 2).

• The Australian Automotive Code of Practice – applies to the control of refrigerant gases during manufacture, installation, servicing or de-‐commissioning of motor vehicle air conditioners.

• AS/NZS 1677.2 – covers the installation of pipework, joint standards, vibration, liquid hammer and pressure tests from a safety perspective.

Skills, training, licensing and audit/enforcement are all interlinked with the construction standard/installation quality issue. No minimum or best-‐practice standard will be adhered to in this cost driven industry if the training is not based on the standards and the standards are not enforced in the industry.

Many of the recommended design and construction practices for leak minimisation are recommendations only and are not mandated. For example, in the Australia and New Zealand Refrigerant Handling Code of Practice Part 2, welding, brazing or another permanent hermetic sealing method are recommended for joining refrigerant pipelines since they offer increased resistance to pressure, temperature and vibration stresses. It is recommended that flared, screwed or flanged connections should be avoided.

Flared connections, flexible hoses and Schraeder valves are among the typical components that industry states are responsible for many of the refrigerant leaks that occur in many systems (http://www.environment.gov.au/atmosphere/ozone/sgg/equivalentcarbonprice/publications/pubs/refrigerant-‐emissions.pdf).

The following table is taken from the AIRAH fact sheet on leak minimisation, outlining the strategies/changes need to be adopted by industry to prevent refrigerant leakage

Designers and Installation Contractors Maintenance Contractors

Put leak reduction as a high priority in design and installation activities (minimise joints and fittings)

Put leak reduction as a high priority in maintenance

Use recognised design standards and Codes of Practice, design to reduce refrigerant charge, i.e.

Create refrigerant log, monitor and record leakage, report to system owner, set maximum leakage target



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shorter pipe runs, high efficiency coils, levels based on system age/size, aim for zero leakage.

Specify and install capped valves, including capped Schrader valves (if they are unavoidable)

Ensure technicians know how to leak test effectively and provide appropriate test equipment.

Protect pipework from mechanical damage by appropriate routing and installation. Use correct pressure rating for pipes and fittings.

Calibrate and maintain the necessary leak detection and repair tools. Routinely review systems for leaks and potential leak sites and advise the owner.

Only use high standard welded or brazed joints, No flared connections.

Help system owners and operators understand the imperatives for leak management

Eliminate vibration in the system, isolate pipework from plant, restrict liquid hammer, support valves and fittings independently

Be prepared to advise system owners on potential system energy efficiency improvements and upgrades including associated costs and savings.

Install leak detection, alarms and charge retention facilities appropriate for the refrigerant charge

Ensure that all system modifications comply with the latest design standards and Codes of Practice

Protect pipework, condensers, evaporators and other system components from corrosion failure.

Update service contracts to include for leak detection and refrigerant management

Label the system including refrigerant type and optimum refrigerant charge. Document “zero” leakage practices in O&M manuals

Be prepared to advise system owners on low-‐GWP upgrade options for existing HCFC systems and high-‐GWP HFC systems.

Fully pressure test and commission the refrigeration system, insist on vacuum and pressure testing, with witnessed sign-‐off sheets.

Monitor systems for leakage and energy efficiency and report results to the owner. Recommend sub meters and monitors to record system energy usage

Only use licensed and qualified design, installation, operation, maintenance and service personnel

3.7.2. Leak-‐containment technologies There are technology-‐based solutions to improve refrigerant containment or reduce refrigerant leakage volumes in the event of a catastrophic system rupture, component failure or other leak event. Typical solutions include solenoids to protect likely refrigerant reservoirs in the system, and automatic pump down arrangements where refrigerant is moved to and stored in a designated area of the system when a leakage is detected. These systems can provide safety and environmental benefits.

Not all refrigerant pump-‐down systems work in the same way, and not all provide the results that were originally anticipated. Some commentators believe that a refrigerant alarm detector, which prompts the operator to call a qualified service technician to investigate, may be more effective and practical in a commercial environment than an automatic pump down system.

The engineering solutions to leakage need to be specified, assessed and validated, by refrigerant type, sector, and application.



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3.7.3. Leak-‐management practices To date, responses to system leaks have been largely reactive. In order for leak-‐management practices to improve they must become more proactive. There is a real need to have owners “buy in” to good practice/best-‐practice proactive leak-‐management techniques. The equivalent carbon price levied on high-‐GWP refrigerants is intended to provide an incentive for improved leak management by introducing high replacement costs for high-‐GWP based refrigerants.

However, owners and operators and service personnel all need to understand what good proactive leak-‐management practices really mean.

Leak-‐management practices should include:

• Regular audits of the system for leaks and potential leak sites – there are no standardised procedures or guidelines covering system audits for this purpose.

• Periodic leak testing to support the system audit approach – suitable leak testing methodologies exist but no guidance is available on their application; i.e. what systems should be tested and how regularly, what leakage test is applicable to which application.

• Maintenance of a refrigerant log for every system – Contractors are required to maintain refrigerant logs for SGGs.

• The installation of permanent leak detection on some systems either operating alarms for manual responses or activating automatic leak-‐containment strategies built into the system.

System design and installation practices mirroring those that are in use in modern ammonia installations have the capacity to reduce annual refrigerant leakage rates to <1%. Adopting these design and installation practices for high-‐GWP synthetic refrigerants would have the capacity to reduce average leakage rates in Australia to a similar level.

Owners will only absorb these costs if they are educated about the benefits of leak management and the commercial and regulatory risks of not managing these issues.

Some sectors would need special provisions and revised operational practices in order for regular leak detection to be carried out (e.g. commercial refrigeration in supermarkets).

3.7.4. Automatic leak detection AS/NZS 1677.2 covers automatic leak detection, but typically only in plant rooms and special machinery rooms for safety and alarm purposes. Automatic leak detection for leak-‐minimisation purposes is not commonly practised throughout the industry, i.e. it is a best-‐practice approach as opposed to the industry norm. With the advent of the equivalent carbon price for high-‐GWP refrigerants and intended market shift to low-‐GWP refrigerants, leak detection systems are more likely to be cost effective due to the increased value of the refrigerant and for risk management purposes.

Note: AS/NZS1677.2 is not a mandatory requirement of the NCC.



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3.7.5. Charge reduction There are also opportunities to reduce refrigerant charges within refrigeration equipment. These opportunities include new heat-‐transfer technologies, including mini-‐channel and micro-‐channel applications.

Some systems are overcharged by 10% to 20% to improve the persistence of optimum performance, by accounting for some leakage. The intention of this overcharging is that system performance may not degrade until the system has leaked more than say 20 to 30% of charge. After that point further leakage rapidly reduces system performance.

3.7.6. Tracking refrigerant emissions HVAC&R users report that quantifying refrigerant leakage from existing air conditioning and refrigeration systems is problematic. The level of difficulty to measure or compile this data by far exceeds the relative level of emissions (typically around 1%). Estimating is one approach; measurement is another. Owners and operators typically do not have the skills or tools to accurately measure direct refrigerant losses.

End users who are required to track their GHG emissions would appreciate a standardised spreadsheet listing common air conditioning units, the type of refrigerant used, the refrigerant charge they hold, and their typical leakage rate. This information is not currently included under the NGER scheme.

3.8. Product stewardship An associated issue with leak management is the whole question of product stewardship within the HVAC&R industry supply chain. Better control of direct refrigerant emissions is also required at plant end of life. Where real product stewardship applies, refrigerant emission avoidance is enforced.

Product stewardship is also not just about end of life. The concept of extended producer responsibility is for whole of life as well as end of life. Product stewardship is through life product management aiming for better environmental and commercial outcomes during production, operation, and eventual disposal.

3.8.1. Refrigerants Refrigerant recovery – Recovery of CFC, HCFC and HFC is a legislated requirement, knowingly venting these refrigerants to the atmosphere is environmentally damaging and an offence under the Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (the Act). The Ozone Protection and Synthetic Greenhouse Gas Management Regulations 1995 specify that the refrigerant recovery process must be undertaken by a licensed person and the recovered refrigerant can only be recovered, stored and disposed of by an authorised business.

Refrigerant reuse/recycling – With the advent of restrictions on CFC and HCFC import and the imposition of the equivalent carbon price on high-‐GWP HFC refrigerants the reuse of refrigerants is becoming more widespread. In many instance a recovered refrigerant can be recycled for reuse in another system. Rising prices should be providing a significant incentive for this practice. However



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the recycled refrigerant needs to be free from contamination, i.e. removal of oil, acid, water and particles from the recovered refrigerant.

AHRI 700 – 2012 Specification for fluorocarbon refrigerants is the accepted global standard for refrigerant purity. The Australian Code of Practice requires all fluorocarbon refrigerant sold to meet this standard, whether it is newly manufactured, recycled, or reclaimed.

Refrigerant Reclaim Australia (RRA) encourages contractors to recover, recycle and reuse refrigerant of acceptable quality, and to return all unwanted and contaminated refrigerant for safe disposal. It provides rebates for collected ozone depleting and synthetic greenhouse gas refrigerants and operates a national collection service, which transports recovered refrigerants to a central, secure storage facility where they are processed or destroyed using cost effective, environmentally safe technology.

Flammable refrigerants – The advent of flammable refrigerants, currently A3 hydrocarbons but in the future A2L refrigerants such HFO1234yf and HFC32, will present major challenges for the recovery infrastructure currently in operation.

Note: ASHRAE standards have included an optional 2L subclass to the existing Class 2 flammability classification, signifying class 2 refrigerants with a burning velocity less than or equal to 10 cm/s.

Refrigerant containing product at end-‐of-‐life – Australia has a world-‐class refrigerant product stewardship program developed and managed by RRA. The recovery rate achieved in Australia is exceeded only in Japan. There, the higher rate of recovery achieved is due to legislation that requires the end-‐of-‐life recovery and proper recycling of consumer durables such as refrigerators, air conditioners, and motor vehicles. These product stewardship programs are focused on the equipment and the refrigerant is recovered in the process of recycling those products. Similar programs exist in Europe.

When air conditioners and refrigeration appliances are retired at the end of life there needs to be an incentive for (someone to) extract the refrigerant contained within it either before or at the point of recycling. Refrigerant emissions at end-‐of-‐lifeproduct recycling stations (vehicles, refrigerators, air conditioners) are not currently enforced in Australia, but they should be to be consistent with Government legislation.

Refrigerant destruction – Refrigerant that can be reused or recycled should never be destroyed. Where refrigerant is too contaminated for reuse it must be safely destroyed. Current destruction system capacity is sufficient to meet current and medium term needs in Australia.

The Australian government is currently investigating and developing a Destruction of Waste ODS and SGG Program. This is being undertaken in consultation with industry and key stakeholder groups. A consultation paper has been issued seeking comment on how a government-‐funded destruction incentives program might operate. Comments provided in response to the paper will inform development of the program.

http://www.environment.gov.au/atmosphere/ozone/destruction-‐program/index.html



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3.8.2. Plant and equipment Product stewardship is not just about refrigerants, there are other materials in HVAC&R equipment that need to be addressed in addition to refrigerants, including blowing agents and toxic electronic components.

Decommissioned HVAC&R equipment also contains valuable metals that can be recovered and resold so there is a business opportunity here.

3.9. Research, development, innovation and commercialisation Research, development and innovation are all linked to the higher education question. Good higher education relies on a strong research and development capacity. Excellence in research and development relies on a strong education framework. Innovation and commercialisation relies on both. All of these areas are critical in any transition to a low-‐emission HVAC&R industry.

Current research and development activity within the Australian HVAC&R field is low although there are some notable exceptions.

3.10. Workforce development Workforce development generally covers the various steps in the development and delivery of a workforce that can deliver a required outcome. This can be considered either nationally, across an industry sector or within an individual enterprise. Workforce development can be characterised by the following steps:

1. Business planning – what are the goals for the business?

2. Workforce definition – what sort of workforce is needed to meet those goals?

3. Workforce analysis – what are the skills of the workforce defined in 2?

4. Current skills held – what are the skills held by current workers?

5. Identification of skills gaps – subtract 4 from 3

6. Fillings identified skills gaps – by up-‐skilling existing workers, recruiting existing skilled workers, or up-‐skilling recruited workers.

For individual enterprises and industry sectors careful implementation of this process is needed to adequately and appropriately respond to workforce changes. The effective transition of any enterprise to low-‐emission s practices and technologies must involve consideration of the requisite skills and training requirements.

The National Workforce Development Fund (NWDF) is an innovative, industry-‐driven model that enables businesses to co-‐invest with Government to train, reskill and upskill workers in areas of skills needs. The NWDF is overseen by the Australian Workforce and Productivity Agency.



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3.11. Skills and training issues Any effective transition must give consideration to the requisite training requirements. The best way to develop the necessary contemporary competencies and to crystallise, in a permanent way, the sorts of behavioural change needed, is through focused well delivered training.

A common theme or issue, with deep ranging impacts, raised in all sectors of the HVAC&R industry is the lack of education and training on a range of HVAC&R related issues. The Australian Government and community are asking the industry to deliver on emissions reduction at a time when the industry is experiencing significant skills shortages at trade and tertiary level and when funding to the TAFE/VET sector is being reduced

The extent of education and training programs in Australia targeting energy efficiency and direct and indirect emissions reduction is poor but improving. New competencies have been developed (or are in development) but these is a considerable ‘lag’ period as new training resources are developed to match the competencies, courses are updated and trainees pass through those courses. It is clear that if the industry is to make a transition to low-‐emission practices and technologies there needs to be considerable up skilling of personnel at all levels and in all sectors. Even with better training courses for technical service providers the incentive is often not there as clients are more often cost driven. Education activities need to also be targeted outside the industry including owners, operators, end users and occupants.

The retention of trained and knowledgeable staff within the industry is also a challenge.

A common complaint among stakeholders is the lacking Australian industry skill set leading to:

• A general lack of high-‐quality design engineering in the HVAC&R industry driven by a lack of engineers. Are there enough degree qualified HVAC&R engineers in Australia?

• Poorly maintained plant and equipment (and consequential poor energy performance and excessive refrigerant leakage). Is maintenance sufficiently focused on in training?

• Equipment set-‐point drift – temperature set-‐point or other control modifications (e.g. time schedule changes) are occasionally the “corrective” actions of choice whilst intrinsic system problems remain unaddressed, sometimes for years. Is this attributable to a quick fix culture within the industry or is this a symptom of inadequately trained technicians or apprentices?

• Skill set shortage – there may simply be not enough adequately trained technicians in the country. Wages within this sector are higher than average (especially so for refrigeration mechanics) yet this has failed to increase the numbers of apprentices entering the market.

The refrigeration and air conditioning industry is on the preferential skill set list for migrants.

A common complaint among technical service providers is the lack of enthusiasm by end users and clients to pay for energy efficiency services. If the majority of stakeholders are not asking for skilled people or are not prepared to pay for the service, then the industry cannot afford to train and develop such skills. Stakeholders need to demand quality and monitor the performance of service



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providers and be prepared to pay for good service which will be cost beneficial in the long term. The key here is for service providers to prove the benefits of the service provided.

The mandatory status of maintenance is also an issue. For cooling towers and evaporative condensers there are requirements to prove that the system is being maintained by a professional licensed service provider, but this is not considered necessary for large complex air conditioning and refrigeration systems that can potentially use 20-‐30% too much energy if they are poorly maintained.

The number of apprentices is governed by the number of employers willing to employ and train them. Generally Government will fund apprentice training, especially in skills shortage areas, so the problem may not be the funding of training providers but rather the lack of industry/employer commitment to employ and train sufficient apprentices.

The biggest issue for tertiary training providers is numbers of “students”.

3.11.1. University training Currently in Australia there is no undergraduate engineering degree course dedicated to building services/HVAC or refrigeration. Currently engineers undertake electives in the topic under mechanical engineering degrees or learn their sector-specific skills on-the-job. Engineering degree programs in “Building Services” and “Refrigeration “are common in other countries and the Australian HVAC&R industry should engage with university level education providers on the possibility of, and process for, developing undergraduate degrees in these areas. Note: In Western Australia, Polytechnic West has an application for an associate Degree in Engineering (HVAC) which will focus on design.

3.11.2. VET/TAFE trade training Nationally recognised vocational education and training, provided by both public (TAFE) and private Registered Training Organisations, is based on the delivery and assessment of national Training Package qualifications and competency standard units. The national training system is intended to provide Australians with the skills needed to enter the workforce, re-‐enter the workforce, retrain for a new job, upgrade skills for an existing job, and to learn throughout their lives. The system is based on an Australian Qualifications Framework policy, a series of industry developed Training Packages, the Australian Skills Quality Authority as a regulator and the National Skills Standards Council (NSSC) and Industry Skills Councils who develop and endorse training packages.

There are range of certificate and diploma courses aimed at the refrigeration and air conditioning technician and apprentice. Some of these include:

• Certificate II in Split Air Conditioning and Heat Pump systems • Certificate II, III in Appliance Servicing • Certificate III in Electrotechnology Refrigeration and Air Conditioning • Certificate III in Engineering – Mechanical Trade (Refrigeration/Air Conditioning) • Certificate IV in Air Conditioning and Refrigeration Servicing • Certificate IV in Refrigeration and Air Conditioning Systems • Certificate IV in Air Conditioning Systems Energy Management and control • Diploma of Refrigeration Air Conditioning Engineering



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• Diploma in Mechanical Services Drafting • Advanced Diploma of Refrigeration And Air Conditioning Engineering

Having course competencies outlined at the VET level does not mean that there are corresponding detailed training technical materials (e.g. trainer/learner guides) available to assist course delivery. Training materials generally have to be developed by the training provider based on the specified course competencies, which does not incentivise the delivery of these new courses. Resources need to be allocated to review existing courses and ensure the development of new energy efficiency based training materials and subsidised training for both new industry entrants and existing workers.

These qualifications are not widely delivered by Registered Training Organisations to the HVAC&R industry due to relatively low student numbers and the lack of:

• State/territory government funding for post trade training delivery. • Suitably qualified and experienced teachers and trainers. • Specialised plant and equipment required.

However, these barriers could be overcome by: • Increasing industry awareness of these courses. • Working with State/Territory Industry Training Advisory Boards and Training Authorities to

ensure they are placed on Skills Shortage training lists for delivery funding. • Applying for National Workforce Development Funds for the delivery of the courses. • Utilising industry experts as teachers or guests lecturers for specialised areas. • Utilising specialised plant and equipment in the workplace.

There is a real tension between practical solutions-‐based training and in-‐depth fundamentals education and a perception in industry that many trade courses gloss over the fundamentals. There have been inadequacies reported in the VET/TAFE technician training program in addressing emissions mitigation. The focus tends to be on fault finding with a lack of focus on maintenance for energy efficiency or leak minimisation. VET/TAFE courses need to address energy efficiency and system optimisation as core training issues, not just as elective subjects.

Apprenticeships are a combination of on and off the job training. All employers who take on trade apprentices have to agree to and sign a training plan for the apprentice. Their part of the agreement is to ensure that the apprentice is provided with the breadth and depth of on-‐the job training to match the competencies in the training plan. In the end it is the employer that has to sign off on the final competency of the apprentice at the end of the training contract period. Generally there appears to be some detachment between employers, i.e. “Industry” and the people who put together the training and advise the ISCs.

The apprenticeship system will play a key role in providing the future workforce for energy efficiency and low-‐emission HVAC&R. This means there is a need for the industry to identify ways to encourage greater take up of training and jobs in the sector, for instance in the provision of career advice and engagement with schools to promote apprenticeships and other relevant education and training opportunities.



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Certificate III course curriculums are now full and any additional units or competencies would need to be met by Certificate IV and above courses.

There are few incentives, in most states, to encourage tradespeople to undertake post-‐trade or additional training. Generally employers don’t provide sufficient incentives for their employees to make this commitment. Subsidised training delivery can assist take-‐up. For government funded training the fee to the RTO is based on the student curriculum hours and any other additional fees and charges that the RTO requires. A typical funding ratio for a Certificate IV would be approx 16 students, if numbers are less then generally the RTO is losing money or has to reduce contact hours or engage more E Learning.

The Plumbing Industry Climate Action Centre (PICAC) provides a range of HVAC&R and energy efficiency training to apprentices and practitioners. Most courses are offered at no cost or minimal cost with support from Government and industry. Examples of current courses offered include “Energy Efficient HVAC Systems” and “Geothermal Heat Pump Systems”.

Any occupational licensing scheme should require training updates at mandatory regular intervals.

3.11.3. Continuing professional development/skills maintenance Training never ends and it is the responsibility of technical service providers (and industry organisations) at all levels and in all sectors to maintain their skills and update their knowledge as changes impact the industry.

Future workforce development needs are likely to be impacted by emerging technologies. It cannot be assumed that standard training will address these emerging needs. Industry should engage with the relevant Industry Skills Councils and Higher Education Providers to ensure training packages, courses and resources comprehensively address energy efficiency and HVAC&R optimisation and respond to changing industry requirements. Skills sets can also be important mechanisms for adapting and updating the skills and knowledge of those people who gained qualifications prior to new technologies being introduced.

The attitude to, and extent of, continuing professional development (CPD) training within the HVAC&R industry is very poor. Licensing requirements do not require contractors or technicians to perform any activities in skills maintenance. Training providers who operate in the CPD area report a low demand for ongoing professional development, with the industry more interested in compliance training than professional development training.

The lack of a need for professional registration to practice building services engineering design and industrial and commercial refrigeration engineering design is a major issue with regards to setting standards and raising the bar in this area.

3.11.4. Design training There are very few formal training courses that cover the design of refrigeration and air conditioning systems either in the residential, commercial, industrial or transport sectors. Where can industry



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practitioners learn the correct application of AS/NZS 1677.2 and other industry standards, learn how to design safe NH3 based refrigeration systems or CO2 based transcritical refrigeration systems, and learn how to optimise existing systems for energy efficiency?

Trade courses include some basic heat load and design information.

Limited design training is provided by product manufacturers and suppliers, and what training is available typically focuses on the manufacturers’ own products and services. Design training and mentoring is also provided in-‐house by design and contracting companies.

3.11.5. Energy efficiency training Due to the various skills shortages within the HVAC&R industry and the migration of professionals and technicians from peripheral skill areas there are many variable perspectives as to what HVAC&R energy efficiency actually is. Much of the intellectual property in this area is held by a few of the industry leaders, large consultancies and contractors and specialist experts engaged in various sectors.

Due to the cost driven and highly competitive nature of the industry, firms and individuals are often unwilling to share their intellectual property, which represents a market advantage to them or their businesses. In addition many of the government sponsored innovation and research projects tend to licence or lock up intellectual property through commercialisation ventures. If energy efficiency knowledge is not transferring well in industry there is a case for a training intervention to help distribute energy efficiency knowledge and skills more widely in the industry. A key question to consider is where the trainers with suitable practical and theoretical knowledge are going to come from?

3.11.6. Installation training Many industry commentators believe that installation methods and standards are not covered adequately by TAFE courses.

3.11.7. Commissioning training Many industry commentators believe that commissioning methods and standards are not covered adequately by most TAFE courses?

• RMIT have a Cert IV Testing, adjusting and balancing (TAB) course • Polytechnic West have a Cert IV in HVAC Commissioning, based on national training package • AMCA deliver NEBB Training on their commissioning standard/procedures

There is a perceived lack of understanding of commissioning in industry and a lack of verification of AIRAH/ASHRAE/CIBSE process for commissioning, tuning, handover, and post-‐occupancy evaluation.

There is not enough education on the commissioning of energy efficient technologies. Even basic principles of commissioning heat recovery systems, free cooling cycles and inverter controlled motors are not fully understood by parts of the industry, particularly on small-‐medium projects.



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3.11.8. Operational training A big issue in system efficiency and the extent of emissions is how the equipment and systems are operated. Systems are often operated incorrectly or outside of their design conditions. There appears to be very little owner/operator training provided or demanded.

There is a disconnect in the knowledge transfer between system designers/builders and system operators. Knowledge should be transferred as part of the commissioning/handover process however this important step is rarely well implemented. There is also a disconnect in the feedback loop between system users/building occupants and system designers/builders. Often designers are unaware of the successes and failures of their designs from an occupant/user perspective.

Occupant expectations of HVAC are often oversold. Inefficient occupant behaviour, a tendency to quick fix in reaction to occupant complaints and excessive overuse of systems are all significant issues in many sectors.

The National Framework for Energy efficiency (NFEE) training and skills committee funded the development of a post graduate course “Energy Efficiency for Facilities Managers” in collaboration with industry (including FMA and AIRAH).

Commercial Refrigeration requires a similar effort and NSW OEH is currently developing a training course for this purpose.

There is a question of the extent to which owners of systems are prepared to pay for training.

3.11.9. Maintenance training Many industry commentators believe that predictive, preventative and scheduled maintenance methods and standards are not covered adequately by existing TAFE/VET courses.

3.11.10. Decommissioning All refrigerant should be removed from plant when it is decommissioned, does this actually happen?

Many industry commentators believe that decommissioning methods and standards are not covered adequately by TAFE courses

3.11.11. Current developments in skills and training There is considerable current activity within the skills and training sectors including:

• The development by relevant ISCs (CPSISC, MSA and E-‐Oz) of Training Package content and resources to underpin delivery of energy efficiency training to industry. This work is currently underway, funded through the Clean Energy and other skills package.

• Work through the National Energy Efficiency Skills Initiative (NEESI) under the National Strategy on Energy Efficiency (NSEE) to develop targeted training products and qualifications for HVAC and facilities managers.

• The Australian government programs include industry’s Workforce Development and Training; the objective being to “Invest in training, apprenticeships and adult language, literacy and numeracy to ensure Australia has the skills it needs to support a growing



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economy” and the ‘Building Australia’s Future Workforce’ Package; the objective being to “provide a new approach to deliver the skilled workers the Australian economy needs”. These provide funds for the "SkillsConnect" suite of programs, which is a service designed to help link eligible Australian enterprises with a range of skills and workforce development programs and funding. The Funds under the ‘SkillsConnect’ suite include the following programs:

National Workforce Development Fund (NWDF) Workplace English Language & Literacy Fund (WELL) Investing In Experience Fund (IIE)

• The Australian Sustainable Built Environment Council (ASBEC) is planning to examine broader skills, standards and risks issues regarding sustainability and the built environment through its Skills Statement work.

• The Department of Industry, Innovation, Science, Research and Tertiary Education (DIISRTE) administers a range of programs e.g. the Clean Technology Investment Program through which enterprises may be able to access funding to support for low-‐carbon and energy efficient HVAC projects, including training aspects.

• A Senate enquiry into skill shortages in engineering is also underway. • The NSW OEH is developing training for HVAC practitioners and end users and a number of

other courses are under development in 2013 (including Cogeneration and Commercial Refrigeration).

• Training materials from NSW OEH Energy Efficiency Training Program are available online. More detailed information is available from http://www.environment.nsw.gov.au/sustainbus/greenskills/eneftraining.htm

3.12. Licensing and registration

3.12.1. Technician licensing Skills and training is linked with licensing and enforcement and all aspects need to be considered together. The skills and training need to form the basis of any occupational licensing system. The licensing system also needs to be enforced to ensure compliance, so that operators or individuals who do not follow the minimum industry standards can have their licences revoked.

There is a national licensing scheme for fluorocarbon refrigerants (the ARCtick scheme) administered by the Australian Refrigeration Council (ARC). There are also state based licensing systems in some states focused towards consumer protection and health and safety.

A national licensing scheme for refrigeration and air conditioning practitioners is currently being examined by the Council of Australian Governments (COAG) through the National Occupational Licensing Authority (NOLA). One option is that all individuals handling any refrigerant or working on refrigeration and air conditioning equipment are required to hold an ARCtick licence. Many industry stakeholders have made submissions on the Consultation Regulatory Impact Statement covering the proposed national occupational licensing system for the refrigeration and air conditioning industry. It is expected that the relationship between the national occupational licensing system and the ARCtick licence will be a matter for future consideration by NOLA, the ARC and COAG.



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3.12.2. Professional registration Currently there is no requirement for building services engineers to be registered to practise in Australia. There are requirements for design certification in some states. The same situation applies to practitioners involved in industrial and commercial refrigeration engineering design.



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4. The major sectors

4.1. Section Introduction This section of the discussion paper looks at the issues from an ‘Industry sector” perspective. The major sectors considered are commercial, residential and vehicle air conditioning, commercial and industrial refrigeration and refrigerated transport.

4.2. Commercial air conditioning Commercial air conditioning is one of the sectors that has been most active in the energy efficiency area. Rating tools such as NABERS and Green Star along with Australian Government legislation/regulation such as the National Strategy on Energy Efficiency (NSEE COAG 2010) raising minimum building energy standards in the National Construction Code (NCC) and the commercial building disclosure (CBD) program mandating disclosure of energy performance for some buildings have driven improvements in the field.

4.2.1. Energy intensity Building design and thermal characteristics – Covered by NCC rules including BCA Section J, the section specifically addressing the performance and deemed to satisfy requirements for building energy efficiency. Industry has questioned the validity and practicality of some of the BCA Section J rules. There are serious questions within the sector about industry compliance, enforcement and general understanding of the requirements of NCC BCA Section J. Several states and territories have not enacted BCA section J requirements beyond the 2009 edition. NCC covers minimum practice and not necessarily best practice.

There have been some studies that suggest the past cost-‐benefit analyses of building regulations have been conservative and others that say they were excessive. There have been several calls from industry for the outcomes of existing stringency measures to be measured and validated before increasing stringency again. The legislative arrangements of the NCC/BCA Section J lack corresponding state legislation to assess or validate outcomes of the stringency measures.

Alternative approaches such as setting maximum deemed to satisfy building architectural cooling and heating loads for different building classes may need to be investigated.

Building air leakage rates – Testing of commercial buildings in Australia has reportedly demonstrated that many existing and often new buildings are very leaky with the consequence of oversized and overused HVAC systems. Although some deemed to satisfy requirements for building sealing are included in NCC Section J there is no standard set for air tightness of commercial buildings hence design and construction techniques do not focus on this area

Benchmarks – Whole-‐building energy performance benchmarks are provided by rating tools such as NABERS Energy. There is no specific benchmark or rating tool for commercial HVAC although these systems make up a significant proportion of building energy use. Internal heat generation, air leakage, occupancy etc can be very variable, and there can be very complex interactions between



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HVAC and other systems. Improving the capacity to monitor and diagnose HVAC systems is certainly worth doing, and benchmarking systems against real time modelling can help to identify deviations from expected performance. A separate HVAC rating system within a building could help the industry target energy efficiency and emissions specific to these systems.

Demand management – methods, processes and tools are available for applying demand management strategies to commercial building HVAC&R.

Energy source – Non-‐grid alternatives are available to the commercial building area and these have been introduced to the market in response to rising energy prices, building energy rating and disclosure and green building rating tools. Technologies include solar PV, wind, co-‐generation and tri-‐generation, biomass boilers and many others that can be integrated into the building.

System size – Oversizing of components and systems in commercial HVAC is reported to be widespread. As climate change occurs systems may be designed for a warmer world which will tend to increase system size further.

One sizing issue relates to the accuracy of load estimate calculations used to determine sizing. A lot of load estimation/calculation tools seem to be based on historic rather than current data. Sizing is also related to building design issues, ensuring no spaces have excessive cooling loads, as well as overall building energy requirements. Given that many buildings are much leakier than expected, and that substitutions of equipment and other issues can happen during construction, oversizing is often seen as a ‘back-‐up’ measure for failings in other areas.

Design strategies – Systems need to be designed with adequate zoning and for future flexibility. The adoption of design strategies so that systems can have their capacity upgraded capacity, e.g. modular HVAC for data centres, would reduce the pressure to design for any future event.

Installation – It is important that systems are installed in accordance with their design intent however installation also needs to take into account any changes to the building occupation or use.

Commissioning – Is a critical part of the design and installation process that has traditionally been poorly implemented.

Systems – Efficiency of components versus whole system efficiency. Also, given that for most of the time systems are running nowhere near full load, design for efficient part and variable load performance is very important.

4.2.2. Energy efficiency New buildings: Covered by building regulations for new buildings (NCC BCA Volume 1) and being addressed in other forums (Building framework). Do regulations need to incorporate peak demand requirements as well as energy performance requirements? Do NCC regulations need to address improvements to existing buildings?



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New systems in existing buildings: Retrofit practices targeting NABERS ratings, energy efficiency opportunities (EEO), environmental upgrade agreements (EUAs), are all designed to address new systems in existing buildings.

Existing systems in existing buildings: programs such as CBD and tenants seeking particular NABERS Energy ratings drive performance improvement in some building grades/classes, but not all. Retrocommissioning (commissioning an existing building that has not been properly commissioned previously) and building tuning are pathways to improving building energy efficiency that are not capital intensive. Most buildings, even those recently constructed and correctly commissioned, can benefit from building tuning for energy efficiency.

Calculating cool – A proposed system for rating the performance of building HVAC&R.

4.2.3. Refrigerant leakage Leakage rates are significant; 5 to 9% for chillers and direct expansion systems is the nominated typical rate in the AIRAH TEWI Guide. There is capacity to improve leakage minimisation through improved industry practices.

The most common cause of refrigerant leakage is a lack of regular system maintenance and leak testing. Likely points for refrigerant leaks are at the flared, flanged, brazed or soldered joints in refrigerant lines and any changes in cross section or direction of these lines. Joints can be damaged by system vibration. The shaft seal on open drive compressors, the service valves and pipe or component corrosion are another common leakage source as are the pipe bends and connections associated with entry to evaporators and condensers. Many of these issues can be addressed during design for new/replacement systems, during maintenance for existing systems and in connection with system energy efficiency upgrades.

4.2.4. Maintenance Mandatory HVAC&R maintenance in commercial buildings is outlined in NCC V1 Section I and includes essential services (essential safety measures) and systems containing microbial hazards. NCC V1 Section I also contains mandatory maintenance requirements for energy efficiency of the plant. There are many state and territory variations to these requirements and they are deleted in some jurisdictions.

All other maintenance is optional and left to the discretion of the owner/operator/service provider.

HVAC HESS program has produced a guide to best-‐practice maintenance in the commercial building sector. Guide to best-‐practice maintenance and operation of HVAC systems for energy efficiency

There is reluctance on the part of many owners and operators to pay for system maintenance.

4.2.5. Building tuning, recommissioning and retrocommissioning Buildings often do not perform as well in practice as anticipated during the design stage. There are many reasons for this, including improper equipment selection and installation errors, lack of



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rigorous commissioning, documentation and proper maintenance, and poor feedback on ongoing performance, including energy performance. There is a growing recognition of the need to formalise building commissioning procedures to ensure that building systems operate as intended.

There are many guidelines and procedures for commissioning and the majority of the activity is for new buildings, AIRAH, ASHRAE, and CIBSE have produced commissioning guides.

Recommissioning is a term used to perform commissioning procedures for existing buildings periodically during their lifetime as a follow-‐up to the initial commissioning. Retrocommissioning refers to a set of procedures, like an extensive tune-‐up, that are applied to buildings that have been changed or have never been commissioned. Ongoing commissioning refers to a more automated commissioning process that is performed and evaluated on a frequent or continuous basis.

It is well recognised within the industry that one of the low cost first steps in energy efficiency is to make sure that the systems that are installed are working “as best they can”. In order for this to happen some form of ongoing system/building tuning or recommissioning is required. This activity is not widely practised in the commercial building sector and, although there are some drivers for it, tuning and recommissioning is often seen as a labour intensive process. Each building needs to be examined as a whole system, i.e. not just look at one piece of equipment, or one aspect of the system. Building design and construction, then system design, installation, controls, commissioning, building operation and maintenance results in most buildings being, to a lesser or greater extent, unique. In general the more complex the building systems, the greater the level of commissioning rigor needed.

Some of the barriers to existing building tuning include the adequacy of the HVAC&R and building control systems, the arrangements for metering (water, power, and thermal energy), the lack of awareness of the potential benefits, and the willingness of owners and operators to pay for the services. It is much harder to tune a building if the measures aren’t in place to actually “see” what is going on.

The experience from the NSW OEH Energy Saver program shows that by using building tuning and recommissioning practices, buildings can save 5–10% of their utility cost and simple payback is less than 2 years, with some less than 1 year.

4.2.6. Fault detection and diagnostics (FDD) Typically the fault detection and diagnostics required in assessing existing systems are labour and skills intensive and this may be one of the main barriers to energy-‐efficiency interventions in existing systems. In many cases existing digital control systems have the capability to be utilised for fault detection and system diagnosis (for example by recording and trending system performance indicators) but are not utilised in that way.

Commercially available tools for automated FDD and ongoing commissioning are beginning to emerge that could greatly assist in achieving low-‐cost and persistent energy savings from existing building stock. These tools attempt to identify when faults occur in real-‐time, diagnose their cause



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and, if they are of sufficient severity, communicate the fault to the facilities managers or maintenance personnel. More advanced systems are able to automatically correct or adjust for faults in some circumstances. This can reduce energy wastage, eliminate scheduled maintenance costs, reduce diagnostic labour, reduce downtime and increase equipment life.

These systems, where applied, need to address any systemic controls and commissioning issues as well as address routine failures of equipment and components. Automatic systems also need to be cost effective, reliable and easily understood and operated by end users.

4.3. Residential air conditioning

4.3.1. Energy intensity Building design and thermal characteristics – Covered by NCC (BCA Volume 2) rules and software modelling systems such as the Nationwide House Energy Rating Scheme (NatHERS) and CSIRO’S AccuRate programs and state systems such as the Building Sustainability Index (BASIX) in NSW. The present residential building regulations in cooler climates are heavily weighted towards winter performance. Separate requirements for summer and winter would focus more attention on each mode of operation. Peak demand is a significant issue that is not currently addressed by residential building regulations. With evidence of a growing trend in residential air conditioning demand regulations should address peak demand as well as energy performance requirements.

Residential building regulations only address the building fabric. You can have a 6 star house and install a 1 star gas heating system, or an under/over-‐sized ducted air conditioning system, even though the air conditioning appliance would comply with MEPS. Regulations do not address the volume of space that potentially needs to be conditioned.

There have been some studies that suggest the past cost-‐benefit analyses of building regulations have been conservative and others that say they were excessive. There have been several calls from industry for the outcomes of existing stringency measures to be measured and validated before increasing stringency again.

Building air leakage rates – Excessive leakage leads to increased infiltration/exfiltration which increases heat and cooling loads and leads to oversized and overused heating and cooling systems. Residential design and construction techniques do not focus on this area and measured leakage rates of Australian residential building stock is reported to be high. There is no standard for the testing and measurement or rating of air tightness in residential buildings in Australia.

Demand management – Australian Standard AS 4755.3.1 is available for residential air conditioners covering demand response enabling devices (DRED). Control interfacing is still reported to be difficult with microprocessor based inverter compressors and units with limited OEM controls.

AS/NZS 4755.3.1 specifies a demand response interface on an air conditioner and specifies a set of operational instructions for that air conditioner. It defines a ‘one-‐way’ signalling interface that enables an air conditioner to enter into a pre-‐defined demand response mode. A related standard,



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namely AS/NZS 4755.1 specifies requirements for DREDs. These standards do not currently specify a more feature-‐rich ‘two-‐way’ signalling system that could facilitate common information exchange between electricity service providers, aggregators, and end users; enabling even greater energy savings and demand reductions through the signalling of feedback and reporting.

Consumption management – At an individual level consumers are driven by a desire to control their energy bills of which HVAC&R forms a significant component. However, very few consumers have access to real time information about their consumption profile and therefore lack the signals to help them moderate their consumption.

Energy source – Very few residential air conditioning systems would be powered by non-‐grid supplied electricity. Standalone solar PV would typically not produce sufficient power to run a typical or traditional residential air conditioning system. However, in very energy efficient houses it may be possible to power very efficient HVAC systems by standalone PV.

System selection – The sales model for residential air conditioners is increasingly from “big box” whitegoods and hardware retailers where the residential customer selects on price rather than selecting a unit based on capacity and required heat load. Under this sales model it is difficult to control the quality of installation.

System size – Oversizing of components and systems is reported to be widespread, inverter technology is masking some of the issues. Retail sales people have a strong incentive to oversize, to make bigger profits, while designers prefer to err on the ‘high’ side so they don’t get complaints on hot days.

Installation – Highly variable standards of installation and commissioning are reported in the residential air conditioning sector. These impact the energy efficiency and the direct emissions associated with this sector. The market is highly competitive with low margins and systems are often installed by poorly qualified people or by non refrigeration or air conditioning trades.

4.3.2. Energy efficiency New buildings: The energy efficiency of new buildings is covered by building regulations (NCC BCA Volume 2) and is being addressed in many other forums. From an HVAC perspective the main opportunities are highly efficient and flexible air conditioning systems, low-‐GWP refrigerant-‐based systems and the opportunities for heat recovery in home ventilation systems.

In the residential market the impact of improved EER under MEPS has been useful but takes significant time to take effect, turnover of already installed stock can take many years. The penetration of residential air conditioning has increased as well as the saturation (i.e. the number of air conditioning units within a home). Even though they may be becoming more energy efficient, the potential for increased household energy use and the negative impacts on peak demand are not being mitigated.



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Non-‐compliance with the energy efficiency provisions of ductwork remains a challenge. The updated AS4254.1–2012, which requires labelling of flexible ductwork, will put a stronger burden of proof on manufacturers and contractors.

New systems in existing buildings: Retrofit practices targeting the potential upgrade of existing air conditioning systems that are low efficiency and potentially environmentally degrading shows significant potential for delivering energy efficiency improvement in existing buildings. Homeowner concerns over electricity price rises may create an environment where there may be some incentive for upgrade activity. The replacement of old inefficient and environmentally damaging equipment needs to be incentivised.

Note: Some state-‐based incentive schemes (e.g. Victorian VEET scheme) incentivise retrofits of more energy efficient heating and cooling appliances.

Existing systems in existing buildings: Maintenance is the key to making existing systems in existing buildings work as well as they are able. Maintenance in the residential sector is often only carried out when a system fails. This is a broad issue affecting gas heaters and other equipment in the residential sector. It may be that an integrated maintenance package is needed, and that it be offered with incentives etc.

One disadvantage of the re-‐scaling of the residential air conditioning energy label is that many people with pre-‐2010 units think their air conditioners are as efficient as new ones, when in reality they are much worse. Publicity and education is needed.

4.3.3. Operation Most owners are totally unaware of the best way to operate their systems for reduced energy costs.

There needs to be a greater focus on consumer information, on the correct operation of residential air conditioning and evaporative air cooling equipment.

4.3.4. Refrigerant leakage Leaks have direct and indirect emission effects. Leakage if left unaddressed will significantly affect the energy efficiency of the system. This is a significant problem in the residential sector because financial payback from leak minimisation activities is poor. The problem is compounded by the poor installation standards applied in the residential sector. Electrical submetering for air conditioning is rare in this sector so any rise in energy demand from inefficient air conditioning is difficult for users to identify.

4.3.5. Maintenance A very poor level of maintenance is applied in this sector and maintenance for energy efficiency is rarely practised. Service calls are generally instigated on system failure only.



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4.3.6. Low-‐GWP refrigerants There is a strong push nationally and internationally to expand the use of hydrocarbon based air conditioning systems for the residential sector. These refrigerants are promoted as a low-‐GWP and energy efficient alternative. Synthetic refrigerants with an A2L designation are also being promoted as an option for this sector. Both of these options introduce risks associated with refrigerant flammability.

The current charge limit of AS/NZS 1677.2 essentially limits the application of HC refrigerants to 1.5kg charge (1 kg below ground) as long as the practical limit (kg/m3 room volume) is not exceeded. Systems containing 0.25kg of refrigerant or less have no restrictions apart from addressing any local sources of ignition. The A2L designation is not included within AS/NZS 1677.1:1998 so AS/NZS 1677.2:1998 does not contain charge limits specific to that designation, the A2 limits apply. Charge limits and refrigerant designations may be revised in the current review of the AS/NZS 1677 series of standards.

4.3.7. Training and licensing Technicians need to be prepared for the next generation of air conditioner refrigerants including dealing with any hazards. Currently there are no requirements for technicians to undertake any skills maintenance or CPD activities or have a licence to handle natural refrigerants, with the exception of Queensland which has requirements in place for hydrocarbon refrigerant use.

4.3.8. Strata title residential buildings Strata title residential buildings dominate in cities and dense urban developments. NSW OEH Energy Saving program partnering with City of Sydney has audited 30 strata title buildings in Sydney recently. The program found:

• The biggest energy consumption is ventilation, such as toilet exhaust system, car park ventilation and other ventilation for common areas.

• Other top end energy uses are heating (domestic hot water, heating for air conditioning, heating for swimming pool), lifts, and swimming pools. Energy consumption can be significant for these uses if not correctly managed.

• There isn’t any benchmark available at the moment. • Building performance varies and it doesn’t link to the building age. • The most dominant central air conditioning system is condensing water cooling system,

cooling using cooled water from cooling tower. • Building management and control systems are seldom installed, which means that

equipment is individually controlled. • Energy savings in HVAC area can be 10% of the building energy consumption. • Alternative energy sources include solar PV and co-‐generation.

4.4. Vehicle air conditioning Vehicle air conditioning is a very broad sector that operates across a range of industries, a range of applications and a range of geographical locations. The significant sectors include:



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• Vehicle air conditioning/auto electrical (passenger cars) • Transport air conditioning (trains and buses) • Mining and agriculture (air conditioning in trucks, tractors and shovels)

These sectors are significantly different and require separate technical skill sets depending on the application and location. Differing geographical locations introduce differing challenges for system technicians. The industry is characterised by large numbers of small independent operators which makes education, training, compliance and enforcement activities particularly difficult.

The issues around vehicle air conditioning in new vehicles are largely driven by international and original equipment manufacturer (OEM) design standards. Vehicle manufacturers prefer a single global refrigerant solution that satisfies regulatory authorities in all global markets. Most vehicles use R134a although due to new European regulations a new synthetic refrigerant HFO 1234yf is being commercialised. The development of HFO 1234yf was originally a collaborative effort between refrigerant manufacturers and vehicle manufacturers. However, a disagreement regarding product licensing and patent arrangements and concerns regarding the flammability and product of combustion of the refrigerant has caused some vehicle manufacturers to move away from the product. As a consequence, HFO 1234yf may not be adopted by all vehicle manufacturers.

Hydrocarbon based refrigerants can be used in vehicle air conditioning and, while currently only provided by one OEM, this refrigerant is also marketed as a retrofit option in Australia. Both in Australia and internationally the majority of OEMs do not support this practice on safety grounds. Safety and efficiency issues are debated and refuted by both sides of the industry and no consensus has been achieved. Industry estimates that hydrocarbons are used in about 10% of cars in Australia. Hydrocarbon suppliers claim it delivers increased efficiency and it is available as a retrofit option in all states. Hydrocarbons are likely to continue as a popular retrofit option on a price basis and because of increased efficiency claims. Energy efficiency claims have not been validated.

Hydrocarbons are not endorsed or used by many vehicle or vehicle HVAC component manufacturers who are concerned that hydrocarbons in vehicle air conditioning may compromise the safety, performance, reliability, longevity, serviceability and warranty of their vehicle system. The use and users of hydrocarbons are not regulated in most states and are not controlled by any standards or code of practice. It is claimed that the unregulated use of hydrocarbons is causing needless and irresponsible contamination of refrigerants in both vehicle air conditioning systems and recovered refrigerant stocks.

The reported efficiencies of hydrocarbon use do not take into account the “whole of life” effect of hydrocarbon use in a system not designed for its use, and have not been verified by any vehicle manufacturers, to substantiate its effectiveness.

CO2 has been trialled as a vehicle air conditioning refrigerant, and some manufacturers are continuing developmental work on this option. The Society of Automotive Engineers (SAE) has invited all automobile manufacturers to join in an industry collaborative effort to fully evaluate the technical aspects of the use of CO2 as an automotive air conditioning refrigerant. It is likely that any



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OEM system based on CO2 or hydrocarbons would be more expensive than the existing R134a based systems due to the increased safety and engineering requirements.

There are also some moves towards using electric motors to drive car air conditioning units, and this would reduce the need for flexible hoses and their connections, which are a common source of leaks.

4.4.1. Design safety standards Standards Australia discontinued a project to develop a design safety standard for refrigerating systems in mobile applications. The scope of AS/NZS 1677.2 excludes non-‐stationary systems.

The Australian Automotive Code of Practice applies to the control of fluorocarbon refrigerant gases during manufacture, installation, servicing or de-‐commissioning of motor vehicle air conditioners. http://www.arctick.org/pdf/Automotive_RAC_CoP.pdf

The Australia and New Zealand Refrigerant Handling Code of Practice Part 2 includes for mobile applications within its scope. This code does not cover the use of flammable refrigerants or the use of newly developed replacements for R134a. http://www.arctick.org/pdf/Stationary_COP_2007_2.pdf

There is no standard or CoP document that covers the application of flammable refrigerants in automotive or mobile applications. Current design standards used are Society of Automotive Engineers (SAE) engineering standards which do not include refrigerant safety standards. Current SAE standards are based on the assumption that R134a is the refrigerant in use.

4.4.2. Energy intensity International OEMs report that a number of measures have been evaluated to reduce heat loads on vehicles including using ventilated systems, reflective paints, reflective glass, and improved insulation of the vehicle body. Reduced internal temperatures have been achieved, indicating that the better the thermal performance of the vehicle shell, the more effective the comfort solutions.

4.4.3. Energy efficiency Improvements to compressors and controls are largely driven by international OEM companies. As the majority of design and component manufacture for vehicle air conditioning systems is conducted outside of Australia on a global scale, the impact of any locally introduced improvements instigated within Australia will most likely have little or no impact on the manufactured vehicles imported into this country, and very little impact on any locally produced vehicles, due to those local manufacturers operating from a global platform.

4.4.4. Refrigerant leakage Because of the small charge of refrigerant typically used in vehicle air conditioning systems leakage volumes per vehicle are small but, as vehicle numbers are high, collectively leakage can be significant from this sector.



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IEA have reported average annual leakage rates for well designed/maintained new vehicles using R134A at around 10g/year.

European regulations limit leakage rates to 40 to 60 g/year depending on the system design.

A leak assessment test method is reportedly being developed by manufacturers to establish compliance of individual air conditioning systems with European regulations.

Government gas regulators advise in relation to hydrocarbon refrigerants that most of the leaks in the car would come from accidents, open drive compressor seals and faulty hoses. From a safety perspective none of these are seen as critical safety risks for the occupants.

4.4.5. Maintenance The majority of maintenance currently performed on vehicle air conditioning systems is to rectify an already under-‐performing or failed system. The design of modern systems has resulted in more reliable systems which require less maintenance. By design, the modern vehicle air conditioning system requires a lower refrigerant charge quantity, uses highly efficient heat exchangers and is also utilising components which are predominantly manufactured of very light-‐weight aluminium.

Technical Standards for refrigerant recovery and charging are contained in the Automotive Code of Practice which also includes advice and requirements for system leak detection.

Retrofitting of ozone depleting refrigerants from mobile air conditioning systems is a practice which is virtually non-‐existent and no longer required. Retrofitting came into practice due to the phase out of ozone depleting refrigerant R12. As all vehicles produced after 1995, either for import into Australia, or manufactured in Australia, were designed to use R134a, there remain very few vehicles in the Australian car fleet which require retrofitting away from an ozone depleting substance. The current SAE standard prohibits the retrofit of R134a systems to HFO1234yf.

4.5. Commercial refrigeration System architecture, refrigerant charge and thus risks and emissions all vary a great deal within this sector.

4.5.1. Supermarket and displays There has been considerable work carried out in the supermarket and other refrigerated display applications. These building types are historically very high energy users, typically because of the extent of the artificial lighting, air conditioning and food refrigeration (display and storage) employed. Large owners and managers of supermarkets have engaged energy efficiency and emission reduction measures however, the extension of these practices to smaller operators is more economically challenging.

The Consumer Goods Forum, a CEO driven industry association of 400 multinational food suppliers and retailers, report significant progress and commitment to natural refrigerant-‐based technologies. The member companies are taking action to mobilise resources within their respective businesses to



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begin phasing out HFC refrigerants by 2015 and replace them with non-‐HFC refrigerants (natural refrigerant alternatives such as CO2 and hydrocarbons) where these are legally allowed and available. This would largely be for new purchases of point-‐of-‐sale units and large refrigeration installations.

Changes such as “virtual” retailing (using images rather than real products, then people can pick them up as they leave the store or have them delivered) and on-‐line retailing may also act to reduce the amount of display refrigeration needed.

There are a significant number of small chiller cabinets provided by suppliers of product and intended to be located at ends of an aisle or at cash registers in supermarkets to encourage impulse purchases. These units, by design, do not have doors/lids/blinds to make product easier to sell. These small display units are generally less energy efficient than bigger display units particularly when there is no door/lid/blind.

Energy intensity The fabric of these buildings is covered by NCC/Building Regulations; however, system energy intensity is often determined by other factors such as the lighting arrangements and technology, rate of product throughput, hours of operation, methods of control and defrost and the type of refrigeration system used.

Most of the larger supermarket chains are addressing their carbon footprint which includes the direct and indirect emissions from refrigeration and air conditioning systems.

Energy efficiency Cases – retrofitting lids, doors and blinds to previously unenclosed refrigerated cases can result in significant savings. Fitting doors to open units is beginning to occur, while some retailers have moved to top access freezer units. Blinds on open display units are also appearing. Improved defrost management is also a significant opportunity. While marketers have resisted doors because they create a barrier to purchasers, some stores have found that improved shopper comfort from doors offsets this concern. Market difference would be negated if the entire industry shifted to doors at the same time.

MEPS – includes both remote and self-‐contained refrigerated display cabinets primarily used in commercial applications for the storage of frozen and unfrozen food. Set out in AS 1731.14–2003 as total energy consumption per total display area (TEC/TDA) in kWh/day/square metre for various unit types. MEPS standards also define minimum efficiency levels for “High Efficiency” refrigerated display cabinets. Only products which meet the specified efficiency levels can apply this term to promotional or advertising materials.

Benchmarks

What benchmarks are available?

By measuring consumption, setting goals, and tracking energy use, supermarkets can gain control of energy expenses. Supermarkets can use benchmarks to rate their energy performance relative to



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similar buildings nationwide. There is no specific benchmark or rating tool for commercial refrigeration systems adopted for use in Australia.

Note: The IEA Heat Pump Centre has recognised this issue and has started a new Annex (collaborative project) to cover it. Australia is not currently a member of the IEA HPC program.

Refrigerant leakage Refrigerant leakage is a significant issue for the commercial refrigeration sector. Refrigerant pipe runs tend to be long and complex incorporating many fittings as they serve multiple cabinets. Pipe runs also tend to be hidden from view and located in difficult to access areas.

Leak management Regular leak testing and audits are difficult for this industry sector due to storage space constraints. Often displays and cabinets need to be emptied to carry out leak testing and/or the evaporator fans need to be turned off to facilitate the still air needed. Limited storage is available and product quality may be impacted by handling and temperature fluctuations, special management solutions are needed.

Maintenance Maintenance is necessary but not always implemented optimally due to the cost and skills issues discussed previously and reluctance by owners or issues associated with the shutdown of systems (e.g. display cases etc) due to lost revenue.

Retro fit/energy upgrades Energy cost savings can justify the replacement of some components of the refrigeration system.

4.5.2. Low-‐GWP refrigerant solutions There is an emerging trend of natural refrigerant-‐based low-‐GWP refrigeration systems in the commercial supermarket area. While not well established in Australia yet there is a growing body of work internationally most notably in Europe (e.g. UK and Denmark). Both of the two major supermarket chains in Australia have made commitments to transition to natural refrigerant-‐based technologies. It is reported that approximately 80 supermarkets have implemented CO2/R134a cascade systems in Australia. There are also some transcritical CO2 systems in place and supermarkets that have transitioned to hydrocarbon refrigerants.

4.5.3. The total-‐system approach to design There is an opportunity to apply a "total-‐systems approach" in the retail chain. There is a large proportion of existing supermarkets where air conditioning and retail refrigeration are separate systems.

This separation tends to be due to commercial issues and contract demarcation lines. The air conditioning is typically included in the building enclosure by the developer, and the refrigeration system is typically included in the fit out and is the responsibility of the retailer. A central systems (total systems) approach can improve full and part load performance of the combined refrigeration and air conditioning systems as well as improve redundancy. Environment control in the shop can be



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of great benefit to the energy consumption of the combined refrigeration and air conditioning systems.

In many refrigeration systems waste heat is available for recovery and reuse including simultaneous heating/cooling for environmental control or for heating water services. For transcritical CO2 applications opportunities exist for using waste cold to reduce gas cooler temperatures (concepts like these are being explored in the retail industry). Very high system COPs are possible with this approach.

4.5.4. Refrigerated warehouse/storage facilities The “In from the Cold” 10-‐year strategy compiled by the DCCEE estimated that “in 2008, non-‐domestic refrigeration in Australia consumed approximately 13,377GWh of electricity and was responsible for greenhouse emissions of 13,695 kilo-‐tons (kt) CO2-‐e, equivalent to 4% of GHG emissions from all fuel combustion in Australia’s energy sector”. The document estimates that the Cold Storage and Distribution sector used 630GWh of electricity for a greenhouse emission of 634 kt CO2-‐e.

There are two main groups in this category: 1. Temperature controlled storage and freezing facilities attached to food manufacturers,

abattoirs, meat processors, frozen and chilled food distributors, importers and exporters, supermarket chains and storage facilities operated by the pharmaceutical companies and others.

2. Independent temperature controlled storage facilities that are not attached to other businesses put provide services to all of the above and form a critical link in the cold chain.

The cold storage industry is very energy-‐intensive and electricity is typically the largest non-‐labour expense in operating these facilities. The industry is also capital intensive because the refrigeration equipment has a long service life and is expensive to replace. Large cold stores tend to be ammonia (NH3) based, however a large number of temperature controlled facilities in both categories are HFC or HCFC based due to the reduced capital investment and the cost and lack of service personnel associated with ammonia refrigeration plants.

HFC-‐based facilities are exposed to a serious potential commercial risk due to the equivalent carbon price levy imposed on high-‐GWP refrigerants. The cost of refrigerant replacement (if required) is now considerably higher due to significant price increases for these refrigerants. Cold stores and refrigerated warehouses currently do not qualify for funding under the Clean Technology Investment Program (CTIP).

Due to their significant energy use these types of facilities have been good candidates for energy reduction interventions. New technologies such as solid state LED lighting, evaporative condensers, variable speed drives for compressor capacity control, variable speed drives for evaporator and condenser fans, voltage optimisation and structural changes to reduce heat and air infiltration, make it possible to make large reductions in energy use.



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The cold storage industry can be very seasonal and the electricity use can suddenly change depending on the type of work carried out. The amount of freezing, the rate of product turn-‐over, the amount of unused space due to market demand, the requirement of clients for chilled or low temperature storage all have major influence on the energy used.

There is a large range in energy consumed by cold stores: • Around 12 to 14 million m3 of cold storage space in Australia • Large range in efficiencies, from 30 to >400 kWh/m3 per year

Storage efficiencies, measured by kWh/m3 per year, vary widely with the most efficient stores using up to 75% less energy than the least efficient. This is largely a factor of store size; the larger stores being more efficient. However, the type of storage operation and the age of the refrigeration system also influence energy use. Blast chillers particularly increase energy consumption.

The European ICE–E project showed a large potential to reduce energy (often by up to 60%). However it is noted that energy-‐efficiency interventions and options are often specific to a facility and not necessarily generic to the sector. Improved insulation and sealing of the refrigerated space and reduced energy consumption when the plant is not running fully loaded using variable speed drives and appropriate control systems were common successful interventions.

Energy intensity Building design and thermal characteristics – These types of facilities are typically procured by an owner rather than speculatively developed. There are no mandated minimum standards for construction of refrigerated warehouses. However, with increasing electricity prices it is in the owner’s best interest to consider the life-‐cycle costs of the construction project.

Use of thermal imaging cameras can identify thermal bridging in refrigerated warehouses. Heat reflecting paints and special loading docks can also cut energy use.

Demand management – Due to their large thermal mass and inertia, refrigerated warehouse and cold storage facilities are prime candidates for demand management and participating in demand response programmes, as they can often ramp down or switch off significant load for long periods (several hours) without affecting product quality or safety.

Energy source – These facilities are typically grid supplied.

System size – Oversizing of components and systems is reported to be widespread. There is often a need for rapid cooling/freezing of inputs; this could use a separate system. Smaller cold stores may have many different tenants over their life time each with differing needs, so flexibility is needed. The refrigeration contractor has to size based on client information. The client usually is unsure of their exact cooling requirements.

Installation – Commissioning, a critical part of the design and installation process, has traditionally been poorly implemented in this sector.



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Energy efficiency While the larger businesses in the industry have made significant improvements in energy efficiency the SME side of the industry is not incentivised to improve energy efficiency due to a number of reasons including:

• Lack of operator understanding of plant operation and energy efficiency. • Low profit margins and lack of funds (technological improvements are very expensive and

ROIs can be long). • Management is already overburdened with compliance and lacks resources to understand

energy efficiency. • Retrofitting energy efficient plant can be very disruptive to business adding to the cost. • Cold store operators may attempt to make the HVAC&R contractor responsible for

consequential damages resulting from disruptions, causing higher contractor risk leading to higher contract prices and poorer ROIs.

• Lack of government incentives (independent cold stores are unable to participate in current Clean Technology Investment Programs).

• Many facilities are old and on small sites and major rebuilding would be required to make major improvements in energy efficiency.

• The cost of land has substantially increased over the life of the facility and it is a better proposition to decommission the plant and sell the land than to make major upgrades.

• Many facilities are leased and the landlord has no incentives to make costly retrofits. Some general feedback from the ICE–E program audits carried out in Europe:

• 30–40% saved by optimising the performance of refrigeration plants • Further savings of 20–30% by reducing heat loads including that from lighting. • Overall savings of 57–72% • Paybacks on investment less than one year

Refrigerant leakage These systems can contain significant charges of refrigerant and any HFC or HCFC based facilities are significantly exposed to the refrigerant equivalent carbon price should they need to be charged or re-‐charged with refrigerant due to leakage from the system. Due to the variance in the quality of design and installation refrigerant leakage rates are reported to vary widely between sites. Annual leakage rates of between 5% and 23% have been reported (AIRAH TEWI) and some sites experience catastrophic (total) loss of charge on a regular basis (annually or even more frequently).

Maintenance Service providers are well placed to provide increased energy efficiency through site surveys and energy efficiency and leakage intervention proposals and advice. Service and maintenance could be applied to reduce emissions and identify possible retrofitting and energy improvements.



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Retro-‐fit Energy cost savings alone can justify the replacement of some components of the refrigeration system and transitioning to low-‐GWP refrigerant-‐based systems can provide significant efficiency improvements.

This sector does not qualify for funding, either under the Clean Energy Future CTIP program or many of the state-‐based incentive schemes, because this sector is not classed as a “manufacturing” sector even though manufacturing and agriculture depend on these services. To exclude such an extensive and energy intensive sector from the clean technology program seems counter intuitive.

Training and awareness

The ICE–E project identified the following training and awareness needs for European cold store operators and owners. They have produced 5 e-‐learning modules (tailored, detailed, easy to obtain information for cold store operators):

• Introduction to Refrigeration – Basic rules of heat transfer and describe how a refrigeration system works using two different explanations. The first uses thermodynamics and the second uses hardware.

• Environmental and legal aspects of carbon reduction – Informs about the use of alternative and more sustainable refrigeration technologies in the context of the fight against climate change, global warming and ozone depletion.

• Service and maintenance to reduce carbon – Understanding the quality and costs of a refrigeration system, reduce costs and improve reliability of the refrigeration system, reduce the environmental impact of the system.

• Energy improvements through plant design and retrofitting – Improve energy efficiency in medium to large scale refrigeration systems for cold stores.

• Energy audit – The main aspects of an energy audit and simple examples.

Case studies with Australian examples of energy saving measures could also be used. Also needed is a ‘systems’ approach that includes the building fabric and its internal heat sources, ventilation, as well as information for the system users and maintenance providers.

4.5.5. Cold rooms/freezer rooms These rooms are common in a range of buildings including food retail shops (butchers, bottle shops), hotels, clubs, pubs, etc.

Energy intensity There are no standards to cover the construction and performance of these areas in Australia.

The floors of many walk-‐in coolers on farms and in grocery stores are simply concrete slabs that extend out of the cooled area. Accordingly, a good deal of cooling energy is lost to the ground and adjoining areas. Retrofitting these with floor insulation can be accomplished inexpensively. Similarly the walls and ceiling materials need to be specified for high thermal insulation and air/vapour sealing. Cooler door(s) should be designed or retrofitted to ensure good door operation, a tight seal when closed, and a gently sloping ramp to facilitate rolling goods into and out of the cooler.



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Also, a lot of thermal bridging occurs via door frames and structural framing. A lot of the condensing units are located in hot places/micro climates with limited ventilation.

Energy efficiency There are currently no Australian standards or benchmarks available to assess cold room energy efficiency against or to allow the comparison of performance of different cold rooms.

Refrigerant leakage Poor leakage performance has been reported in this sector. There are numerous anecdotes about small leaks being left unrepaired in order for the service provider to generate income. The equivalent carbon price for high-‐GWP HFC refrigerants should inhibit these practices, but education of the end-‐users is also required. Many end-‐users appear to be of the misunderstanding that refrigerants are a consumable. End users need to understand that refrigerants belong in the system and if the system leaks there is something wrong with the system and the service provider must address it.

Maintenance Generally, the approach to maintenance is ad-‐hoc or based on a ‘maintain on failure’ strategy. Maintenance for energy efficiency is not practised.

Retro-‐fit Energy cost savings can justify the replacement of some components of the refrigeration system. Improvements to room fabric (walls floors and ceilings), doors, operating practices, and the like also have the potential to provide significant energy savings

This sector does not qualify for funding under The Clean Energy future CTIP program.

4.6. Industrial refrigeration Industrial refrigeration is usually defined as large systems, custom designed and built to meet specific requirements often using refrigerants such as ammonia, hydrocarbons, hydrofluorocarbons, and carbon dioxide.

The sector is closely linked with the cold storage industry discussed previously. Industrial refrigeration also plays a significant role in the materials processing functions that involve the use of refrigeration within the manufacturing, agricultural, food, meat, wine, beverage, petrochemicals, pharmaceuticals, printing and a wide variety of other industries.. Industrial refrigeration within some sectors has been in decline as a market for the past 30 years, as the Australian manufacturing base has shrunk and as multinationals acquired, consolidated and automated domestic businesses.

In mid last century, the synthetic refrigerants R12, R22, and R507 impacted greatly on the industrial refrigeration sector, replacing ammonia in many smaller to medium sized installations and sometimes in large installations. At this time many skilled personnel left or retired from the sector resulting in the current shortage of engineers and tradespeople with experience in ammonia based systems.



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Due to the nature of the equipment, the critical aspect of refrigeration in the production processes, and the potential losses per hour in downtime, the equipment is generally purchased to higher specifications than in some other industries, and higher standards of preventive maintenance are common. As a result the sector repairs and maintains equipment rather than replacing it resulting in longevity of equipment, increasing life-‐cycle value and reducing environmental impact.

Industrial refrigeration companies in this field generally have in-‐house engineering, drafting, installation, and service personnel. This enables tight control over the complete installation ensuring a high level of safety. Personnel are trained in house as no external training is available. Supervised on the job training is critical to producing personnel competent in handling large systems containing sometimes up to several tonnes of ammonia or propane.

Energy intensity The size and range of applications within the industrial refrigeration sector makes it difficult to comment on the energy intensity of these systems. Benchmarking data is available on US and European cold storage facilities of varying pallet holding capacities. Such data could be used as a guide.

Energy efficiency There is great potential for energy-‐efficiency interventions in industrial applications. This area has been heavily canvassed over the past two years. Energy guides are well documented and funded audits have been abundant. Most industrial refrigeration companies have consulted with clients on methods to reduce energy consumption.

Refrigerant leakage For ammonia based systems modern installation methods and materials allow reliable and rugged construction. Systems are usually fully welded such that leakage of refrigerant is a rare occurrence. Ammonia leakage response plans are usually in place at large sites. Leakage rates for ammonia based systems are typically below 1% per year.

Within the oil, gas and chemical sectors, systems are subject to HAZOP and other stringent reviews during the design stage, resulting in a high intrinsic level of basic system integrity. Safety planning and staff training are both critical to plant operation, and are well-‐funded and implemented.

Leakage of refrigerant can be significant on systems containing large quantities of HCFC or HFC based refrigerants. These systems have tended to be built to a lesser construction standard, primarily for cost saving reasons and due to reduced safety risks associated with those refrigerants.

Maintenance The level of maintenance typically applied to industrial type systems is variable and largely depends on the system owner and the criticality of the system to the overall industrial process or output.

For critical systems high standards of preventive maintenance are common. Within the oil and gas sector, where large propane systems are common, leaks are simply not tolerated. Maintenance standards are very high, principally because of the huge cost of downtime which can be tens or



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hundreds of thousands of dollars per hour. Loss in a production environment is instant when the process stops, unlike a cold store which may be able to hold over for many hours without refrigeration, before temperatures rise to a point where losses begin.

Some systems are maintained to a very high level while others are maintained at a low or inadequate level. Most owners of ammonia systems are acutely aware of the ramifications of an ammonia leak and therefore most apply routine maintenance at least to a standard sufficient to avoid significant leakage.

Guidance Due to the energy consumption of this sector and the potential for energy efficiency improvements there is a considerable amount of design guidance available including:

• Sustainability Victoria: (http://www.resourcesmart.vic.gov.au/documents/BP_Refrigeration_Manual.pdf )

• NSW Office of Environment and Heritage: (http://www.savepower.nsw.gov.au/RefrigRprtLowRes.pdf )

Companies within the oil, gas and chemical sector often have extensive in-‐house standards based on years of accumulated experience, such as the Shell ‘Design and Engineering Practice’ series.

4.7. Refrigerated transport Transport refrigeration is essential in today's society, to preserve and protect food, perishable goods, flowers, drugs and medical supplies in the cold chain. This sector includes transport of refrigerated products with reefer ships, intermodal refrigerated containers, refrigerated railcars, refrigerated marine and air applications, and road transport including trailers, diesel trucks and small trucks and vans.

Mobile refrigeration equipment is required to operate reliably in much harsher environments than stationary refrigeration equipment. Due to the wide range of operating conditions and constraints imposed by available space and weight, transport refrigeration equipment typically have lower efficiencies than stationary systems. This, together with increasing use of refrigerated transport arising from the much wider range of transported goods, home delivery and greater quality expectations are placing considerable pressures on the industry to reduce the energy consumption of refrigerated transport. The reduction in energy consumption, however, cannot compromise the temperature control of the transported food products which is governed by legislation.

The two main components effecting the relative emissions of refrigerated transport solutions include the insulated body or envelope and the refrigeration unit.

4.7.1. Refrigerant HCFCs and HFCs have traditionally been the refrigerants most widely used in refrigerated transport applications, with the most common refrigerants for transport refrigeration applications currently being HFC based. Ammonia, hydrocarbons and carbon dioxide are also being used to a lesser extent.



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Refrigerant charges range from less than 1 kg (refrigerated vans) to several kilograms (trucks, trailers and reefer containers) to several tonnes on board large fishing vessels.

Leakage rates in this sector are high and typically range from 15 to 20% for road/rail applications and from 20 to 40% for marine applications (AIRAH TEWI Guide).

The international transport refrigeration OEMs state that ‘the use of HFCs in transport refrigeration systems must be complemented with responsible HFC use. The transport refrigeration industry commits to providing products with the best LCCP that is technically, and financially available. This will differ across the various products and applications, and will continuously be evaluated as technology develops. In addition to significant operating efficiency improvements, the industry has already taken action to reduce refrigerant emissions by designing leak tight equipment, minimising system charge and recycling refrigerants.

The industry actively promotes the following general principles that should be followed for all refrigerants:

• Use in tight (leak proof) systems that are leak tested and then frequently monitored after installation to eliminate direct refrigerant emissions

• Recovery, recycling and reclaiming of all refrigerants • Training of all personnel involved in the refrigerant handling • Compliance with standards, which govern proper refrigeration installation and maintenance • Equipment sizing to match the specific need, thereby minimising the refrigerant amount • Design and installation and operation to optimise energy efficiency • Minimise number of connections through which refrigerant flows.

4.7.2. Energy intensity Traditionally, insulated shipping containers are used to transport foodstuffs and other cold chain goods in the refrigerated container industry. Domestic road transport has utilised fibreglass trailer construction for its improved insulation capacity. Australian Design Rules impose a 2.5m width restriction on road vehicles which leads to a slight reduction in our thermal efficiency compared to what can be achieved in the US due to their 2.6m vehicle width.

The majority of refrigerated road transportation is conducted with semi-‐trailer insulated rigid boxes. Many factors are considered in the design of the envelope of a refrigerated transportation unit including:

• design exterior conditions (temperatures, solar etc) • design interior conditions (temperature and humidity) • insulation properties of materials and methods of construction • envelope sealing and infiltration of air and moisture • tradeoffs between construction cost and operating cost • physical deterioration from shocks and vibrations.

Passive reflective coatings are available to significantly reduce the heat load (cooling load) when applied to the external surface of containers. There is also significant potential for thermal bridging through these structures.



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Energy efficiency Very small units are electronically driven off the primary vehicle motor, but most units utilise a separate power source for the refrigeration equipment. This will typically be an integrated diesel motor, but is sometimes a standalone diesel generator on road and rail container transport or an electronic motor driven off batteries that are charged over night.

Like all diesel motors, the manufactures have to weigh up fuel efficiency gains against the new emission standards that typically reduce fuel efficiency. New compressor designs and PLC/onboard computer programming have led to many efficiency gains.

Low-‐GWP alternatives

Currently the vast majority of refrigerated transport applications are based on HCFC or HFC technologies.

Container refrigeration systems based on CO2 as a refrigerant have been developed in Germany and are being trialled by four international shipping companies. It has been reported that these units offer a 23% reduction in emissions when compared to standard HFC based units.

Flammable gases and ammonia have not been introduced because of the wide variety of unskilled mechanics working on the equipment and the equipment’s exposure to shock and crash due to its environment.

Maintenance The Australia and New Zealand Refrigerant Handling Code of Practice Part 2 includes guidance on maintenance for mobile applications.

4.8. Other sectors

4.8.1. Residential refrigeration Residential refrigeration means the refrigerators and freezers commonly found in domestic or non-‐commercial use. These are whitegoods typically purchased from big box retailers.

Existing fridges and freezers are mainly HFC, HCFC and CFC-‐based systems. The main questions for these systems are end-‐of-‐life refrigerant emissions controls and questions of product stewardship. Programs to recycle the metals from disposed consumer goods are well progressed however refrigerant reclamation is typically not practised.

New fridges and freezers are typically either HFC based or hydrocarbon (HC) based systems. Government gas regulators have formed the opinion that because hydrocarbon-‐based systems are, fully sealed, rarely leak and generally contain less than 150 grams (often less than 100 grams) of refrigerant, these are not a fire safety issue. End-‐of-‐lifeemissions is a safety/materials handling issue.

The majority of refrigerators and freezers commonly available in the retail market are covered by MEPS and energy labelling programs. Some thermoelectric and 3-‐way LPG fridges are not covered by MEPS/energy label rating. Some high value homes are beginning to install custom-‐built fridges using



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commercial sector technology; these can be very inefficient and are not covered by MEPS. Another issue for this sector is the growth in extra features that often reduce energy efficiency e.g. ice makers, butter softeners etc

4.8.2. H is for Heating Heating systems also fall under the broad definition of HVAC&R.

Reverse-‐cycle air conditioning Air conditioning, which is considered in this discussion paper, includes heating.

Issues relating to use of reverse-‐cycle air conditioning in residential sector in locations where overnight temperatures are very low need to be better understood. Both efficiency and capacity are reduced, while icing of the condenser coils can also be a problem. Strategies such as drawing inlet air from under houses with suspended floors, or using heat sources such as tank water to pre-‐warm inlet air to the evaporator could be useful. Flexibility and overall system design, appropriate sizing and controls are all significant.

Given climate change, improving building efficiency and much higher ownership of air conditioners, there is likely to be a shift away from separate gas heating to reverse-‐cycle equipment. In terms of capital cost, if planning to install air conditioning for cooling anyway, reverse-‐cycle is much cheaper than gas heating. Also, the most efficient reverse-‐cycle air conditioners are lower emission and similar or lower running cost to gas.

As customers in some geographic areas are purchasing reverse-‐cycle air conditioning as their principal heating source in winter, and removing other heating sources (such as gas heating), this adds demand on electricity distribution networks.

Boilers Other forms of heating include boilers producing hot water for HVAC heating systems or other hydronic systems such as radiators.

Boilers have been reported to be poorly implemented within the Australian HVAC industry. Poor system design, control and maintenance result in poor efficiencies and increased direct and indirect emissions. Boilers are also used for low and high temperature hot water heating for domestic and commercial purposes. Boilers can use gas, oil, electricity or biomass as the heating source.

Hot air heaters Furnaces (gas or oil) are also used to provide heat for air-‐based heating systems. The safety aspects of gas based heating are already covered in gas regulations.

Electric resistance heaters Whether duct mounted or standalone these systems are typically highly inefficient and emission intense.



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4.8.3. Hot water heat pumps Heat pumps are also used in other non HVAC&R applications such as domestic hot water heating and pool heating.

These units use refrigerants; however, since they are installed predominantly outside, are self contained and factory built and commissioned their scope for leakage and or efficiency intervention is small. The superior efficiency of these systems over traditional electric water heaters is well documented.

Hot water production is a major source of energy consumption and there is a very large number of existing hot water heaters that are energy inefficient. One energy efficient alternative is to convert electrical resistor based systems to heat pump systems, where a heat pump is either a solar system or an inverter based heat pump system.

Strong growth is expected in heat pump hot water services. These have many advantages over solar hot water and the best models are equivalent to 80% solar contribution. A comparison with solar systems is needed as that is the main competing technology rather than traditional gas or electric resistance systems. Some units use sealed CO2 refrigerant compressors and circulate water between the unit and the storage tank, so they are easy to install. For people with PV and low feed-‐in tariffs, these systems can run at very low cost when there is excess solar electricity available.

Pool heat pumps could also become a significant market, especially where they run on PV. But they would need to be integrated with pool covers and other energy efficiency measures if the system capital cost is to be reasonable.

Demand management – Australian Standard AS 4755.3.3 is available for water heaters covering DRED. Their ability to be connected to load control tariffs offered by electricity distribution networks and retailers present a significant demand management outcome and customer savings on running costs. This should not present a technical issue for manufacturers as most of their products are already suitable for such tariff connection. Heat pumps for pool water heating do need to be managed appropriately to ensure that they have cooled appropriately prior to energy removal to eliminate damage to the unit).



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5. Proposed solutions

5.1. Section introduction Sections 2, 3, and 4 of this paper all point to a myriad of issues and problems that exist or are perceived to exist in the wide world of HVAC&R emissions.

This section lists all of the solutions that have been suggested or implied by various industry stakeholders. At this stage no prioritisation, costing or assessment of any of these solutions has been undertaken.

These solutions are roughly grouped into subject areas around the five pillars underpinning the transition; Professionalism, Regulation, Information, Measurement, and Emission abatement (PRIME). In addition there are some solutions that relate to non stationary HVAC&R applications and some solutions that relate to complementary actions and activities.

5.2. Professionalism

5.2.1. An HVAC&R industry council Solution: The industry should form an umbrella group to help coordinate policy and concentrate action. A uniting body made up of industry stakeholders that can provide a sustained communications strategy and policy framework would benefit all sectors of the industry

Notes: A single point of reference for the HVAC&R industry would assist with engagement with the Australian Government and also assist in building an improved public profile for HVAC&R. If such a council is formed it should have the charter to seek change rather than oppose change. The industry also needs to recognise that it will be difficult to have a ‘united body’ that represents all industry stakeholders without considerable good faith on all interests’ part. Other industries achieve this and the HVAC&R industry should be able to. It is possible for individual stakeholders to ‘agree to disagree’ on some issues however the power of an industry council would focus on where consensus can be achieved.

One suggestion is that this group could be a sub group of an existing body (e.g. ASBEC). This would give the group an immediate presence, and their work some credence, without the pain of trying to establish itself and work its way through the various networks.

An alternative suggestion is that, due to the resources and time that would be required to establish another formal representative group within the industry, a less formal "coalition of industry stakeholders" is formed whereby those existing industry organisations that are willing to work towards the common aim of delivering low-‐emission HVAC&R meet regularly to progress the project. A statement of aims would be developed and MOUs developed and signed.

5.2.2. Objectives of low-‐emission HVAC&R Roadmap Solution: The industry needs to document a vision and set of objectives for the transition roadmap.



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5.2.3. Funding and resources The industry needs to consider how any new initiatives might be funded or resourced.

Funding the transition Solution: Industry will need to consider sources of funding and resources for any new initiative.

Notes: Any industry assistance or change program will require funding and the allocation of resources. Possible sources for funding include:

• Australian government – Through the return of the equivalent carbon price revenues to the industry, through existing programs, through new programs and initiatives.

• State and territory governments -‐ Through existing programs, through new programs and initiatives.

• End users – Through a levy charged on HVAC&R imported equipment. • Industry sector organisations – That may see a return on investment from these activities,

such as property, cold storage, supermarket, retail. • Industry – Through voluntary contributions incentivised by tax deductions • Individual – Through voluntary contributions incentivised by tax deductions

Chasing Government and other organisations for funding may prove to be a tiresome and thankless task.

Funding training Solution: Advocate to government for a fairer share of education funding and some decently funded and managed education programs that recognise the HVAC&R industry as a cornerstone of the economy.

Note: The HVAC&R industry provides more employment and turnover than many other industries that appear to have attracted more comprehensive education assistance.

Solution: Approach HVAC&R related philanthropists to bequeath or donate some scholarship funds to universities involved in HVAC&R education.

Solution: Set up an HVAC&R industry training fund where tax free donations can be made to fund training development and delivery priorities.

Note: Commentators suggest that training needs to be commercially viable.

Funding research Solution: Set up an HVAC&R industry research fund where tax free donations can be made to fund research priorities.

Notes: Similar to the Ammonia Research Foundation (ARF) created under the auspices of the International Institute of Ammonia Refrigeration (IIAR). Proceeds are used to fund research within ammonia refrigeration. Research projects are prioritised by the IIAR research committee and funding allocated by the IIAR Board based on the committee’s recommendations.

Solution: Negotiate with government to impose a legislated levy on all imported HVACR equipment.



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Notes: This could achieve the scale of funding required and could underpin funding for policing of MEPS etc. i.e. a user pays system taking funding pressure off of government budgets.

5.2.4. Industry data Solution: The HVAC&R industry needs to collaborate to produce some hard evidence-‐based data on key performance data outlining the current state-‐of-‐play of the HVAC&R industry in Australia.

Notes: As the HVAC&R industry is fond of saying “you can’t manage what you don’t measure, to measure is to know”. However, we don’t practice what we preach and there have been many gaps highlighted in the available data on the HVAC&R industry. The HVAC&R industry needs to know a lot more data about the current situation while it addresses improvements for the future. Benchmarking energy consumption and leakage rates is a way real value can be obtained from industry data. The following are some suggested areas where current and accurate data is required:

• Direct and indirect GHG emissions by sector. • Refrigerant leakage rates – by sector and by system type. • Refrigeration system safety incidents– frequency and type, by sector and by system type. • HVAC&R energy use– by sector and by system type. • Breakdown on quantity of imported bulk refrigerant, by type, used for servicing needs as

opposed to new charge for HVAC&R equipment. • End-‐use submetering data for buildings e.g. HVAC, lighting, plug loads. • Building infiltration rates – by class and size of building. • Duct and system sealing/leakage – how extensive. • What is the ratio of regulated (NCC) building works versus less-‐regulated (non-‐NCC) building

works (i.e. refurbishments and upgrades). • The proportion of buildings with natural ventilation/hybrid ventilations as opposed to 100%

mechanically ventilated. • Data on fault types and associated maintenance costs found during recommissioning,

building/system audits and tune-‐ups. • Research list, what research and development in HVAC&R field is occurring in Australia. • Industry training list, what training is available and where and at what level. • Data on the significance of maintenance for running costs. • Data on the existing design practices and the extent that they deviate from good practice. • Review of Australian design practice against world’s best practice. • Data relating to the relationship between water and energy use in a HVAC system. • Performance data relevant for benchmarking HVAC systems across different sites. • List of incentive schemes for energy efficiency work. • How can the effectiveness of the SGG equivalent carbon price be monitored? • Existing data on the effectiveness of the current government incentives. • Data relating to the relationship between water and energy use in a HVAC system. • Performance data relevant for benchmarking HVAC systems across different sites (relates to

the potential for NABERS HVAC rating). Note: The Department of Sustainability, Environment, Water, Population and Communities have commissioned a study of the refrigeration and air conditioning) industry in Australia, as a follow-‐up to previous studies. The report will attempt to estimate the total economic activity within the



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refrigeration and air conditioning industry including the total value, number of people employed, and number of businesses involved. It will also update earlier analysis of the installed equipment base, the total energy consumption of RAC equipment, and direct and indirect greenhouse gas emissions from various equipment segments and trends in equipment and working gases. The study will also report by refrigeration type (HCFC, HFC and low-‐GWP) and include a chapter on low-‐GWP alternatives (natural and others) and their current market penetration. The objective of this project is to ensure that the Australian Government has an up-‐to-‐date source of information on the refrigeration and air conditioning industry in Australia. The report and data is expected to be published to the DSEWPaC website in the 2nd half of 2013.

Solution: The HVAC&R industry should encourage government to update industry data (e.g. Cold Hard Facts) periodically, every three years has been suggested.

5.2.5. Sharing data and collaboration Solution: The HVAC&R industry, property industry and commercial refrigeration industry needs to work on ways that building and system data can be shared without breaching commercial or confidential interests.

Notes: There is a lot of data is out there but it tends to be hidden or protected, mandatory or voluntary disclosure of data would be a good thing. For example PCA used to be a good source of data but now major property owners tend to keep property data confidential.

Solution: Introduce greater collaboration in industry when developing information materials, fact sheets and design guidelines. Collaboration encourages knowledge and skill sharing.

5.2.6. International experience Solution: It is important for industry and government to review international experiences in order to generate and share ideas for future programs.

Notes: It is important to leverage off international experience and learn about technologies and programs where industry groups have taken a leading role in driving water and energy efficiency improvements overseas. Building effective links between industry and government in order to share experiences and generate ideas for future programs.

5.2.7. Low-‐emission HVAC&R defined Solution: Industry needs to discuss and agree what low-‐emission HVAC&R really is and what target for emissions they would like to achieve.

Note: Is some form of a definition needed based on the current emission levels from the industry and a vision of what a low-‐emission HVAC&R industry should actually look like (including a statement of what is in and out of scope). A definition of low-‐emission HVAC&R may need to be discussed and defined at the international level (IIR, ASHRAE, etc). The Australian industry first needs accurate data in terms of the emission rates for refrigerants by sector and the energy use of HVAC&R systems, also by sector. Quantification may be difficult given the range of systems this industry covers and their differing applications (different climate zones etc).



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5.2.8. Fee structures Solution: Improving the fee structure to reward good design outcomes would be a useful incentive for best-‐practice design.

Note: Current design fees are usually structured to relate to system size not system efficiency which creates a disincentive for optimised design where longer design time results in smaller and less capital intensive systems.

5.2.9. Design engagement and feedback Solution: The industry should consider how best to provide feedback to designers on the final outcomes of their designs.

Notes: Typically the real level of engagement of designers drops away after completion of tender documents. Designers will often remain commissioned for the construction phase; however the flow of information to designers is often poor so there is inadequate feedback on the cost effectiveness of their strategies, particularly innovative strategies. The length of the construction period, the many unknowns, and competitive fixed fee bargaining creates a high probability of low fee bidding on the hope things will work out. This can result in tension, inadequate communication and issue resolution, poor commissioning attendance, and substandard outcomes when things don’t work out.

5.2.10. Trade training

Trade courses Solution: Update VET/TAFE course competencies and teaching resources to include HVAC&R system optimisation and energy efficiency issues as core training issues, not just as elective subjects.

Note: System optimisation and energy efficiency issues are core concepts that are covered in the competencies in the relevant Certificate III and IV qualifications.

Solution: Update VET/TAFE course competencies and teaching resources to include HVAC&R system maintenance for energy efficiency.

Note: While system optimisation and energy efficiency are embedded in existing units, the HVAC&R advisory group recently identified a need for new competency standard units covering Energy Efficiency Assessment for residential, commercial and industrial HVAC&R applications. These will be developed in the next round of continuous improvements.

Solution: Update VET/TAFE course competencies and teaching resources to include effective and appropriate use and handling of alternative refrigerants

Solution: Update VET/TAFE course competencies and teaching resources to include HVAC&R system Communication Skills with focus on promotion of financial benefits of EE systems.



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Note: The competency standards units are primarily technical in nature, describing the “what” and the “how”. A competent trainer would emphasise the business and financial benefits of energy efficiency (the “why”) as part of the training delivery.

Notes: To fit more units into a qualification you may have to decide what to remove. A better path might be to have the basic refrigeration course for a trade qualification and then have post trade courses that, once achieved, can be shown on the recipient’s trade licence certificate. This way Australia can create specialists in certain fields and also recognise these extra skills and competencies.

Solution: Subsidise the training delivery of the updated units to improve take-‐up.

Notes: There are a number of opportunities for employers to seek subsidised training for post-‐trade qualifications, Certificate IV and above, such as the National Workforce Development Fund, Critical Skills Investment Fund as well as other State/Territory funds.

Solution: Industry organisations should consider Group Training Schemes, similar to those operated by the Master Builders Association.

Apprentices Solution: Upgrade the trade apprenticeship to a Certificate IV rather than a Certificate III course.

Notes: This would enable more units to be fitted into the qualification. There are already examples where trade apprenticeships have been upgraded to Certificate IV, for example the Electrical/instrumentation apprenticeship which is a Cert IV in Western Australia.

Solution: Industry organisations, major companies and SMEs agree to and fund increased apprentice training.

Notes: If industry can show a commitment to increased apprentice uptake government are more likely to provide additional funds.

Solution: Industry and Government collaborate to set up an apprenticeship training fund based on a levy of the HVAC&R industry. This is proposed as a similar scheme to the Western Australia Building and Construction Industry Training Fund which allows the fund to give targeted incentive bonuses to employers who train apprentices.

Skills maintenance Solution: Include minimum skills maintenance requirements into ARCtick and any other occupational licence arrangement.

Notes: Licence conditions should require proof of ongoing training and skills development. This may require amendment to the Ozone Regulations if administered by ARC. Germany has a requirement that technicians must do training every 2 years to maintain their licensing. Australia could mirror that requirement and make it a condition of National Occupational Licensing that the licensee has undertaken update training within the past 2 years, prior to granting of a license renewal.



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Solution: Develop an internet based skills maintenance system that issues updates and alerts and make licences holders of all types undertake a professional development online course every quarter to maintain licence. This could give the Australian industry a world class internet based compulsory training scheme to maintain skills and knowledge.

Notes: The following topics have been suggested for skills maintenance: • Preventative maintenance for energy efficiency • Refrigerant leakage – System auditing, issue identification and issue resolution. • Working with natural refrigerants • Passive design 101 • Emissions management

Online courses are not fraud proof so an alternative could be for courses for license retention to be conducted annually and passing the final exams upon conclusion of the training made a requirement for license retention. The logistics of managing quarterly/annual licence retention exams would be considerable and costly. There would be difficulty in providing access to remote contractors, people with poor computer skills and people with language or literacy issues. There may be resistance from license holders to formal training.

Solution: Develop an industry endorsed skills maintenance or CPD activities list that licence holders can undertake to meet minimum CPD points or credits for licence retention.

Notes: This is proposed as a similar scheme to ones currently operated by Engineers Australia, Australian Institute of architects etc. The professional development activities will need to be readily available, easy to access, inexpensive or free, and not time consuming, for example access to on-‐line information/resources.

5.2.11. University training Solution: The Australian HVAC&R industry should engage with university level education providers on the possibility of, and process for, developing undergraduate engineering degree program in ‘Building Services and Refrigeration’. Note: Undergraduate engineering degrees are common in other countries, which may have models and content that could be adapted for Australian use. Engagement with CIBSE and Massey University (NZ) is encouraged for this solution.

Solution: Existing University based training in engineering and related courses should include energy efficiency and emission reduction as a key core component including Australian based case studies, data and financial benefits of energy efficiency.

Notes: This is relevant to commercial and residential building engineering courses and units, mechanical engineering courses, including courses and units for architects and other building professionals. Visiting professors from industry, international experts, Master’s courses following graduation and PhD paths for undergraduates are all suggested methods.

Solution: The Australian HVAC&R industry should engage with university level education providers on the possibility of, and process for, developing a professorship and a study facility in energy and



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thermodynamics with specialisation options for candidates in refrigeration, air conditioning, building services and food technology.

Solution: The value of invigilating basic units based on HVAC&R into end-‐user training courses (e.g. agriculture training and the like) should be assessed.

Notes: This would distribute required HVAC&R knowledge directly to end users.

5.2.12. CPD training Solution: Develop Industry based training for building professionals to assist in professional development.

Notes: Industry needs flexible, practical and up to date training. Many businesses are not overly concerned about formal qualifications but do want training recognised as professional development/skills maintenance. Individuals are more interested in qualifications. Cost is an issue, but less so than time. Businesses need to commit to implementing key actions and opportunities arising from training, otherwise the time and cost is wasted. Delivery methods are critical and the industry probably needs to explore innovative delivery vehicles (e.g. massive open online courses (MOOCs)) that satisfy the need.

5.2.13. Trade licensing Solution: Industry should collaborate and develop a single agreed proposal for occupational licensing for the HVAC&R industry.

Notes: Practitioners should be certified to prove that training has been undertaken. NOLA is currently investigating options for a national licensing scheme for individuals and contractors operating in the refrigeration and air conditioning fields. A Regulatory impact statement was published and individual industry stakeholders made individual submissions on individual preferences to NOLA. The results of that consultation and review process are not currently available.

Solution: Industry should promote a licensing system based on or similar to the Danish system.

Notes: Current licensing arrangement does not cover mechanics working with any natural refrigerant nor does it address energy efficiency issues.

5.2.14. Professional registration Solution: Industry should collaborate and develop a single agreed proposal for the professional registration of building services and refrigeration engineers operating in the HVAC&R industry.

Notes: Currently there is no requirement for building services engineers or commercial/industrial refrigeration engineers to be registered to practice in Australia. There are requirements for design certification in some states.



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5.3. Regulations, standards and government programs

5.3.1. Measuring success Solution: It is important for all levels of government and industry to understand which Government programs have been successful in improving energy efficiency and reducing emissions. For all government programs (including completed programs) the achievements or outcomes should be measured where possible and the results shared with the wider industry.

Notes: This could be achieved through publication of case studies, evidence of actual cost and benefits, evaluation reporting etc. Some commentators have suggested that measuring the success of programs should be the responsibility of the Productivity Commission as opposed to the Department(s) managing the program to avoid conflict of interest in publishing accurate program performance assessments. An important aspect here is ensuring that in the design of any government program, monitoring and evaluation are built into it.

5.3.2. Intellectual property Solution: Mandate that in all government funded energy efficiency/HVAC&R related work programs intellectual property is to be publicly shared and disseminated appropriately (respectful of commercial-‐in-‐confidence requirements).

Notes: Some of the Government sponsored programs that have been successful in sharing knowledge include Green Building Fund (AusIndustry) Commercial Office Building Energy Innovation Initiative funding (Sustainability Victoria) and Energy Efficiency Training Program (NSW OEH). Not only did the government fund or co-‐fund the activities but the programs required knowledge sharing through case studies etc. The outcomes and results should be publically available and disseminated (i.e. copyright in reports should be handed over) but the intellectual property in the innovation itself (i.e. patents) should remain with the inventor.

5.3.3. National Construction Code Solution: Residential building regulations should address peak demand as well as energy performance requirements. Regulations need to incorporate performance requirements for both heating and cooling for all climate zones.

Solution: The impact of minimum efficiency standards and the stringency increases within commercial building regulations should be quantified prior to significant additional increases.

Notes: The actual outcomes of the previous increases in stringency (within Section J) have not been quantified in terms of actual costs and benefits (and perverse outcomes). If government or industry doesn’t know how effective previous stringency increases are, on what basis can future stringency increases be designed?

Solution: Passive design (insulation, glazing and shading) for all building works should be better audited.



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Notes: Under the current system building certifiers need designers to show them that the design documentation complies with Section J. However, there seems to be no onus on certifiers to determine whether what is built/installed actually reflects what was documented.

5.3.4. Mandatory commissioning Solution: Industry should collaborate to develop a Proposal For Change (PFC) to propose minimum mandatory building commissioning requirements to be included in NCC/BCA V1 for Class X to Y buildings.

Note: Mandatory requirements for building commissioning were included in the public comment draft of the changes to BCA 2010 but were removed prior to publication. Industry believes commissioning and optimising operations through tuning and recommissioning should be fully explored and implemented before increasing stringency standards for HVAV&R systems.

Solution: Industry should only support the ‘Independent’ commissioning model, not other models.

5.3.5. Mandatory submetering and monitoring Solution: Introduce mandatory requirements within the NCC that all large refrigeration and air conditioning systems (above XXX kWr) should be submetered and charge monitored.

5.3.6. Mandatory energy efficiency maintenance Solution: Encourage the state based regulators to mandate the energy efficiency maintenance requirements of the NCC.

Notes: Mandatory maintenance for energy efficiency is included within the NCC but is not enforced in State/Territory regulations. This may be a matter that needs to be discussed and resolved at the COAG level. National mandated requirements would drive demand for energy efficiency maintenance skills in industry. Similar suggestions include:

• Develop and mandate installation of appropriate monitoring, diagnostic and shut-‐down systems.

• Mandate regular maintenance to an appropriate standard. • Develop and mandate smart monitoring and shutdown systems to minimise safety risks and

leakage.

5.3.7. Building air tightness Solution: Adopt an international test method for measuring/validating air tightness of all public, commercial and residential buildings and include minimum building air tightness requirements within building regulations/National Construction Code?

Notes: This solution is proposed for residential and commercial buildings. Other issues may need to be addressed such as IEQ, moisture and condensation, biological contaminants. Building rating and simulation tools would also need to align on treatment of building air tightness and infiltration/exfiltration rates.



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5.3.8. Upgrades and minor works Solution: Create a mechanism for minor upgrades to comply with minimum NCC standards

Notes: A lot of upgrade and refurbishment work in existing buildings is not covered by the NCC and is therefore less regulated than new buildings. A minor upgrade (definition varies by jurisdiction) does not need building approval so, although new appliances or equipment are covered by MEPS, many items such as insulation levels, control requirements, and the like are not. The extent of this work, the implications (training, cost) and the benefits (CO2 reduction) should be considered with a view to creating a mechanism for all work to comply with the minimum NCC/industry quality standards either via regulation or an industry mechanism.

The current Section J energy efficiency requirements do not apply to refurbishments of existing buildings unless the building fabric is to be altered in the refurbishment. There is currently no onus on the building owner to improve the thermal performance of existing building fabric during an upgrade.

5.3.9. Documentation standards Solution: Introduce a “Chain of Custody of Documentation” system or methodology for systems of refrigerating capacity greater than XXX KWr or for buildings of greater size than XXXX m2. The methodology would outline the minimum information that must be provided and retained with a building for its lifecycle (design, install, commission, recommission, fine tune, operate, maintain, decommission).

Notes: Previously justified as a HVAC HESS project, the issue of accurate and trusted building information being maintained through a building/system life-‐cycle remains an issue in the industry and a barrier to energy efficiency improvement and emission reductions.

Solution: Introduce a Building Log Book program for commercial buildings.

Notes: Previously justified as a HVAC HESS project, if buildings over a certain size were required to have an on-‐line building log book, which registered the maintenance of critical mechanical services and had to be completed at least once every 6 months you would create a data base that identified size and type of working refrigerant bank, peak load hot spots and cooling demands, etc as well as optimised energy efficient safe systems.

Solution: Introduce a mandatory requirement in NCC/State building regulations that building or system energy efficiency/emission controls should be annually inspected and operations validated.

Notes: Similar to the mandatory requirements and existing arrangements for annual inspections which validate essential fire and smoke services, HVAC&R systems could be inspected annually to ensure they are still operating at the same or better emissions level as their original design.



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5.3.10. Facilities for maintenance Solution: Industry should produce/develop a new Code of Practice or standard to specify the minimum access and facilities that need to be provided to HVAC&R plant and equipment for the purposes of ongoing maintenance. Code should clearly state the minimum WHS requirements for access for maintenance personnel.

Note: Current standards require access to be provided but do not specify any minimum requirements or provide methods to determine compliance. Access and facilities provided for the maintenance of systems and plant is often inadequate. Coils and fans that cannot be reached, roof mounted equipment with no safe access, high level plant installed without access platforms, no lighting, power or drainage facilities for maintenance providers. If safe and adequate access is not provided maintenance is considered too dangerous or expensive and is not carried out. Not providing adequate access may contravene new WHS laws and regulations.

5.3.11. CTIP finance Solution: the HVAC&R industry should advocate to government to allow refrigeration related industries associated with manufacturing, agriculture and cold chain food distribution and storage access to the existing CTIP program?

Notes: refrigeration related industries associated with manufacturing, agriculture and cold chain food distribution and storage are emission intensive HVAC&R industries that should have access to existing government incentive schemes, particularly SME operators.

5.3.12. Refrigeration safety standards Solution: Continue to support the Standards Australia work to revise and update AS/NZS 1677 design safety standards and encourage greater dialogue and consultation with the broader industry.

Note: Industry continues to support the revision of AS/NZS 1677.2 and the further development of ISO 5149 for potential alignment. Any changes should be subject to industry/public review and comment and the normal standards development processes. Caution with expanding scope of AS 1677 beyond safety, other issues could be covered in a separate standard or guide. The update of AS/NZS1677 needs to cover those environment aspects that could clash with safety aspects. The current edition of AS/NZS1677 has caused confusion in the industry as to the legality of fusible plugs, bursting disks and when and where pressure relief valves are required. The update should not stipulate the choice of refrigerant with respect to the environment but should include requirements for leakage and ensuring pipe fractures and the like don’t occur.

Solution: Continue to support the development of a series of industry derived Codes of Practice (CoP) or Guidelines to cover the safety and legal requirements for refrigerant handling and application.

Notes: It should also be noted that a Safe Work Australia Code of Practice has specific legal status and consideration could be given to providing guidelines as an alternative or the industry can self codify without it being a SWA endorsed Code. Eventual coverage should include all refrigerants



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including new codes on flammable refrigerants (A2 and A3), CO2, and new generation synthetic refrigerants, as well as revising existing codes on ammonia, and fluorocarbon refrigerants.

Solution: Industry and Government need to review when and where the AS/NZS 1677 standards are required or referred to for regulatory compliance. What regulations and codes require compliance with the standard in which sectors and in which applications?

Notes: These standards are referred to in a range of industry codes, standards and regulations and some review and harmonisation should be undertaken so it is clear to the industry technical service providers and end users to understand when and where application of AS/NZS 1677.2 is required by law. There is general confusion and ignorance within the industry on what regulations and standards are applicable. There is a real need for end users to easily identify the compliance requirements for ALL refrigerant types. Codes of Practice are a very good tool on providing an overall ‘map’ of the relevant regulations and applicable standards across the various jurisdictions.

Solution: Industry and Government should agree to make safety standards mandatory.

Solution: Industry and Government should create a multi-‐lateral working group to rigorously and systematically assess risks associated with all refrigerants and provide guides for selection using a strong evidence-‐based approach.

Notes: The working group should include manufacturers, end-‐users, designers, contractors, emergency services, environmentalists, economists, sociologists, regulators and politicians.

5.3.13. CoP for flammable refrigerants Solution: Develop the CoP for flammable refrigerants as a high priority as it may be easier and quicker to deliver an interim CoP than a revised AS/NZS 1677.2.

Notes: There are documents available overseas that may be adopted in Australia. There has been research that shows industry/employer associations are the most trusted by businesses for information. Industry bodies have a role here and with collaborative process with regulators could have complementary support from each jurisdictional regulator.

Solution: Industry and Government should agree to make compliance with CoPs mandatory and a licence requirement for ARCtick licence holders.

5.3.14. CoP for HFC refrigerants Solution: Review and revise the current CoP’s for HFC refrigerants (published in 2007) to include safety.

Notes: Current CoP’s only cover environmental aspects as related to the ozone protection and synthetic greenhouse gas management legislation. They need to be updated to include safety and potentially be endorsed by WorkSafe Australia. The CoPs would then provide the regulatory roadmap for compliance and could reference AS/NZS1677 (or its replacement) as well as other



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applicable standards. Revised Code should also cover the new generation low-‐GWP HFC synthetic refrigerants.

Solution: Industry and Government should agree to make compliance with CoPs mandatory and a licence requirement for ARCtick licence holders.

5.3.15. Refrigerant handling Solution: Review and revise the three current refrigerant handling Codes of Practice.

Notes: Specifically look at leak minimisation, construction standards, refrigerant containment systems, energy efficiency, (re)odorising of refrigerants and the use of the one-‐off cylinders.

Solution: Compliance with the three revised refrigerant handling Codes of Practice should be a condition of the ARCtick licence.

5.3.16. System age Solution: Old (> 10 year) plants, particularly with small operators, need to be identified and it be made mandatory to have a safety compliance audit and performance audit carried out at least every 2 years.

Notes: A bit like a rego check on old vehicles. Should systems have a fixed life span set as there are many old large plants with leaking solder joints and work hardening of the copper components resulting in leakage of refrigerant? Joint okay one day, failed the next day. This approach would need to have an evidenced-‐based case before considering it as a mandatory requirement. It may not be easy to find the age of ‘older’ systems or the date they were installed for operation?

5.3.17. Government programs – MEPS

Lack of part-‐load coverage Solution: Improve the MEPS scheme to more thoroughly test and report system efficiency under a wider range of operating conditions (e.g. more part-‐load test points).

Notes: Recommend moving away from COPs and EERs as the basis of rating. These full-‐load rated metrics can be misleading for equipment at part load conditions. This could be covered by moving to a true SEER type MEPS rating and should mirror the US or European standards. Also recommend adding additional points in the SEER calculation and publishing all of the points so that others can do their own weighting (i.e. integration).

Lack of claims validation Solution: MEPS administrator should provide publicly available information outlining the check test/validation of claims program as applied to MEPS.

Notes: Several industry commentators have questioned the level of check testing within the program.



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International consistency Solution: MEPS should be reviewed to bring the implementation timelines into line with European (EU) or USA practice.

Optimum not minimum performance Solution: The MEPS program should be reviewed to incorporate a focus on the top performers as well as the lowest performers and Japan’s “Top Runner” program is suggested as an appropriate model.

Notes: MEPS test results should be used to identify and reward the highest performing equipment as well as penalising the poorest performing. The ‘Top Runner’ is a government program aimed at continuous improvement across a range of different industries.

Residential refrigeration Notes: To allow manufacturers sufficient planning horizons.

Solution: Introduce MEPS and energy labelling for thermoelectric and 3-‐way LPG and gas powered refrigeration equipment.

MEPS for heat pump water heaters Solution: Industry should support introduction of MEPS for heat pump water heaters (and all other water heating technologies).

Note: There would need to be separate MEPS for domestic hot water and pool heating.

5.3.18. Government programs – HVAC HESS Solution: Industry should re-‐assess the existing project list/measures from the HVAC HESS scheme to determine which projects are still viable or high priorities for the industry. Use this assessment and its conclusions to inform the current HVAV HESS program review being undertaken by DCCEE.

Notes: Extensive research, consultation and justification behind HVAC HESS objectives, industry need to determine what HVAC HESS projects, that remain un-‐delivered, should be pursued (if any) and why.

5.3.19. Government programs – In from the Cold Solution: Industry to review the existing strategy to determine how it could be better aligned with the move to low-‐emission/low-‐GWP systems within this sector. Use this review and its conclusions to inform the current program review being undertaken by DCCEE.

Notes: Extensive research, consultation and justification behind In from the Cold objectives, industry needs to determine what projects should be pursued and why. The Australian market size may be too small and diversified for industry to justify many of the programs identified in the ‘In from the Cold’ strategy. It may more practical to adopt some of the Eco-‐Design strategies from Europe when they are fully developed and implemented. Any revitalised program should focus on benchmarking performance rather than prescribing technologies and should also focus on direct emissions.



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5.3.20. Government programs – Mandatory disclosure Solution: Instigate mandatory disclosure of energy used in all government buildings.

Notes: This has the potential to be a major driver for efficient HVAC installations in a wide range of building types and system applications. This would facilitate MJ per m2 per annum benchmarking for different public facilities and could include mandating publication of energy use /performance, monitoring mechanisms, commissioning and retrofitting strategies that were used to improve performance. This aligns with NSEE framework policy of Government leading the way in energy efficiency.

Solution: Mandate monitoring and publication of energy use for all public buildings.

Solution: Extend the CBD scheme to all other building types, including residential and more commercial types of buildings.

Notes: Government is scheduled to expand the CBD scheme from 2014.

It is important to encourage private building owners to disclose building and system performance data around water and energy efficiency. Private building owners are a large percentage of the market and they are driven to minimise utility costs in order to remain competitive in the market place. A large number of city office buildings are more than 30 years old, privately owned, and trade in floor spaces of less than 2000 m2 etc. The mandatory disclosure CBD scheme its current format misses a lot of them. These buildings need to be targeted somehow, perhaps by mandating that every building’s energy consumption be disclosed annually and perhaps also mandating minimum acceptable levels.

5.3.21. Government programs – NGER scheme Solution: The NGER scheme should be expanded to include more of the HVAC&R industry.

Notes: Currently some organisations within the industry have to report under NGERS. Is it feasible to lower and/or expand the reporting threshold to include more of the HVAC&R industry? Can the current relevant information collected through NGERS be made available to the HVAC&R industry?

5.3.22. HVAC&R design standards Solution: Reduce the prescriptive nature of requirements in current HVAC&R standards in favour of outcomes-‐based requirements.

Notes: Prescriptive standards are one way to do things performance based outcomes is another pathway. Conceptually performance based approaches sound good but in reality they may enable poor design. Who validates the performance compliance? Who knows what the right solution is? Who accepts the risks? State Electrical Regulators insist on prescriptive standards when it comes to appliance design and manufacture. Many commentators have suggested that safety standards should never be performance based.



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5.3.23. Cool/Cold rooms design standard Solution: Industry should develop an energy efficiency design standard for small cool rooms and cold stores. Note: Currently no Australian energy efficiency design standard or guidelines exist for this application. There are overseas based documents available.

5.3.24. Commercial HVAC&R demand management Solution: The HVAC&R industry should adopt emerging international standards and open protocols that facilitate the implementation of demand management

Notes: Emerging international standards specify a feature-‐rich ‘two-‐way’ signalling system for commercial air conditioner and refrigeration. Examples include OpenADR 2.0, and ZigBee Smart Energy Profile 2.0. Commentators suggest that there is a clear need for as single national standard and that the government/COAG may need to intervene.

5.3.25. Residential air conditioning design and installation standard Solution: Complete the residential air conditioning standard currently being developed (but stalled) at Standards Australia.

Notes: Wide ranging and diverse industry support for this standard to be completed.

5.3.26. Residential air conditioning demand management Solution: Introduce regulation to require the manufacturers or suppliers of air conditioners for sale in Australia to provide AS/NZS 4755.3.1 compliant demand reduction interfaces in their products and require electricity distributors to develop and offer demand response programs on their networks.

Notes: There is already some current progress on incentives for DRED in some residential markets. Manufacturers of air conditioners for the residential market have or are gearing up for significant spread of AS4755.3.1 compliant units across their ranges. Only one electricity distributor is taking advantage of this functionality to deliver demand management for these units through addition of a DRED. This impetus must not be lost but needs to be built upon to ensure that seamless demand management of air conditioners provides significant options for electricity distributors managing power supply on their networks.

5.4. Information

5.4.1. Industry information and online repository Solution: Create a low-‐emission HVAC&R “street directory” or “IP repository” website that helps people find all of the validated energy efficiency information that is available, a one-‐stop-‐shop for guides and tools and other information related to low-‐emission HVAC&R. Information (branded or not) could be deposited by a variety of sources to a central database.



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Notes: Currently a lot of useful and freely available information is located in diverse locations on various government and industry websites. A big issue is who and how information is verified. There may be value for both technical service providers and end users/operators to provide a single trusted source point for this information. This solution could be linked with training and other information dissemination activities. Problems with such a central repository include the resources required to manage it, the logistics of it being kept up-‐to-‐date and possible legal implications of people using information that is later proven to be flawed.

5.4.2. The value of HVAC&R Solution: The industry needs to create some general awareness information about the value of the HVAC&R product. Technical service providers, end users, government stakeholders and the general public all need a better awareness of how critical the industry is and how it underpins much of the Australian society and economy.

Note: Well put together case studies, simple comparisons (company X saved the equivalent of 200 cars....), news reports etc. The International Council of Air conditioning, Refrigeration, Heating manufacturers Association (ICARHMA) has also recognised this issue of lack of recognition of the HVAC&R industry and is working on a draft document that describes the value the industry brings.

5.4.3. Grants and incentives Solution: The industry needs to create some training and awareness information about the use of government grants and incentives designed for HVAC&R.

Notes: Many HVAC&R technical service providers and end users do not know how to correctly access the existing grants and incentive schemes, including completing applications and meeting program eligibility requirements, leaving schemes that are underused and do not meet their potential target market.

Solution: Industry should document all of the alternative options or programs available for low interest or no interest finance for energy efficiency intervention work.

Notes: Document and explain schemes such as Low Carbon Australia, Environmental Upgrade Agreements, Government incentive schemes, energy performance contacts, environmental performance contracts and any other options available to end users in a single reference source. A fact sheet may be an appropriate format to share this information with end users

5.4.4. Fee structures Solution: HVAC&R industry should develop a rigid, structured relationship between fees charged and the responsibilities of the designer for use by end users.

Notes: There needs to be a direct relationship between fees charged and the volume/quality of information provided to the entity requesting the design in return for the fees paid. There also needs to be a direct relationship between design information and technical and legal responsibilities by the designer for the design prepared. There are examples in other countries of a rigid, structured relationship between fees charged and the responsibilities of the designer. In these countries the



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quality of information, the level of information, the responsibilities relating to these deliverables and the milestones that a project may be divided into are enshrined in law.

Solution: Industry needs to promote to clients, funding authorities and end users that low-‐emission design requires additional work up front. Industry should publish a range of typical hours of professional work likely to be required for a certain low-‐emission task, design, modelling, analysis, research, validation and the like by defining the complexity of a typical task and an estimate of the hours required for the task.

Notes: Low-‐emission design and installation, whatever the operational gains and returns on investment, requires additional effort and therefore fees up front. The Fire Engineering Guidelines include estimates of hours for tasks of varying complexity for fire engineering alternative solutions. A similar publication for low-‐emission HVAC&R design and analysis may help raise awareness and assist with reviewing fee structures.

Solution: Industry needs to promote energy performance contracting as an alternative to fixed fees.

Solution: Rather than focus on fees, industry needs to build awareness of clients and owners on the importance of utilising well trained designers to analyse life-‐cycle costs and TEWI calculations rather than design/build to minimum initial cost arrangements.

5.4.5. HVAC&R design data Solution: Develop a design guide or handbook outlining the current HVAC&R design rules and load estimation factors based on current regulations, systems and practices.

Notes: Current design guides, load estimation programs and building simulation programs may not accurately cover the current Australian climate, internal heat loads, occupant densities, design set-‐points etc. Many existing design rules were developed based on cost but costs and focus have changed. Revising AIRAH application manual DA09 to include updated climate data and internal and external heat loads could be a good vehicle for this. Design guides need to cover the HVAC&R design strategies and options, control options, current construction methods, etc and include evaluation strategies for selecting different types of HVAC&R system/delivery approaches.

Load estimation calculations and system design methodologies need to be updated to reflect contemporary methods and materials and a standardised set of ‘rule of thumb’ figures or defaults produced for pre-‐design calculations and design analysis.

5.4.6. Internal design/comfort conditions Solution: Review and revise the comfort conditions that are being used as the basis for design and operation.

Notes: The HVAC&R design process requires nominated internal comfort or design conditions so that loads can be calculated and controls set up. A 21°C/50% RH condition is not an uncommon specification however comfort can be provided at higher temperatures (with significant energy



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savings). The industry needs to have a serious discussion about comfort conditions for design and operation.

Solution: The HVAC&R industry should endorse the ASHRAE 55 thermal comfort Standard for use in Australia and provide guidelines to practitioners on how it can be applied to save energy while maintaining comfort.

Notes: The HVAC&R design industry should focus on increasing the flexibility of internal comfort conditions beyond mean temperature. There are a number of parameters that influence personal comfort which if utilised could contribute to a more comfortable and a more water and energy efficient internal environment.

5.4.7. Air-‐cooled/water-‐cooled cost analysis Solution: Carry out and publish an energy efficiency/cost analysis of water-‐cooled versus air-‐cooled systems, in various scenarios (cooling tower, evaporative condenser) and sectors (refrigeration, air conditioning), and climate zones to help inform designers during their decision making processes

Notes: A cost analysis in various scenarios and sectors based on plant size, configuration, controls, location, cost, etc would be a useful tool for increasing the awareness on whether an air-‐cooled or water-‐cooled system can be beneficial for particular sites. Cost should not be the sole determining factor when comparing water-‐cooled and air-‐cooled systems. Prioritising energy use ahead of water use due to the associated carbon emissions will negatively impact the creation of holistic HVAC systems. Both water and energy use in HVAC systems can be reduced simultaneously. It is important to take a whole-‐of-‐system approach when calculating the true reductions in energy and water via the installation of an air-‐cooled system.

Solution: Develop a study quantifying the water-‐energy nexus of various HVAC systems (i.e. quantifying the amount of energy use associated with water use and vice versa) to ensure the use of both resources is accounted for when considering upgrades/retrofits.

Note: To encourage a holistic systems approach to HVAC&R design, operation and management.

5.4.8. Commercial refrigeration design approach Solution: A total-‐system design approach for commercial air conditioning and refrigeration should be documented by the industry for the commercial refrigeration sector.

Notes: There is a large proportion of existing supermarkets where air conditioning and retail refrigeration are separate systems resulting in a lost opportunity for energy efficiencies.

5.4.9. Co-‐generation/Tri-‐generation Solution: The industry should develop a report on co-‐generation/tri-‐generation world’s best practice.

Notes: To build awareness about methods of implementing these systems.



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5.4.10. Alternative technologies and practices Solution: Support the development case studies covering the successful and or unsuccessful implementation of alternative technologies and practices.

Note: Information is an appropriate response. Make available information about alternatives and provide the information necessary to demonstrate why/when/how these alternatives are superior. The demonstration of superiority will rely on good information about the performance of properly implemented existing technologies.

Individual site audits/feasibility studies and case studies have been effective in stimulating change on a site level. Individual businesses respond well to case studies of similar sites that have installed new technology with positive results. When a new technology can be demonstrated as operating efficiently with tangible reductions in operational and/or construction costs businesses are more likely to consider it. Open dialogue of the pros and cons of design, installation and operation issues allows fast tracking of new ideas with less cost risk to the end user.

Traditionally HVAC&R case studies associated with awards or high end building projects tend to be engaging and attractive but devoid of much in-‐depth technical content, lessons learned, true costs, actual validated savings, technical instruction, implementation issues and resources for use/used. Convincing case studies need to focus less on graphic design and more on capturing and sharing technical information and know how. Independence is important when developing case study materials.

5.4.11. CPD training Solution: Develop Industry based training for building professionals to assist in professional development.

Notes: industry needs flexible, practical and up to date training. Many businesses are not overly concerned about formal qualifications but do want training recognised as professional development/skills maintenance. Individuals are more interested in qualifications. Cost is an issue, but less so than time. Businesses need to commit to implementing key actions and opportunities arising from training, otherwise the time and cost is wasted. Delivery methods are critical and the industry probably needs to explore innovative delivery vehicles (e.g. massive open online courses (MOOCs)) that satisfy the need.

Solution: Develop training for architects, services engineers, designers and contractors so they can incorporate features that complement energy efficient HVAC solutions.

Notes: The following are some suggested topics (typical):

Back to basics – A CPD course for designers, contractors and technicians to cover the fundamentals of HVAC&R; thermodynamics, refrigeration cycles, heat flow, heat transfer, comfort, design conditions, load calculations and basic HVAC&R system types and characteristics.



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Integrated design, passive solutions and low-‐emission HVAC&R – A CPD course for designers and contractors to cover methods of collaborating on appropriate building design that minimises peak cooling and heating loads, can reduce the need for heat rejection, and the quantitative design analysis on the effect of passive design solutions, to validate such designs. Include information on natural ventilation and detailing for building air tightness.

Utilising Controls to diagnose HVACV&R for energy efficiency – A CPD course for engineers and facilities managers covering the utilisation of intelligent control networks in building services to improve water and energy efficiency. Training could be in the form of a seminar, documentation, or presentation on how to utilise control and monitoring systems, i.e. BMCS,EMS or data loggers as a diagnostic tool for analysing building energy use and energy efficiency.

Co-‐generation (power and heat) and tri-‐generation (power, heat, cool) – A CPD course for HVAC&R designers and contractors including technical information, lessons learned and best-‐practice management processes for co-‐generation and tri-‐generation systems within buildings/sites. Identify and resolve technical impediments to the optimum application of these systems in buildings.

Objectives and opportunities of low-‐emission HVAC&R – A CPD course for architects and end users about the objectives and opportunities of low-‐emission HVAC&R. Could be delivered via Information sheets with CPD sessions (RAIA, ACA) offering additional information.

Holistic HVAC&R the systems approach – A CPD course for HVAC&R designers and installers and system procurers to encourage them to take a more holistic ‘systems’ approach to HVAC&R including case studies and ‘how’ to’ methodologies.

Demand management and HVAC&R – A CPD course for HVAC&R designers and installers outlining successful electrical demand management strategies that can be applied in commercial buildings including demand reduction devices, thermal energy storage systems and other solutions. Also information to allow them to inform building owners and operators of the cost savings and potential income streams that can be unlocked by demand management strategies. Time-‐of-‐use metering and the implications for HVAC&R system selection could also be covered.

Boilers control and optimisation – A CPD course for HVAC&R designers and installers outlining successful hot water and steam boiler control and optimisation and waste heat recovery options. Information could be disseminated via information sheets with CPD sessions offering additional information.

Refrigeration systems – best-‐practice in design, installation and maintenance – A CPD course for refrigeration system designers and installers outlining current best practices and techniques for optimum design and installation of low-‐emission refrigeration systems in commercial and industrial applications.

Optimising existing HVAC&R systems for low-‐emission outcomes – A CPD course for HVAC&R system designers, installers and technicians, facilities managers, and end users about methods to get the best low-‐emission performance out of existing systems including building/system tuning,



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recommissioning, retrocommissioning, optimal supervisory control strategies, fault detection and diagnosis and maintenance approaches. Also reducing GWP of existing refrigeration plant including evaluation and refrigerant replacement.

5.4.12. End user information and awareness There is a strong role seen for industry bodies in providing end user information and awareness. Industry provided educational information through industry bodies, manufacturers and suppliers, training websites, as well as the development of ‘applications’, computer software and other helpful tools are all seen as potential paths for industry participation in end user awareness issues.

Fact sheets – System operators Solution: Develop a series of concise fact sheets for HVAC system owners and operators, perhaps leveraged off the HVAC HESS operation and maintenance guide.

Notes: Perhaps existing documents are too long and overly detailed for the purposes of system operators. The use and dissemination of concise fact sheets (e.g. ten top HVAC efficiency tips or a one page guide to HVAC system monitoring) to get the message across to operators could be useful. Providing these fact sheets to industry facing professionals could help disseminate best-‐practice information to industry.

Suggested topics (typical) – for owners and operators:

• Ten top HVAC efficiency tips. • Benefits and practicalities of submetering; getting systems installed and monitored. • One page guide to HVAC system monitoring. • Maintenance for energy efficiency, Why? How? • Flammable refrigerants, do’s and don’ts. • Stop that refrigerant leak! Why leaks are dangerous and cost owners money. • Ductwork leakage, why it wastes energy and money and how it can be stopped. • Consequences of running refrigeration plant outside of design conditions. • How systems are used effects energy and water consumption, here is why. • Why I need to responsibly dispose of and recycle my unwanted system and how. • Best-‐practice management of heat transfer surfaces within HVAC&R (coil cleaning). • Time-‐of-‐use electricity pricing, demand reduction and HVAC&R. • How to stimulate low interest finance for energy efficiency upgrades. • Demand management, what it means and what it can do for my building. • How systems should be sized and the energy impact of oversizing.

Fact sheets need to incorporate high-‐quality information, not just generalisations, and should be linked/refer to case studies where possible.

Systems life-‐cycle guide for owners Solution: Develop a comprehensive guide providing step by step easy to understand instructions on system sizing and the relationship to through life operating costs of smaller heating and cooling units in residential situation to larger capacity for commercial organisations.



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Notes: A key need for end-‐users is to get investment decision makers to understand life-‐cycle costing in the context of HVAC&R so that lowest first costs solutions do not always dominate procurement decisions. This guide could increase awareness of sizing, technology and control issues and their relation to ongoing operation and maintenance costs. This knowledge would help put owners on the right direction to selecting someone who can help them with their design. This should be only intended for increasing awareness around life-‐cycle issues and should not be treated as a complete design guide. It is also important that any guide recognise that system size can be reduced or even eliminated by utilising passive design in combination with retrofit activities.

Cost-‐benefit analysis guide for owners Solution: Provide end users with solid and trusted cost-‐benefit analyses proving the economic merit of optimising and maintaining system efficiency is crucial.

Note: In the absence of other incentives proven and documented cost benefit analysis of maintenance is critical to motivate end users to procure energy efficiency maintenance.

Return on investment guide for owners Solution: It is appropriate that industry should document and promote simple payback calculation methods for SME HVAC&R practitioners/end users and smaller projects, but a fuller return on investment calculations(such as NPV or IRR) for larger projects and sophisticated clients.

5.4.13. myHVAC&Rsystem.com.au Solution: Develop an energy version or augmentation of mycoolingtower.com.au to include energy efficiency calculators, benchmarks and energy efficiency audit information for HVAC systems.

Notes: An online portal for HVAC &R energy efficiency information, advice and technical resources would be very useful for building owners and operators, particularly the SMEs operating in the sector. Constructing information resources which are free from complex legal and technical nomenclature is vital to end-‐user uptake.

5.4.14. Natural refrigerants Solution: Develop an application guide for designers and installers to improve their knowledge, understanding and trust of natural refrigerant solutions and applications.

Notes: A table of applications with a traffic light signal to designate if the application is suitable or not for Hydrocarbon, Ammonia and CO2 based refrigerants could be a useful tool. Industry consensus does not appear to have been achieved on the most appropriate application of natural refrigerants. Overseas developed documents may be a suitable basis for development of such an application guide.

Solution: Recommend an industry lead advocacy campaign to building owners and developers on the benefits of natural refrigerants and their suitability.



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5.4.15. Ammonia refrigerants Solution: Recommend industry develops a series of fact sheets covering the successful use of ammonia overseas and in Australia, e.g. Heathrow terminal.

Solution: Recommend that ammonia plant greater than 50kg charge and intended to be located in suburban areas for residential/commercial applications be provided with water scrubbing systems for system relief vents.

Notes: Mandating this practice is not well supported; however, formalising this and similar practices could remove one of the barriers to the wider application of systems based on this natural refrigerant in the commercial refrigeration and air conditioning sectors. If this practice is to be validated, it will also be necessary to establish a design standard. Such a standard does not presently exist, but it is a topic on the list of research projects prepared by the IIAR research committee. Water efficiency needs to be a key consideration when considering water scrubbing systems. Also need to consider trade waste aspects as ammonia in sewers can be a health and safety risk to sewer workers and a nutrient load that must be removed at sewage treatment plants

There are several other ways of mitigating the effects of an ammonia release. The pros and cons are the topic of the IIAR research project. This issue requires a quality engineering approach from project to project and should be considered in concert with charge reduction techniques.

5.4.16. Passive design Solution: Develop a guide quantifying the impacts that passive design solutions can have in terms of reducing the load on HVAC systems in commercial building energy retrofit opportunities.

Notes: Providing commercial building owners with a brief and concise guide to passive design and retrofit opportunities, particularly those opportunities relevant to commercial office and retail buildings given their extensive use of HVAC systems.

Solution: Develop a guide showing how HVAC&R professionals should quantify the performance aspects of particular passive design or alternative passive technology solutions.

Notes: Providing HVAC&R professionals with a brief and concise guide to quantifying the performance aspects of passive design will help them to provide building designers with the evidence-‐based design advice that they require.

5.4.17. Best-‐practice HVAC&R installation Solution: Develop a best-‐practice HVAC&R design and installation guide focused on energy efficiency.

Notes: High standards of design, installation and maintenance need to be promoted. This was previously proposed as an HVAC HESS project. Could be used as the basis of an accreditation scheme.



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5.4.18. Building tuning and recommissioning Solution: Greater emphasis should be placed on building tuning and recommissioning procedures and tools, through mechanisms such as industry best-‐practice guidelines and/or government policy (i.e. solution 5.10.1 XXX)

Note: NSW OEH is developing a guide to HVAC optimisation. Most buildings, even those recently constructed and correctly commissioned, can benefit from building tuning for energy efficiency.

5.4.19. Commercial refrigeration Solution: Industry should ensure that end users, suppliers, installers, as well as maintenance contractors are conversant with energy efficiency and optimisation issues for commercial refrigeration equipment.

Notes: This could be done through training, information sessions and case studies. Industry and government could take shared responsibility for implementing this.

5.4.20. System age Solution: Industry should develop an education/awareness program based around energy efficiency rather than the risk of direct refrigerant emission from a leak.

Notes: 10 year old systems, cool rooms and cabinets are going to have major issues around degradation of the insulation, linted up coils, corrosion of fans and the like that causes major increases in energy consumption. An industry guideline covering what to look for and how to improve systems may be useful.

5.4.21. Optimising and maintaining efficiency Solution: Industry should develop guidelines on the financial and risk assessment of existing HFC/HCFC based systems for owners and service providers to help them decide priorities for system replacements/upgrades.

Solution: Industry should develop guidelines on the best-‐practice methods for energy-‐efficiency interventions and system upgrades.

Note: NSW OEH is in the process of developing an Energy Saver HVAC Optimisation Guide which will be available from mid-‐2013.

5.4.22. Maintenance for energy efficiency

The value proposition for energy efficiency maintenance Solution: The industry needs to build a value proposition for the benefits of good maintenance, case studies and independent testing that proves, to end users, the cost savings and additional benefits from good maintenance.



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Solution: The industry needs to promote submeters and benchmark checking as a means of identifying reducing performance and the need for maintenance.

Notes: Case studies and guidelines should include maintenance for different building classes, different types of systems and different climate zones.

Other suggested means to increase maintenance of HVAC&R equipment include: • HVAC&R industry actively promoting maintenance to their clients/community through

various media avenues, • Industry integrating maintenance programs into their capital contracts as part of the whole

package.

Maintenance guides Solution: Encourage owners and operators through industry awareness programs to procure energy efficiency maintenance requirements.

Notes: Costs and benefits of energy efficiency maintenance need to be demonstrated and documented to encourage better uptake. Standard clauses could be written for procurement guidelines.

Solution: Develop a short and simple best-‐practice guide on energy efficiency maintenance for owners and operators and a more comprehensive technical and practical guide for technicians and contractors.

Notes: Document procedures for an initial audit and review, plus follow up rectifications, plus set up of ongoing monitoring system. Maintenance guides for contractors may be required across all sectors. Guides should be freely available to encourage use. Guides should leverage off existing published materials (HVAC HESS GUIDE, AIRAH DA19) and provide a simple and clear summary. Split landlord/tenant incentives often apply in maintenance procurement and any guide should address this directly.

OEH Energy Saver HVAC Optimisation Guide which is in development for a mid-‐2013 release may also help on this issue.

Maintenance training Solution: Create training modules based on the content of the maintenance guides. Water and energy efficiency should be part of the training programs.

Note: Training should be developed and delivered by industry sector, e.g. residential, commercial, automotive, industrial to ensure training is relevant and affordable.

Maintenance accreditation Solution: Develop a maintenance contractors energy efficiency based accreditation program.

Note: Accreditation program could be based on Guides and training resources. Program could be administered by ARC. Program would need to be linked to a policy framework and RTO.



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5.4.23. Residential air conditioning design and installation standard Solution: Use the Residential air conditioning design and installation standard to educate residential air conditioning customer as to minimum standards for an installation (what to look for, questions to ask, how to recognise a qualified installer).

Note: This could be covered in a fact sheet

Solution: Provide training and promotion to consumers and contractors of appropriate sizing for modern more efficient homes.

Note: The AIRAH FairAir website is a good start, but it needs to include more options for high efficiency houses, such as advanced glazing and higher levels of insulation. Some of the state and territory agencies may have useful information on this topic.

5.4.24. Residential air conditioning demand management Solution: Develop residential air conditioning consumer awareness material to address the questions; will my comfort be compromised? How often will the units be managed? How much will I save on my bill or be rewarded for having my air conditioning managed by the electricity distributor?

Notes: Consumer concerns remain a barrier to demand reduction.

Solution Address manufacturers/supply side to ensure that compliance with AS4755.3.1 does not require additional work at time of installation (i.e. PCB swap out), by managing consistent message through distribution/sales/installer channels regarding manufacture and supply of DREDs, and logistics of getting DREDs to end-‐user and installed.

Notes: Technical logistics with DREDs remain a barrier to demand reduction.

5.4.25. Residential maintenance Solution: Industry develop and deliver customer awareness sheets.

Notes: If customers can be educated to understand that maintenance gives so many benefits (energy efficiency, reduced wear, prolonged air conditioning life, healthier air delivery, reduced noise, reduced environmental impacts etc.) and value these in dollar terms, customers would at least be mindful of the need for maintenance.

5.5. Measurement

5.5.1. HVAC system rating Solution: Develop a consensus and transparent HVAC rating and benchmarking tool to:

• provide an overall measure of HVAC performance • provide separate ratings for heating and cooling systems



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• consider the direct and indirect water, energy and refrigerant use associated with each individual system

Notes: This will provide more detailed information to building operators and allow more targeted improvements in HVAC system performance and assist in the identification of efficient and inefficient systems. The ranking of systems also places a building’s HVAC system into the context of the wider industry and will increase the recognition of systems requiring maintenance, retrofits and replacement.

The relevance has been questioned by some with regards to buildings with current NABERS Energy ratings but it is supported in all other sectors. However, NABERS measures Whole-‐building performance and does not single out the HVAC systems. As such a building that has good NABERS rating now may have a poorly performing HVAC system that is compensated for in other areas. Similarly MEPS, as a rating tool focuses on a particular piece of plant rather than the system as a whole.

The rating tool could be in the form of an ‘app’, a software program, or a spreadsheet based system. Perhaps integrating a HVAC rating into the NABERs rating tool in order to maintain consistency and increase the relevance of the HVAC rating tool.

“Calculating Cool” is an existing HVAC HESS project with very similar goals.

5.5.2. Refrigeration system rating Solution: Develop a rating tool for rating proposed commercial refrigeration systems based on TEWI or similar life-‐cycle assessment.

Notes: Any tool needs to be made available in a computer program, application, spreadsheet or quick assessment sheet and should be ‘open access’ to allow anyone complete a basic analysis. A simplistic rating system for commercial refrigeration products would make the acquisition of efficient systems less problematic and may act to increase competition between manufacturers to design more efficient systems.

The model would necessarily need to make default assumptions and the resulting limitations of the model parameters must be explicit. May be difficult to develop and implement given the huge variety of systems, configurations and operating variables. Perhaps start with a cool room calculator (linked with 5.8.16 XXX) and expand from there.

Solution: Develop a benchmarking tool for custom-‐made commercial refrigeration addressing energy use intensity based on useful product cooling so that there is incentive to minimise standing losses and other parasitic loads. Where the primary system function is storage only a metric such as per unit of product stored or storage volume or similar would be appropriate.

Notes: This tool would provide drivers for industry to identify improvements in real terms. The tool would act as an incentive, especially for the smaller end of the market, to determine the



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performance of systems. The tool should also have the capacity to facilitate monitoring of any optimisation measures implemented.

End users with existing HVAC&R infrastructure would require a cheap and accurate way to obtain the measurements and information needed to apply the tool.

5.5.3. Water rating Solution: Include a water rating or assessment in any rating tool developed to assess or benchmark HVAC&R systems.

Notes: Quantifying the amount of energy associated with water use and vice versa within various HVAC systems will provide a basis for designing systems that reduce the need for both resources. This would contribute to a more holistic approach that recognises the more complicated relationships that exist between energy consumption and HVAC&R operation.

Solution: Government could consider expanding the WELS scheme to include HVAC&R equipment.

5.5.4. Validation of product claims Solution: Develop an Australian industry mechanism that can be used to validate the efficiency, environmental and safety performance claims made by new technology providers, the design fraternity, contractors, owners and the like.

Notes: These objectives cannot be achieved through existing mechanisms like MEPS based on Australian Standards. Perhaps some sort of industry accreditation scheme whereby an independent group can review and assess new technologies in partnership with the system manufacturers/suppliers. The big issue is who and how claims are verified. Much marketing information is technically light and can give false impressions of the true performance; trust is paramount in a risk averse sector. In the USA for example the Air conditioning, Heating and Refrigeration Institute (AHRI) undertook this role by developing performance measurement standards that manufacturers had to adhere to before making claims. This could be an extremely expensive process and the Australian Industry may be too small to justify it. It may be possible to partner with organisations such as AHRI and make this a more global initiative. There is also a need to get innovative products (e.g. building materials) incorporated into rating schemes (e.g. NatHERS). This also requires testing and validation.

TAFE or CSIRO may have currently unused facilities that could be adapted as suitable test facilities. It has also been suggested that developing a working relationship with and providing expert impartial industry information to the ACCC could be an effective way of implementing this solution.

5.5.5. Technology comparison tool Solution: Industry should assist in establishing comparative measurement and verification (M&V) tools to demonstrate relative energy efficiency across all cooling technologies.



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Notes: One of the challenges of improving energy efficiency and emission in general is to compare alternative solutions. Providing a level playing field for comparison would be a priority from an end user point of view. There is a need for an unbiased, vendor-‐neutral decision-‐support tools that can assist in informing HVAC&R clients of the feasibility of emerging technologies and optimal technology investment options. Providing cost and implementation comparisons between the different emerging technologies, and properly implemented existing technologies, and a checklist to know which ones are best for particular applications would be a good start. A common approach is to use estimation tools to attempt to make comparisons on a fair and consistent basis. It can be difficult to create a tool that covers all possible situations that might arise. Comparisons would generally only be practical for a specific set of conditions which may not result in the correct answer when technology is implemented in different environments. Comparisons need to be careful to encompass whole-‐of-‐system performance including maintenance procedures and effective system operation. The comparison tool would need to encompass energy and water efficiency when operating at different loads (i.e. not just peak loading).The expectations of accuracy from any such tool must be realistic and should focus on aspects that give large effects. Any comparison tool must be extensively verified against measured data and have its limitations and constraints well defined. Development of such a tool may be expensive and this could be taken on by organisations such as AHRI and IIR who have much greater resources. There is already a lot of work going on with respect to LCCP calculators and any Australian tool(s) would need to be internationally consistent.

Solution: Industry should develop an agreed technology pathway roadmap for new technologies.

Notes: Industry could build consensus on the directions that should be taken to change the business as usual approach to technology. This could then tie into possible regulatory/ rating frameworks rather than tying into design practitioners as the path to implementation.

5.5.6. Benchmarking existing systems Solution: Industry should collaborate to ensure that the best available data is available to allow owners and operators benchmark the performance of existing HVAC&R systems.

Notes: Benchmarking the energy consumption and refrigerant leakage rates of existing systems can add value in all sectors of the industry. Industry specific figures for kWhr/m2/per annum need to be compiled from best available information. Where information is not available collection mechanisms should be put in place.

5.5.7. Metering and monitoring Solution: Develop an incentive scheme to provide free submeters/check meters to electricity users to facilitate their monitoring of the electricity consumption of individual HVAC plant and systems.

Notes: Demonstrating the benefits of submetering for electricity consumption, through case studies with demonstrated energy savings and operational benefits could greatly enhance their uptake. Demonstrating that access to higher quality, on time system performance data makes the operators job easier and more effective would help build the business case for best-‐practice monitoring.



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Solution: The use of building and system submetering with upload to an application such as REF (which stands for Rapid Efficiency Feedback), administered by Buildings Alive, or ABER (which stands for Australian Building Energy Repository), administered by CSIRO, could assist building owners in benchmarking their HVAC systems against other like buildings.

Notes: The uploading of the building data to an open and transparent online register could assist in disseminating advice and best-‐practice between stakeholders.

Solution: The industry should collaborate to create a comprehensive Australian data base on building energy use incorporating metering and monitoring data from applications such as NABERS, Green Star, REF and ABER.

Notes: Creating a large Australian database of building energy data, with high resolution sub system energy data such as HVAC, lighting, plug loads, could be used for generating or validating building energy models as well as quantifying and benchmarking building energy use and feed back into design practice. Data base would ideally be administered by a commercially neutral trusted data custodian, e.g. government, CSIRO, university.

Solution: Build awareness of how operators could use remote monitoring and web-‐based energy trending to create building energy use profiles and provide training on how to interpret the profiles to improve energy efficiency.

Solution: Build upon the findings of the HVAC HESS Wireless Metering project to further justify and quantify the business case for wireless metering and provide recommendations to industry.

5.5.8. Maintenance records Solution: Create an industry based online register of refrigeration system maintenance. Owners of equipment with charges of greater than XX kg in aggregate could be required to keep a register of all equipment and maintenance regimes, charge type and size, replacement and top up rates etc.

Notes: Owners could outsource the establishment of the register to their mechanical service contractors who could fill in the proforma register provided via the online service. Equipment owner can download in the case of a random inspection of the register by government.

5.5.9. Fault detection and diagnosis Solution: Research projects to evaluate the feasibility and energy savings potential from automated fault detection and diagnosis (FDD) tools in the Australian context should be undertaken.

Note: Government sponsorship should require IP sharing.

5.5.10. Cool/cold rooms design standard Solution: Industry should develop an energy efficiency benchmarking standard or data base for small cool rooms and cold stores. Note: Currently no Australian benchmarking information publically available.



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5.5.11. Benchmarking electricity use Solution: Energy retailers should investigate the possibility of including benchmark figures in electricity bills for commercial or industrial customers.

Notes: When a commercial or industrial consumer gets their power bill it shows the benchmark figure and where this consumer sits relative to it.

Solution Electricity retailers should include general site energy use intensity with utility bills as a performance indicator.

Notes: The regular provision of this information to energy users could raise awareness of energy use and help identify energy efficiency opportunities. A best-‐practice guide might be able to cover many of these issues.

5.5.12. Managing consumption Solution: Empower energy users with tools to harvest real time information on their electricity consumption so that they can exercise some control over their consumption, independent of electricity retailers.

Notes: Energy retailers are more interested in (maximum) demand reduction rather than net energy use reduction and consumers may need additional tools to incentivise reduced energy use if overall energy consumption is to be targeted.

5.6. Emission abatement

5.6.1. Product stewardship Solution: HVAC&R product manufacturers and suppliers should engage in discussions with product stewardship experts and government to discuss the form and cost of a possible Australian product stewardship scheme for HVAC&R products (including equipment, materials used for HVAC&R systems, and refrigerants).

Notes: There should be an industry wide discussion on this issue. Does Australia need HVAC&R equipment suppliers and manufacturers to adopt a product stewardship scheme? What would such a scheme look like and what are the main barriers to implementation? How can the recycling and reuse of HVAC&R plant and equipment be incentivised or better managed? Australia may need to leverage what other nations have implemented and learn from them. Equipment suppliers suggest that any mandatory program should only be undertaken after a detailed study of the quantum of the problem.

Solution: The industry should discuss the potential of developing an endorsement system for suppliers who conform to stewardship and quality/environmental management systems.



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Solution: The industry should discuss the potential of adopting/developing product stewardship principles for systems, i.e. a stewardship position taken by designers, constructors, operators and maintenance organisations.

Notes: There is split responsibility across these organisations and it would be good to find: 1) a way that each becomes more aware of, and takes greater responsibility for, the full system life-‐cycle; and 2) a way to improve the association of responsibility for individual system performance between each of these organisations and also the end users.

5.6.2. Quality/design assurance Solution: Industry should develop and promote a voluntary energy efficiency design assurance scheme for the designers and installers operating within the refrigeration industry.

Notes: These types of schemes exist in other countries and include mandatory requirements for quality and environmental management systems. Those who sign up for the scheme receive a computer program and training in its use. The software forces the designer to limit heat exchanger temperature differences to certain maximum values, to use compressors of a certain minimum efficiency/maximum compression ratio and to limit fan motor power to a certain percentage of evaporator/condenser capacities. The intention is that the design parameters used will result in a minimum ‘good practice’ level of energy performance. Such a scheme could also address other issues such as annual performance and system stewardship.

5.6.3. Research, development, innovation and commercialisation Solution: Industry should develop a proposal for the establishment of a cooperative research centre (CRC) for research, development, and innovation in the field of HVAC&R.

Notes: The industry should form a view on the need and delivery path to attain a higher level of research and innovation in HVAC&R. The Australian HVAC&R industry is a technology taker rather than developer. If technology development received Government funding it would most likely have a constraint that manufacture would also have to occur in Australia. The Government would have to totally change its attitude towards Australian manufacturing and funding to justify a cooperative research centre. As an alternative it may be possible for the industry to form strategic links with an existing CRC.

Solution: Industry should form an expert group of academics that have an interest in the HVAC&R space and leading industry experts, to develop up a set of HVAC&R research priorities. These priorities could then can be proposed to Final year/Masters students and introductions to industry facilitated to help make the research happen.

Notes: The results of the research projects conducted by master’s students should be publicly available in order to maximise research outcomes and share industry knowledge (eg. knowledge portal). Significant effort needs to be made to translate findings of research into communication material that can be read and understood by all stakeholders in the HVAC&R industry (e.g. facilities managers).



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5.6.4. Innovation showcase Solution: There should be a special innovations display area, and arrangements and incentives provided to showcase new and innovative HVAC&R technologies at industry exhibitions such as ARBS and the like.

Note: Independently assessed products would be most powerful.

5.6.5. Incentive schemes/trials for new technologies Solution: Introduce incentives to encourage businesses, end users and technical service providers to trial new technologies. Learnings must be publically reported so others can understand and learn.

Note: Have living labs. Fund commercialisation and trial sites of technologies that have been successfully applied overseas due to the much larger market sizes. Professional management and oversight and independent auditing is critical for the success of any technology trial program

Solution: DCCEE are currently investigating a National Energy Savings Initiative scheme, a market-‐based tool for driving economy-‐wide improvements in energy efficiency. The HVAC&R industry should engage directly to help shape the scheme.

Note: Incentives are an appropriate response where the benefits of the technology are proven Energy efficiency grant schemes will help pull through new technology and improve efficiencies. The initial cost of emerging technologies is a barrier to adoption. Once they are proven costs reduce due to demand. Grants should only be for emerging technology to promote early stage innovation and industry development. Large scale GHG emissions savings should use schemes that provide funding on a more certain basis (eg tradeable certificates, standing offer etc) This will dramatically reduce the administrative burden and more flexibly fit funding processes/ timelines. Greater dialogue is needed between government and industry and research to find most cost effective assistance delivery mechanisms. The process for accessing the grants does however need to be simple and efficient for business to ensure take-‐up. A national scheme is preferred to individual state based schemes.

The NSW ESS scheme currently administers, and the VEET scheme is currently seeking public comment about, a methodology for assessing project based assessments (PBA’s). PBA’s are particularly relevant to a building that is considering a complete upgrade of a whole or part of a HVAC system. Certificates will be issued based on the system savings rather than individual equipment such as a chiller or fan. This encourages the industry to take a holistic view of HVAC system upgrades.

Solution: Analyse whether schemes such as the Vic VEET and NSW ESS influenced the uptake of emerging HVAC&R technologies in the business sector.

Note: Trials of technologies that help to reduce the heating/cooling load of a building could help quantify energy and subsequent greenhouse gas savings and could form submissions for deemed activities under the schemes. These schemes are typically geared more toward established



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technologies with proven economics rather than “emerging” technologies. Grant schemes are generally more appropriate for “emerging” technologies.

Note: The Essential Services Commission (ESC), who is the administrator of the VEET Scheme, publishes annual reports on the performance of the scheme, including details on what prescribed activities are taken up and in what proportion.

5.6.6. Targeting implementation of innovative technologies Solution: Assess the potential of implementing emerging or innovative technologies in the areas where networks are particularly congested.

5.6.7. Government procurement Solution: Government should mandate life-‐cycle considerations in all of their HVAC&R procurement decisions, including maintenance procurement.

Notes: This aligns with NSEE framework policy of Government leading the way in energy efficiency procurement. Procurement decisions should focus on long-‐term low TEWI solutions, LCA and environmental product declarations. Evidence of savings from the LCC approach would be needed and some standard clauses could be developed for Government to include in tenders. This would apply in design and operation/maintenance.

Solution: Industry needs to work with key government procurement organisations (e.g. local government) to develop best-‐practice procurement guidelines for HVAC&R design, installation and maintenance services.

Solution: Offering discounted or free co-‐generation/tri-‐generation feasibility studies via the HVAC&R industry and or government organisations.

Notes: A preliminary study to estimate the number of sites interested in and suitable for co-‐ and tri-‐generation technology would be required. Ideally buildings where heating/cooling loads and water and electricity consumption is already at best-‐practice levels before sizing/implementing a system. Feasibility studies also need to be cognisant of the future carbon intensity of gas fuel. A significant number of co-‐generation and tri-‐generation plants burn natural gas which is a limited natural resource.

5.6.8. Commercial refrigeration design approach Solution: The Industry should engage with Mall developers and owners and supermarket operators to help address the traditional tenant/landlord split incentives that exist with the major shopping mall owners and identify solutions to overcome these issue.

Notes: The split incentive or market failure operating here is that the Mall /Complex developer or builder provides the air conditioning service at the time of construction, while the tenant or supermarket operator provides the refrigeration system, during the tenancy fitout.



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5.6.9. Best-‐practice HVAC&R installation Solution: Develop an energy efficiency accreditation program for HVAC installers to ensure they are adequately conversant with energy efficiency and new technologies. Notes: Scheme could be based on the best-practice design and installation guide.

5.6.10. Commissioning Guarantee scheme Solution: Industry collaborates to develop a best-‐practice Commissioning Guarantee scheme for use in Australia.

Note: The Commissioning Guarantee scheme is proposed as an accreditation scheme that stakeholders must pay to become a member of. Members, including building owners, equipment suppliers and technical service providers agree to work to a specified standard of commissioning. Some of the membership fee goes into an “issues resolution fund”. If there is a commissioning problem on a scheme members job and someone has to come back and fix it up the funding for the fix up comes out of the “issues resolution fund” and the member at fault is counselled or removed from the scheme. The scheme would need to include strong branding around this to promote the use of member installers. NEBB run a Commissioning Guarantee scheme for NEBB members.

5.6.11. Residential air conditioning design and installation register Solution: Establish a registration program for residential air conditioning installers (like Master Electricians) and audit their work to ensure compliance to the standard and for them to remain as “registered installers”.

Note: This could be linked to the proposed/draft standard on residential air conditioning and requirements covered in a licensing system.

5.6.12. Residential installers guarantee scheme Solution: Industry collaborates to develop a best-‐practice Residential Installers Guarantee scheme for use in Australia.

Note: The proposed Residential Installers Guarantee scheme is an accreditation scheme that stakeholders must pay to become a member of. Members, including building owners, equipment suppliers and residential installers agree to work to a specified standard of installation. Some of the membership fee goes into an “issues resolution fund”. If there is an installation related problem on a scheme members job and someone has to come back and fix it up the funding for the fix up comes out of the “issues resolution fund” and the member at fault is counselled or removed from the scheme. The scheme would need to include strong branding around this to promote the use of member installers.

5.6.13. Co-‐generation/tri-‐generation Solution: Develop a co-‐generation/tri-‐generation accreditation scheme allowing only accredited system designers who have the required skills to design these systems.



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Note: In this way it is likely that the misapplication and over sizing issues of these systems can be significantly minimised and optimum design and operating conditions can be met for a particular facility.

Note: NSW OEH is in the process developing a co-‐generation feasibility guide that includes system design guidelines.

Note: The Australian Government has commissioned E-‐Oz Energy Skills Australia to undertake the development of training resources covering the specialist skills and knowledge required for operating and maintaining co-‐generation and trigeneration systems. This project will be undertaken by the NSW Utilities & Electrotechnology Industry Training Advisory Body. This project is funded by the Australian Government through the National Resources Sector Workforce Strategy.

5.6.14. Commercial refrigeration Solution: Industry should agree to voluntarily ban open type display cabinets across the industry. If all businesses agree to move to closed display cabinets at the same time then one of the major barriers to this initiative would be removed.

Notes: The initial agreement could apply to new units with an agreement to move to all units (i.e. retrofitting) within an agreed time frame.

Solution: Industry should create a ‘display cabinet buy-‐back’ scheme similar to the ‘Fridge buy-‐back’ scheme.

Solution: Manufacturers and other stakeholders could instigate a commercial solution similar to the domestic “Fridge Buy Back” scheme to promote the removal of aged inefficient plant and equipment in favour of new MEPS approved solutions.

5.6.15. Existing systems in existing buildings Solution: Industry should promote the ways to extract the best (low-‐emission) performance out of existing systems in existing buildings.

Notes: This could include disseminating materials on retrocommissioning, optimal supervisory control strategies and solutions, verified field performance related to whole integrated plants, retrofit guides, and any research or rules of thumb relating to improving existing equipment (roof top air-‐cooled, split systems, water-‐cooled heat pumps, etc).

Solution: Industry should promote the benchmarking of existing systems and use the measurement of energy flows in particular applications as a trigger for performance upgrades; non-‐compliance with a prescribed maximum kWh/m2 would be the trigger.

Notes: This solution would not be viable until benchmarks for all sectors/applications have been established.



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5.6.16. Incentivising energy-‐efficiency interventions in existing buildings Solution: HVAC&R end users would respond well to government or other incentives to upgrade the efficiency of existing systems.

Solution: Industry should promote the concept of accelerated or ‘Green Depreciation’ for energy-‐efficiency interventions in existing buildings.

Notes: Green depreciation involves the provision of accelerated depreciation allowances for capital expenditure on refurbishments that “Green” existing commercial buildings, including upgrades and improvements to HVAC&R systems. Accelerated depreciation would play a key role allowing investors to defer tax payments in exchange for implementing energy efficiency and greenhouse gas reduction activities.

Solution: Industry should promote the concept of public funding of energy efficiency retrofits for commercial and residential buildings.

Notes: Financial assistance mechanisms including grants, subsidies and rebates for improvements undertaken by building owners would reduce the investment cost and close the pay back gap providing significant incentive to invest in energy efficiency.

5.6.17. Incentives for commercial maintenance Solution: “Tax breaks for maintained buildings” program.

Notes: Cost is a big barrier to maintenance; could better maintenance be incentivised by tax breaks? Infrastructure maintenance requires time effort and economic investment. Tax breaks for those end users that adhere to maintenance schedules and protocols would increase the likelihood of industry adherence to Codes of Practice and safety standards. The alternative view is that best-‐practice maintenance should pay for itself.

5.6.18. Residential Maintenance Solution: Manufacturers and suppliers develop and deliver ‘extended warranty for maintenance’ program.

Notes: Manufacturers or the supply chain need to offer standardised maintenance offerings at time of sale. Proof of following a maintenance schedule (like a car servicing book) would extend the normal air conditioning unit’s warranty period at no additional cost to the customer.

5.6.19. Incentives for replacing inefficient residential systems Solution: Create an incentive scheme for residential building owners to upgrade an existing low efficiency/oversized/poorly constructed air conditioning system to a new replacement high efficiency/right sized/well installed system. Use the residential air conditioning standard as the compliance basis.



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Notes: Many of the existing residential air conditioning systems are very inefficient due to outdated design, lack of fitness for purpose, age and lack of maintenance. Manufacturers/suppliers and government could liaise together to subsidise the cost of new equipment, electricity networks and electricity retailers could liaise to subsidise the cost of the installation. Home owner would need to pay remaining costs. This scheme could significantly improve home energy efficiency, reduce energy intensity, provide leak free systems, and incorporate demand reduction and/or time-‐of-‐use tariffs. The scheme could also assist in reducing the existing bank of CFC/HCFC refrigerants in this sector.

There would have to be a significant win for the customer in terms of financial gain, i.e. reduced energy bills and or reimbursement to cover any perceived unnecessary cost. Illustrate the savings in running costs of a new air conditioning at X Star Rating to that of a comparable five/seven year old unit. Any recovery value in the removed air conditioner (refrigerant, precious metals, copper piping, etc) could be given back to the customer as a cash-‐back?

Solution: Industry should investigate ways to promote existing incentive based schemes for installation of high efficiency HVAC systems

Notes: There are existing incentive based schemes, such as the VEET scheme and Sustainability Victoria’s gas space heater rebate program. What is the opportunity for industry to promote and/or leverage these programs to increase uptake of high efficiency systems?

5.6.20. Direct refrigerant leakage Solution: Review and update all codes and standards relating to system construction standards to improve system integrity by banning the common leakage sources including the removal of mechanical joints and the phasing out open drive compressors in inappropriate applications.

Note: If a fitting is known to be leak prone it could be argued that continued use is an act that may be judged as negligent. Open drive compressors are more likely to leak than hermetic and semi-‐hermetic compressors. However, they are inherently more energy efficiency than hermetic and semi-‐hermetic compressor types which have limited capacity and are less suitable for large applications.

Solution: Adopt/adapt European F-‐gas leak-‐management procedures for voluntary or contractual use in Australia and make available to industry as a standard leak-‐management agreement.

Note: Sector-‐specific management procedures would need to be developed before mandatory or contractual leak testing could be accepted. The use of automated monitoring units, linked to a monitored centre (like security systems are) or else with automatic shutdown and alarm, could be a suitable alternative to inspection and testing.

Solution: Industry should engage with Government to establish effective enforcement approaches for refrigerant leakage.



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Note: Currently, preventable leaks are illegal but this ineffective if not enforced. It has been suggested that the role of ARC should be clarified/expanded to provide powers of enforcement including powers of entry etc

Solution: Introduce a comprehensive and mandatory protocol for the tracking of all refrigerants.

Solution: Develop a self certification model/mechanism for policing system leakage similar to what is in place for electricians and gas fitters.

Solution: Develop a series of fact sheets with photos for owners to raise awareness.

Solution: Industry should adopt the leak-‐management techniques used by the NH3 industry and apply these to all refrigerant-‐based systems.

Notes: Several proposed approaches to policing refrigerant leakage ranging from mandatory zero leakage to voluntary best-‐practice leakage. Many commentators believe that Zero Leakage is not practical, there will always be some (low) level of leakage.

5.6.21. Leakage monitoring Solution: Leak detection and leak monitoring systems need to be validated in practice to determine the practical limitations of their applications, characteristics of different technologies and the role of maintenance requirements etc. The results should be used to create an industry guideline to cover automatic leak detection and monitoring (for alarm or automatic action)

Notes: Leak detection and leak monitoring systems need to be better understood by industry. Current F-‐Gas regulations require leak monitoring. There are currently no specific standards on leak detection equipment and hence it is very difficult to validate their performance.

Many HVAC&R applications use ventilation to remove heat/facilitate the transfer of heat energy and leak detection in these circumstances has questionable validity.

5.6.22. Leakage testing Solution: Develop an industry standard leak testing procedure including identification of equipment on the market that is accurate and reliable.

5.6.23. Refrigerant containment Solution: Engineering solutions to refrigerant leakage containment should be assessed or validated so that industry can develop endorsed design and specification standards for leak containment technologies.

Notes: Not all leak containment systems work in the same way or provide the same performance and industry stakeholders need standard on which they can rely. The inclusion of leak containment technologies could then be easily mandated for certain types and sizes of systems



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Solution: Encourage modular systems so that the maximum amount of refrigerant at risk of leakage is limited.

Notes: Industry guidelines should ensure that low leakage risk design strategies do not result in overall systems that produce lower overall efficiencies

5.6.24. Maintenance for leak minimisation Solution: Quantification of efficiency gains in terms of kWh/bill cost benefits from proper levels of refrigerant and raising operator awareness of these savings might be a base that will encourage improved maintenance for leak management.

Solution: Requirements for leak minimisation should be built into maintenance contracts and there is a need for industry to develop standard contract clauses that can be used by clients and end users.

Notes: If operators are made aware of how energy inefficient and costly systems become when refrigerant charges fall they may improve maintenance interventions.

5.6.25. Refrigerant logging Solution: The industry should standardise the logging of refrigerant leakage, how it is done and in what format as a guideline with simple procedural steps and create an on-‐line register in which the data can be entered and stored.

Notes: Current refrigerant logging is variable and the data is not being collated into useable information.

Solution: The industry should develop a standardised spreadsheet listing common air conditioning units, the type of refrigerant used, the refrigerant charge they hold, and their typical leakage rate.

Notes: End users that are required to track their GHG emissions would appreciate a simple and standardised method of assessing the contribution of their HVAC&R systems.

5.6.26. Refrigerant reclamation and recycling Solution: Industry should review the need for refrigerant reclamation standards for all refrigerants and licensing.

Note: The recycling of refrigerants is a major issue for equipment owners and manufacturers with equipment under warranty. HFC refrigerant blends pose particular issues with fractionation of the blend so that the composition changes. To guard against this and other issues recycling should only be done by facilities that can prove they bring the refrigerant back to AHRI 700 – 2012 specification. This discussion should be informed by Australian Government policy currently under development.



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5.6.27. Refrigerant leakage Solution: Include a refrigerant leak monitor/detector on residential systems so that if some refrigerant charge is lost it either shuts down the system (preferable, as this will lead to a service call out) or provides a warning.

Note: This would likely need to be retrofitted for the Australian market and monitors may require maintenance. This may not be cost-‐effective given the relatively small size of the charge. If installation standards are improved then this may become redundant especially as if there is significant leakage then loss or lack or performance will be obvious without a detector. Refrigerant leak monitoring/detection has proved to be a very difficult area for even large commercial systems to achieve.

5.6.28. End-‐of-‐lifeleakage Solution: Provide industry education and awareness of end-‐of-‐liferefrigerant emission issues, particularly the recycling industry. Important to emphasise that once correct procedures are in place recycling HFC refrigerants can be an additional income stream, as well as metals.

Notes: Several countries have end-‐of-‐liferecovery programs in operation (e.g. Japan). It should not be possible for a consumer to dispose of a refrigerator or an air conditioner unless it can be verified that the refrigerant has been removed by a person licensed to do so. The refrigerant removal costs should be built into the equipment price.

Solution: Some of the new equivalent carbon refrigerant levy revenue should go to incentives for returning high-‐GWP refrigerants for recycling and reuse. Maybe a return deposit rather than a fee to encourage recycling or destruction.

Notes: Several commentators have suggested that refrigerant reclamation should be self funding, given the high value of fluorocarbon refrigerants.

5.6.29. Commercial leasing Solution: Facilities managers and technical service providers and property owners and tenant bodies should be encouraged to discuss methods to overcome the limitations that prescriptive lease based HVAC&R operation requirements have on energy efficiency and power use.

Notes: including mandatory operating times for air conditioning and very tight temperature operation ranges can significantly limit the ability of the system to achieve optimum energy efficiency. Air conditioning can be ‘available’ through controls without necessarily ‘running’. NABERS Energy rating protocols also need to be reviewed in this regard. A best-‐practice guide would assist with stimulating the consideration of these issues.

Solution: The HVAC&R industry should develop best-‐practice guides and standard leasing clauses dealing with the provision of HVAC&R services.



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5.6.30. Evaporative air cooling Solution: Continue to promote the water efficiency best-‐practice guide for residential evaporative cooling systems.

Note: In some climate locations evaporative air coolers can be used for comfort cooling at a significantly less energy cost that traditional air conditioning, however there is a water use penalty. Guide is available free from AIRAH www.airah.org.au . http://www.airah.org.au/Resources/BestPracticeGuides/Residential_evaporative

5.6.31. Hot water heat pumps Solution: Similar to the approach for residential air conditioning there could be an industry and government collaboration on an incentive scheme to help owners replace inefficient water heater models/installations.

Note: There are reportedly many of these systems in existing installations that are relatively inefficient. This scheme could significantly improve home energy efficiency, reduce energy intensity, and incorporate demand reduction or time-‐of-‐use tariff technologies. Note there are a number of existing incentive based schemes aimed at promoting the installation of high efficiency and low greenhouse water heaters. Examples include VEET, Sustainability Victoria’s solar and gas hot water rebate program, the Australian Government’s solar and heat pump hot water rebate program and the Small Scale Renewable Energy Target scheme.

5.6.32. Residential refrigeration upgrade and replacement Solution: Create a fridge buy-‐back scheme to incentivise replacement and to control disposal.

Notes: A fridge buy-‐back scheme could help address this if there is an operational model to recycle the old fridges, recovered refrigerant, precious metals, copper piping, etc have value, some of which could be passed back to the customer. Fridge buy-‐back schemes are in operation in some local government areas of Australia.

Solution: Create customer awareness materials to ensure that when customers do buy a new fridge they purchase the most energy-‐efficient one they can afford (A comparison of the running cost of a 5, 10 and 15 year fridge? star labelling?) and they do not continue to use the old fridge as a second fridge.

5.7. Other sector solutions not included in the roadmap

5.7.1. Vehicle air conditioning Solution: Review and update the current existing Automotive Code of Practice, not only to focus on leak minimisation but more importantly to address flammable refrigerants in the automotive market and the impending replacement/s for R134a refrigerant into new vehicle HVAC systems.



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Note: Many of these issues are not currently covered by the Automotive Code of Practice. Specific emphasis should be placed on leak minimisation and the risks of retrofitting to flammable refrigerants. This could also be done under a WorkSafe Australia endorsement. Solution: Industry and Government could consider a MEPS approach to vehicle air conditioning or an overall energy efficiency approach such as in the US.

Note: The relative efficiencies of different design approaches and different refrigerant options are not well understood.

5.7.2. Transport refrigeration Solution: Increase the awareness of the industry to passive reflective coatings that are available to retrofit onto vans and containers that will significantly reduce the heat load (cooling load) when applied to the external surfaces. Other solutions such as minimising door opening, putting strip curtains on doors etc could also be covered.

Notes: Possibly a fact sheet for the industry outlining the costs, benefits (including reduced maintenance and management) and typical payback periods.

5.8. Complementary actions

5.8.1. Workforce development There are a number of Government programs available to support the development of new training content and to subsidise the up skilling of employees in energy efficiency and sustainability skills. One such program is the National Workforce Development Fund (NWDF). This program forms part of the Australian Government Skills Connect initiative designed to link industry to funding for whole of workforce planning and development. The NWDF is a partnership between industry and government to support the training of workers in areas of identified need and is facilitated through the Industry Skills Councils (ISCs) network. The ISCs provide assistance to businesses providing a workforce development and planning approach. The NWDF is an innovative, industry-‐driven model that enables businesses to co-‐invest with the Government to train, re-‐skill and up skill workers in areas of skills need.

Solution: The HVAC&R industry should be encouraged to make use of the NWDF.

5.8.2. The Clean Technologies Supplier Advocate The HVAC&R industry should fully utilise existing government resources and work in partnership with the Clean Technologies Supplier Advocate to help promote energy efficient technologies currently available in the marketplace to customer markets. The Clean Technologies Supplier Advocate is employed by the Australian Government to assist Australian HVAC&R suppliers gain exposure to customer markets.

Solution: The HVAC&R industry should be encouraged to make use of the Clean Technologies Supplier Advocate.



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5.8.3. Building information modelling The AMCA: BIM-‐MEPAUS Initiative is an industry initiative (www.bimmepaus.com.au) which seeks to effectively address the issues currently impeding the transition to BIM based integrated project delivery. The goal is to achieve significant increases in productivity and a commercial framework for implementation of BIM through industry adopted software platforms, standards and services. During 2012/3, a number of Australian projects will pilot specifications, standards, models and workflows being developed under the BIM-‐MEPAUS initiative.

Three key principles underpin the development of the initiative: • vendor independent, but support vendor specific workflows; • inclusive / collaborative; and • BIM customised to Australian industry standards and workflows.

The initiative has gained widespread industry support including in-‐principle adoption by many of Australia’s largest developers and builders and it is expected to become the industry standard for BIM based project delivery and supply chain integration within the building services sector.

Solution: The HVAC&R industry should encourage Government to mandate BIM within their building procurement processes.

5.8.4. Harmonisation There has been some work carried out among a number of parties regarding the need to streamline the building simulation modelling protocols used in Australia to reduce unnecessary rework when models are used for multiple purposes. This harmonisation work includes the standardisation of default assumptions for items such as occupancy, equipment schedules and other assumed inputs such as infiltration.

Solution: The HVAC&R industry should continue to support the efforts of the three main energy modelling protocols, ABCB, NABERS and GBCA in their efforts to harmonise default inputs used in their protocols.



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6. Managing the transition

6.1. Working with government/ industry stakeholders In the future industry has to ensure that, when working with the Australian government and industry stakeholders, any programs are established with the conditions in place that require:

• Accountability of all stakeholders engaged. • Transparency within the program management. • A viable industry–Government forum with the power to keep programs moving and on

track.

Collaboration and open communications are the keys to relationship management. An HVAC&R council or umbrella group would help coordinate policy and provide a sustained industry communications strategy and policy framework which would be more accessible to government.

6.2. Current tools There are industry tools currently available which have made significant steps towards an industry transition. Some of the most effective of these tools include:

• Arctick certification for refrigeration trades. • MEPS ratings for manufactured equipment and TEWI calculation method for systems. • NCC section J and recent introduction of mandatory electrical sub-‐metering for large

commercial premises. • Australian and New Zealand Refrigerant handling Code of Practice. • NABERS Energy ratings and commercial building disclosure (CBD) of the rating result to the

wider property market. • Green building ratings and tools. • Building and system modelling, simulation and rating tools. • Refrigerant Reclaim Australia. • Publications such as “In from the Cold” and the UK Carbon Trust’s “Refrigeration Road Map”

which have the potential to provoke mindset changes in the industry.

The most successful tools are typically the ones that are developed and implemented through effective industry collaboration with all stakeholders. MEPS, NABERS, Green Star are all examples of tools that have been developed collaboratively. The less successful tools and programs tend to be developed and implemented through a top down approach.

6.3. Psychological and sociological factors Transition and innovation is about humans and behaviour change. Change can create uncertainty and uncertainty brings fear and other emotions. There are a range of psychological and sociological factors that also need to be considered as the industry transitions to a low-‐emission future. Some of these factors include:

• Resistance to changing the way of doing things, e.g. comfort conditions and dress codes. • Lack of skills and training and confidence in new methods. • The perception of the speed of change (incremental or radical change). • The perception of the difficulty of change (incremental or radical change).



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• Generational and cultural differences.

6.4. Changing entrenched industry attitudes To change industry attitudes it will be essential to change the attitudes and priorities of clients, regulatory authorities and end users as well as the technical service providers. This document provides a pathway to distil the key messages and pass them up and down the supply chain.

There are some core concepts that can be useful to describe an effective approach to change management including:

1. Plan for change from a solid base. 2. Identify differences between formal and informal practices. 3. Control expectations about the proposed changes. 4. Select change agents carefully. 5. Build support among like-‐minded people however they are recruited. 6. Identify those opposed to change and try to neutralize them. 7. Avoid future shock.

6.5. Lessons learned from overseas experiences Australia does not need to ‘reinvent the wheel’ with a lot of transition initiatives. There are many existing international initiatives being implemented overseas which Australian industry could adopt or adapt for local use. It would be useful if stakeholders with experience in appropriate programs can outline the lessons learned from applicable overseas projects.

• Which overseas programs were successful and what lessons can be learned from their successes or failures?

• Would any overseas programs be suitable for adoption in Australia? • Have the costs and benefits of these programs been quantified? • Which tools and training materials would be suitable for adoption in Australia?

6.6. Opportunities for the HVAC&R industry The transition to low-‐emission HVAC&R is largely seen as a threat to industry however the transition can also be viewed as a source of business opportunities.

6.6.1. Low-‐carbon consultants This may be time for the operators in the HVAC&R industry to think outside the HVAC&R box. Many of the energy-‐efficiency interventions in buildings will lead to downsizing the size of plant and systems it may be time that HVAC&R service providers diversify to become low carbon advisors able to advise on, cost and implement the full range of energy-‐efficiency interventions including increased thermal insulation, providing sealing and draught proofing services, installation of additional blinds and shades, provision of alternative lighting systems as well as new technologies and practices associated with low-‐emission HVAC&R. Forming strategic alliances with other service providers (e.g. energy auditors) can also help develop new business streams.



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6.6.2. Maintenance for energy efficiency With energy prices continuing to rise, many owners and operators will be focussing on reducing their energy consumption and energy bill. As a result they will be reviewing their HVAC&R systems and will require technical advice and assistance. There is a significant opportunity for existing technical service providers to expand their services into energy efficiency maintenance and interventions.

6.6.3. Maintenance for leak minimisation With significant increases in refrigerant replacement prices many owners and operators will have a renewed focus on reducing system leakage rates and taking a more proactive approach to leak minimisation. There is a significant opportunity for existing technical service providers to expand their services into leak minimisation maintenance and interventions.

6.6.4. System upgrades for energy efficiency Existing systems that are otherwise functional and would have been left alone may now be replaced or upgraded due to deficiencies in their energy efficiency or energy consumption. This represents a new work stream for the HVAC&R industry in a low-‐emission future.

6.6.5. System retrofitting for low-‐GWP refrigerants In the quest for low-‐emission HVAC&R these may be an increase in the retrofitting of low-‐GWP refrigerant-‐based technology into existing HVAC&R systems. These retrofit projects require skilled design and knowledgeable implementation and again this represents a new work stream for the HVAC&R industry in a low-‐emission future.

6.6.6. Identifying incentives and finance opportunities One of the major barriers to energy-‐efficiency interventions is cost and finance issues for owners. Any HVAC&R company that can provide owners with accurate information and practical help in accessing the incentives and finance schemes will be provided with a market advantage.

6.7. Demand and supply and demand Unlike the rapidly increasing demand for electricity, air conditioning and refrigeration the demand for training, maintenance and energy-‐efficiency interventions in HVAC&R remains at a low level. This is counter intuitive in many ways; there is a want and a need for these services but no demand. This appears to result from a disconnect between system users and the systems themselves. For the most part HVAC&R is invisible to users and owners and consequently a lowest-‐common-‐denominator approach is taken to system procurement and management.

• Unless there is a demand for low-‐emission HVAC&R services there will be no low-‐emission service providers.

• Unless there is a demand for low-‐emission training in HVAC&R there will be no low-‐emission training providers.

• Unless there is a demand for low-‐GWP technologies there will be no low-‐GWP technologies installed.



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This is no chicken and egg situation; the demand for a service must exist for the supply of that service to be a sustainable business proposition. In some cases the demand for a service might be stimulated by providing or facilitating a supply process.

A sustained communications strategy would benefit all sectors of the industry, the strategy should be targeted to the end user to stimulate demand. If the demand is there then the industry will respond. The industry must look for ways to create the demand from the end user

6.8. Intellectual property and knowledge transfer There is generally a poor transfer of information between industry stakeholders. Industry professional development systems are weak and there is a low demand from industry practitioners for continuing professional development in many sectors including energy efficiency.

Intellectual property is hard won in both the consultancy and contracting industries, with new technologies and associated practices often refined and streamlined through lessons learned from mistakes or individual investments in training, research and development. Many organisations protect their intellectual property as it is seen as a market advantage and a key point of difference between them and their competitors.

However it is clear if the industry and society is serious about a transition to low-‐emission HVAC&R then some of the barriers to the sharing of intellectual property among competing businesses and between large and small organisations needs to be improved.

6.9. Small and medium enterprises SMEs

6.9.1. SME end users Many of the end users of HVAC&R fall into the SME category and this sector deserves special mention with regard to barriers to low-‐emission HVAC&R and energy-‐efficiency interventions in general. Some of the specific problems that SMEs face in transition include:

• Lack of end user understanding of the HVAC&R issues, typically this is not their core business.

• Lack of awareness of the percentage of their energy bills is directly related to HVAC&R systems.

• Lack of awareness of opportunities to improve efficiency including behavioural changes, equipment/system upgrades, time shifting of demands.

• Lack of understanding of how to match time-‐of-‐use tariffs to HVAC&R equipment use.

• Lack of time to seek technical assistance, apply for grants, analyse energy profiles.

• Lack of resources to fund energy efficiency interventions.

• Lack of resources to provide staff training to improve behaviours.

• Poor advice that reflects the interests of the service provider giving the advice.



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6.9.2. SME technical service providers Many of the HVAC&R technical services providers (designers, contractors and maintenance providers) fall into the SME category and this sector deserves special mention with regard to transition. Some of the specific problems that SMEs face in transition include:

• Most SME managers time is spent looking for work to keep their businesses afloat.

• Clients and end users are minimising expenditure on maintenance.

• Small end users are only intervening at system failure.

• Small contractors will only up skill tradespeople in response to business demands.

• Contractors have difficulty selling the concept of preventative maintenance or building/system tuning to owners and operators.

• Most SMEs are unaware of programs such as HVAC HESS and In from the cold.

• Most SME’s see the equivalent carbon price for high-‐GWP HFC refrigerants as a threat to their business and do not focus on the potential opportunities.



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7. Industry transition action roadmaps

7.1. Section Introduction The primary purpose of this project is to help the HVAC&R industry define a roadmap outlining the actions and solutions that need to be taken to transition the industry to low-‐emission practices and technologies. What has been created with the discussion paper will not generate a cradle-‐to-‐grave Roadmap for low-‐emission HVAC&R. The industry does not have a well defined emissions start point or and end point at this stage and it is difficult to draw a map if you do not have the data to know where you are or where you are going. What the discussion paper has generated is a list of potential practical steps that could be implemented to encourage, facilitate, or mandate lowering the direct and indirect emissions associated with the HVAC&R industry. Some small and simple steps, but many larger and more complex and possibly inter related actions.

What has been developed is a series of pathways for improvement rather than a roadmap to an end point.

The pathways that have emerged are presented as follows:

Professionalism – The things that help to set the industry objectives and process for transition including funding and engagement, strategy and policy, compiling and sharing data, and professionalising the industry through skills, training, licensing and registration.

Regulating – The things that relate to helping the HVAC&R industry to inform government policy and regulations, industry codes, Australian Standards, and government programs.

Information – The things that relate to the information that can be provided to educate and inform end users and technical service providers on energy efficiency and low-‐emission skills and knowledge, technologies, fee structures and design practices, and maintenance imperatives.

Measurement – The things that relate to helping industry and end users monitor, measure, rate, and benchmark HVAC&R performance, validate efficiency claims, and compare technology solutions,

Emission abatement – The practical things that are done to reduce emissions including product stewardship, incentives for new technology and innovation, system procurement, good/best-‐practice accreditation, incentivising low-‐emission interventions, maintenance for energy efficiency and refrigerant containment.

It is intended that this Draft Roadmap and its proposed solutions be assessed and prioritised by industry stakeholders and the results taken for refinement and strategy planning at the industry summit.

The pathways included in this section will then be populated with the industry endorsed solutions and actions.



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7.2. Roadmap Therefore the HVAC&R Industry Roadmap currently looks something like this:

DRAFT ROADMAP – Transition to low-‐emission HVAC&R

Overall objective or

Vision A highly skilled and professional Australian HVAC&R industry that is safe, cost effective and environmentally effective.

Pathways – To low-‐emission HVAC&R

Professionalism Skills and training, licensing, professional registration, tertiary education and an industry council or forum to consider strategy, policy, information sharing, and industry practices.

Regulating Inform government policy and regulations, industry codes and Australian Standards, including validation, regulatory data, and enforcement.

Information Educate and inform end users, disseminate low-‐emission skills and knowledge, technologies, design practices, convert data to information.

Measurement Measure and benchmark HVAC&R performance using system rating tools, industry metrics, building tuning, system optimisation, validated efficiency claims and technology comparison tools.

Emission abatement Product stewardship, new technologies, work practice accreditation, incentivising low-‐emission interventions, maintenance for energy efficiency, and refrigerant containment.

PRIME : One of the meanings of the word prime is to prepare, to get ready, to brief, to train and to

prepare something for operation. It is also used to designate importance. In the context of the industry roadmap the word “Prime” seems an appropriate term to use. PRIME means putting in the right effort and groundwork before you start to ensure you get a good outcome.

Within this roadmap there are also some general principles that need to be adhered to:

• Develop data on the current situation • Learn from international experience



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7.3. Professionalism solutions Draft Roadmap – Professionalism pathways to low-‐emission HVAC&R

Pathway 1 Pathway 2 Pathway 3





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7.4. Regulatory solutions Draft Roadmap – Regulatory pathways to low-‐emission HVAC&R






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7.5. Information solutions Draft Roadmap – Information pathways to low-‐emission HVAC&R






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7.6. Measurement solutions Draft Roadmap – Measurement pathways to low-‐emission HVAC&R






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7.7. Emission reduction solutions Draft Roadmap – Emission reduction pathways to low-‐emission HVAC&R






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7.8. Complementary solutions Draft Roadmap – Complementary pathways to low-‐emission HVAC&R




-‐End of discussion paper-‐



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Appendix A Project Stakeholders and Supporters THE FOLLOWING ORGANISATIONS HAVE SUPPORTED THIS PROJECT:

Australian Chamber of Commerce and Industry

ACT Planning and Land Authority

Actrol

AECOM

AG Coombs

Air Conditioning and Mechanical Contractors Association

Air Conditioning and Refrigeration Equipment Manufacturers Association

Airchange

Airefrig

Alan Pears

Aldi

Amcor

ARUP

ASHRAE

Austral Group

Australian Building Codes Board

Australian Conservation Foundation

Australian Construction Industry Forum

Australian Constructors Association

Australian Direct Property Investment Association

Australian Hotels Association

Australian Industry Group

Australian Institute for Building Performance Research

Australian Institute of Architects

Australian Institute of Building Surveyors

Australian Institute of Quantity Surveyors

Australian Meat Industry Council

Australian National University

Australian Refrigerated Warehouse Association

Australian Refrigeration Association

Australian Refrigeration Council

Australian Sustainable Built Environment Council

Australian Workforce and Productivity Agency

Australasian Procurement and Construction Council

AUSVEG

BAYER

Building Commission (VIC)

Building Commission (WA)

Buildings Alive

CA Group

Chartered Institute of Building Services Engineers

City of Yarra

City West Water

Coles

Consult Australia

Consumer Electronics Suppliers Association

Crone Partners

CSIRO

Cundall

Dairy Manufacturers Sustainability Council



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Department of Business and Innovation (Vic)

Department of Defence

Department of Finance (WA)

Department of Industry, Innovation, Science, Research and Tertiary Education

Department of Infrastructure and Planning

Department of Planning, Transport and Infrastructure (SA Govt)

Department of Resources Energy and Tourism

Department of State Development, Infrastructure and Planning

Department of Sustainability and Environment (VIC)

Department of Sustainability, Environment, Water, Population and Communities/ Department of Climate Change and Energy Efficiency

Dsquared consulting

EE-‐OZ

Energex

Energy Efficiency Council

Energy Networks Association

Engineers Australia

Enterprise Connect

Ergon Energy

Exergy

Expert Group

Facilities Management Association of Australia

Foodworks

Gas Regulators Technical Committee

GEA Group

GHD

Gordon Refrigeration

Green Building Council of Australia

Grundfos

Heatcraft

Hussman

Hychill

IHRACE

Institute of Hospital Engineers Australia

Institute of Refrigeration (UK)

ISECO

Lend Lease

Manufacturing Skills Australia

Massey University (NZ)

Master Grocers Association

Master Plumbers and Mechanical Services Association of Australia

Mediaforte

Metcash

Minus 40

Moreland Ciy Council

Moreland Energy Foundation

National Occupational Licensing Authority

NDY

NECA / RACCA NSW

NECA WA

NSW Office of Environment and Heritage

Office of Energy (WA)

Pioneer Air

Pitt and Sherry

Plumbing Industry Climate Action Centre

Plumbing Industry Commission (VIC)

Plumbing Trades Employees Union

Polytechnic West

Property Council of Australia

Pump Industry Australia

RACCA Qld -‐ IRASE



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Real Cold Australia

Refrigerant Reclaim Australia

Refrigerants Australia

Refrigerated Warehouse and Transport Association

Refrigeration and Air Conditioning Contractors Association

Refrigeration Innovations

Royal Institute of Chartered Surveyors

Safework Australia

Scantec

Seafood Services Australia

Society of Building Services Engineers

Standards Australia

Sustainability Victoria

Sustainable Built Environment National Research Centre (SBEnrc)

Sustainable Melbourne Fund

Swinburne University -‐ National Centre for Sustainability

TAFE trainers and head teachers

The Fifth Estate

The Warren Centre

Thinkwell

Tritech Refrigeration

University of Wollongong

United Nations Environment Program

University of South Australia

University of Melbourne

University of New South Wales

University of Queensland

University of South Australia

University of Sydney

University of Technology Sydney

VASA

Victoria University

Viridis 3D

Williams Refrigeration

Winery Engineers Association

Woolworths

WSP Group

XO

Copyright AIRAH -‐ 2013