Ground-source heat pumps

May 2024

Technical bulletin on amending the standards

Webinar – Monday, June 3, 2024, 1:00-2:00 pm EDT

In April 2024, the Office of Energy Efficiency at Natural Resources Canada (NRCan) updated its Forward Regulatory Plan which identifies its intention to amend Canada’s Energy Efficiency Regulations (the Regulations) to align the scope with Ontario by: (i) reinstating energy efficiency and testing standards for water-to-water ground-source heat pumps (GSHPs), (ii) increase the stringency of energy efficiency standards for water-to-air GSHPs, and (iii) introducing energy efficiency and testing standards for direct-exchange GSHPs.

This technical bulletin has been released to initiate the consultation process and to collect stakeholder views on the requirements being considered for GSHPs.

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

The Government of Canada intends to pre-publish a regulatory proposal in the Canada Gazette, Part I, in 2025.

Background

In Canada, GSHPs manufactured as of February 3, 1995, are subject to the Regulations.

Water-to-air and water-to-water GSHPs were first regulated in 1995, with CSA C446-94 as the referenced testing standard. On June 1, 2006, the Regulations were amended to update the testing standard to CSA C13256-1. However, this standard only applies to water-to-air GSHPs. Hence, water-to-water GSHPs have been excluded from the Regulations since 2006. (CSA C13256-2 applies to water-to-water GSHPs but this testing standard was never referenced by the Regulations.)

While GSHPs are not regulated by United States, ENERGY STAR Canada and the province of Ontario have requirements for water-to-air GSHPs, water-to-water GSHPs and direct exchange GSHPs.

Using GSHPs for heating and cooling Canadian buildings could substantially reduce energy demand and help Canada reach its decarbonization goals.

The Government of Canada is committed to improving energy efficiency standards for consumer, commercial and industrial products to reduce energy consumption and support the goal of net-zero emissions by 2050. In this context, where feasible and appropriate, energy efficiency standards for some products could, for climatic and market reasons, exceed the stringency of those in the United States.

NRCan is considering amending the Regulations to: (i) reinstate energy efficiency and testing standards for water-to-water GSHPs, (ii) increase the stringency of energy efficiency standards for water-to-air GSHPs, and (iii) to introduce energy efficiency and testing standards for direct-exchange GSHPs.

Product description

GSHP means a single package or split-system heat pump that is factory-built, has a cooling or heating capacity of less than 40 kW (135,000 Btu/h) and is intended for application in an open- or closed-loop ground-source system. It includes water-to-air, water-to-water and direct-exchange GSHPs.

Testing standard

NRCan is considering referencing the following testing standards, as applicable, using incorporation by reference:

• CSA-C13256-1-01 (R2021) – Water-Source Heat Pumps — Testing and Rating for Performance — Part 1: Water-to-Air and Brine-to-Air Heat Pumps.
• CSA C13256-2-01 (R2020) – Water-source heat pumps — Testing and rating for performance — Part 2: Water-to-water and brine-to-water heat pumps.
• AHRI 871-2016 (R2-2023) (SI) – Performance Rating of Direct Geoexchange Heat Pumps

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

Energy efficiency standard

The energy efficiency standards under consideration for GSHPs are summarized in the table below.

Energy efficiency standards being considered for GSHPs
Product Type	Sub-type	Coefficient of Performance for Cooling (COPc)	Coefficient of Performance for Heating (COPh)
Water-to-air	Open loop	5.96	3.9
Brine-to-air	Closed loop	4.77	3.4
Water-to-water	Open loop	5.60	3.4
Brine-to-water	Closed loop	4.41	2.9
Direct exchange-to-air	N/A	4.69	3.6
Direct exchange-to-water	N/A	4.40	3.1

Text version

1. Table Overview:
   • The table provides information about energy efficiency standards being considered for different types of ground source heat pumps.
   • It contains four columns and six rows.
2. Column Descriptions:
   • Product Type: The first column specifies the type of ground source heat pumps.
   • Sub-type: the second column provides additional details about the ground water loop (e.g., open loop, closed loop, or N/A).
   • Coefficient of Performance for Cooling (COPc): the third column represents the efficiency of the ground source heat pump in cooling mode.
   • Coefficient of Performance for Heating (COPh): the fourth column represents the efficiency of the ground source heat pump in heating mode.
3. Row Details:
   • First row: for Water-to-air, Open loop ground source heat pump, the energy efficiency standards are 5.96 for Coefficient of Performance for Cooling and 3.9 for Coefficient of Performance for Heating.
   • Second row: for Brine-to-air, Closed loop ground source heat pump, the energy efficiency standards are 4.77 for Coefficient of Performance for Cooling and 3.4 for Coefficient of Performance for Heating.
   • Third row: for Water-to-water, Open loop ground source heat pump, the energy efficiency standards are 4.41 for Coefficient of Performance for Cooling and 2.9 for Coefficient of Performance for Heating.
   • Fourth row: for Brine-to-water, Closed loop ground source heat pump, the energy efficiency standards are 4.69 for Coefficient of Performance for Cooling and 3.6 for Coefficient of Performance for Heating.
   • Fifth row: for Direct-exchange-to-air (N/A sub-type) ground source heat pump, the energy efficiency standards are 4.69 for Coefficient of Performance for Cooling and 3.6 for Coefficient of Performance for Heating.
   • Sixth row: for Direct-exchange-to-water (N/A sub-type) ground source heat pump, the energy efficiency standards are 4.40 for Coefficient of Performance for Cooling and 3.1 for Coefficient of Performance for Heating.

Important dates

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

NRCan is considering applying the updated and new standards to GSHPs manufactured on or after January 1, 2026.

Regulatory pathway

NRCan is considering amending the Regulations through Governor in Council amendment.

The considered changes would be pre-published in the Canada Gazette, Part I, followed by a public comment period. The exact date for final publication in the Canada Gazette, Part II will depend on the number and nature of comments received during the public comment period. Final publications are typically within a year of their initial public comment period. These changes and the timing of publication are subject to decision-making authorities under the Energy Efficiency Act.

Labelling requirements

NRCan is not considering a mandatory EnerGuide labelling requirement for GSHPs.

Verification requirements

NRCan is not considering any changes for the verification requirements for GSHPs.

These products will continue to carry a third-party verification mark indicating that the product meets the energy efficiency standard and that the information to be reported has been verified.

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

Reporting requirements

Energy efficiency report

NRCan is not considering any changes to the energy efficiency report requirements for this product.

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

Import report

There is no change to import reporting.

Comments invited

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

NRCan is specifically interested in getting feedback on:

• The estimated number of Canadian annual shipments (or sales) of GSHPs, ideally, by type (water-to-water, water-to-air, direct exchange) and broken out by both capacity and efficiency. NRCan is interested only in total market data; shipments by individual manufacturers will remain confidential.

It is important to NRCan that we engage the public and stakeholders on amendments to the Regulations. If you are aware of any dealer, manufacturer, importer, retailer, utility provider, small business, consumer group, organization, or representative of a specific group(s) of the population (including, but not limited to, women, 2SLGBTQQIA+ people, persons with disabilities, visible minorities, socio-economic status, residency, housing status, etc.), Indigenous peoples/communities, and/or other person or group that may be interested in participating in the amendment discussion and/or may be negatively impacted by this proposal, please forward them or their representative this bulletin. Please click here to register to our mailing list which is used to notify stakeholders of upcoming amendments, technical bulletins, webinar registrations, official publication in the Canada Gazette, etc.

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

We welcome your comments by September 13, 2024. All correspondence should be forwarded to:

Natural Resources Canada
Office of Energy Efficiency
580 Booth Street
Ottawa, ON, K1A 0E4

E-mail: EEregulations-reglementEE@nrcan-rncan.gc.ca

Email subject heading to be: Bulletin – Ground-Source Heat Pumps – Thermopompes géothermiques – May 2024 mai