Appendix B to RIS 2009-03 - Australian Building Codes Board

Appendix B to RIS 2009-03 - Australian Building Codes Board

Adding the proposed regulations to the BCA would offer the possibility of national

consistency, and if adopted by some or all jurisdictions would reduce the costs to

builders and water heater suppliers of complying with varying State provisions.

Energy labelling

The labelling of water heaters with their energy consumption or relative level of

efficiency has had little impact on the general water heater market, and even less impact

on the market for water heaters in new houses.

Buyers of whitegoods such as refrigerators usually inspect and compare models in

showrooms, where they are exposed to energy labels, and they usually buy the products

for their own use, so if they choose they can weigh capital cost against energy efficiency

and other features.

Water heaters are generally purchased by or on the advice of builders, plumbers or other

intermediaries who have little or no incentive to take the information on energy labels

into account. Even where users order water heaters directly, they would rarely visit a

showroom to inspect a physical sample.

These market conditions have led to the rejection of energy labelling as a workable

energy efficiency measure for electric water heaters, in favour of minimum energy

performance standards (MEPS) (GWA et al 1993). The fact that gas water heaters carry

energy labels is a carryover from the time when the gas utilities and then the Australian

Gas Association managed the program in the 1980s (MEA et al 2002). One of the

reasons for now considering MEPS for gas water heaters is the limitations of the

labelling program (E3 2008/07).

Even if energy labelling (either physical or on brochures or websites) were effective, it

would only influence choice within the same technology and energy type. The

achievement of the objectives of the proposal rely on influencing choice towards low

greenhouse forms of water heating, whether of different technology (eg solar vs

conventional, electric heat pump vs electric resistance) or different energy form (eg gas

vs electric).

Therefore energy labelling alone would not achieve the objectives of the proposed BCA


Minimum Energy Performance Standards

Minimum energy performance standards have been shown to be effective in increasing

the level of efficiency of products of specific types and energy forms. In water heating

alone, mandatory MEPS have been used to reduce heat losses in electric resistance

water heaters. Higher MEPS are also being proposed as a means of raising the average

energy efficiency of gas water heaters (the MEPS levels currently in place are so low

they have no effect on the market).

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