What to know about Amendment 15

By MichaelRidler

Amendment 15 introduced minimum energy performance standards, testing standards, verification and reporting requirements for several product categories in the mechanical trades.

In the residential sector, it affects electric furnaces, gas boilers, fireplaces and furnaces, heat recovery ventilators (HRVs), oil boilers, and tankless water heaters. For the commercial sector, it’ll affect gas boilers, oil boilers, electric water heaters, and gas and oil water heaters.

The amendment was published in the Canada Gazette, Part 2 in June 2019. One of the bigger issues with water heaters is the use of VS, which uses the measured volume of the water heaters to determine the efficiency of the units, rather than VR. The Department of Energy (DOE) uses VR to calculate efficiency whereas Canada uses VS, which causes grief for the manufacturers. Additionally, with the water heater, there is an issue regarding standby losses with electric water heaters.

Replacement commercial water heaters may now be replaced with a like-unit, but it must have a label indicating that it is for replacement only

Condensing boilers have been regulated into residential applications for years, but commercial boilers being required to be condensing technology goes into effect on July 1, 2025. The big issue with this regulation is that it includes replacement boilers. This seriously impacts the building owner with additional costs for venting. If the building has a standard installation of commonly vented boilers and they must replace one boiler, they may require changing them all to support the venting of the new boiler.

There are several identified problems with a replacement boiler. NRCan has been working with the Canadian Institute of Plumbing and Heating’s members to create a “Best Practices Guide” to guide contractors and building owners. This document that was set to be released in June 2021, but has yet to be released.

Commercial gas boilers

Commercial gas boilers used for space heating in buildings and can either use hot water or steam will be affected; this applies to natural gas or propane as the fuel source which have input ratings greater than or equal to 87.92 kW (300,000 btu/h) and less than or equal to 2 930.71 kW (10,000,000 btu/h). For commercial gas boilers manufactured on or after Jan. 1, 2025, Amendment 15 sets the minimum energy performance standards (MEPS) at the condensing technology level. Performance will be measured in accordance with testing standards aligned with those of the DOE.

New language

The use of "residential" has been replaced by household within Amendment 15. As such, household and commercial gas-fired instantaneous water heaters are the next product to be affected. These use either natural gas or propane as the fuel source. For household and commercial instantaneous gas-fired water heaters manufactured on or after Jan. 1, 2020, and July 1, 2023, respectively, the amendment set the MEPS at condensing technology levels equivalent to current Energy Star performance levels. Performance will be measured in accordance with testing standards aligned with those of the DOE.

Commercial products

Commercial oil-fired boilers that are used for space heating and use either hot water or steam as the heating medium are next on the list. The input ratings regulated are greater than or equal to 87.92 kW (300,000 btu/h) and less than or equal to 2 930.71 kW (10,000,000 btu/h). For commercial oil-fired boilers manufactured on or after Jan. 1, 2025, Amendment 15 sets the MEPS at levels prepublished in the U.S. DOE final rule on Dec. 28, 2016. Performance will be measured in accordance with testing standards aligned with those of the DOE.

Commercial electric water heaters with input rates of greater than or equal to 12 kW (40,982 btu/h) and a volume of at least 50 L (13.21 U.S. gal) will be affected. For commercial electric water heaters manufactured on or after Jan. 1, 2020, Amendment 15 set the MEPS at levels that are currently in place in the United States. Performance will be measured in accordance with testing standards aligned with those of the DOE.

Additionally, commercial gas-fired storage water heaters that use natural gas or propane as the fuel source and have input rates greater than 21.97 kW (75,000 btu/h) is included in the amendment. For commercial gas-fired storage water heaters manufactured on or after July 1, 2023, Amendment 15 set the MEPS for commercial units, marked as replacement units, at levels that are currently in place in the United States. For all other products, the amendment sets the MEPS at condensing technology levels. Performance will be measured in accordance with testing standards aligned with those of the DOE.

More stringent MEPS

For commercial oil-fired water heaters manufactured on or after Jan. 1, 2020, (and have an input rate greater than 30.5 kW or 105,000 btu/h), Amendment 15 set the MEPS at levels that are currently in place in the United States. Performance will be measured in accordance with testing standards aligned with those of the DOE.

Amendment 15 also introduced more stringent MEPS and updated testing standards for several other products within the newly named household sector.

Household gas boilers used for space heating with either hot water or steam as the heating medium and that use either propane or natural gas and have an input rate of less than 87.92 kW (300,000 btu/h) will be affected by the amendment. For household gas boilers intended for hot water systems that are manufactured on or after July 1, 2023, Amendment 15 set the MEPS at the condensing technology level equivalent to the current Energy Star performance level. For household gas boilers intended for steam systems manufactured on or after January 15, 2021, the Amendment 15 set the MEPS at levels that will apply on that same date in the United States. Performance will be measured in accordance with an updated testing standard aligned with that of the DOE.

Household oil-fired boilers supplying either hot water or steam as the heating medium for the space and that have an input rate of less than 87.92 kW (300,000 btu/h) are subject to the amendment. For household, oil-fired boilers manufactured on or after Jan. 15, 2021, Amendment 15 set the MEPS at levels that will apply on that same date in the United States. The existing testing standards are being updated but will remain aligned with those of the DOE.

Amendment 17 is implementing administrative powers that should allow NRCan to make editorial changes without the regulation having to go once again to cabinet.