1. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 1 Boiler- & WH labelling and European directive EuP Ecodesign of EuP Dedicated Water Heaters EUROPEAN COMMISSION Directorate-general for Energy and Transport Unit D3, Energy Efficiency Draft proposal NOx –Emission Limit Values

2. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Commission draft proposal From 01/01/2013 Emissions of NOx from..Water heaters..shall be subject to the following limit (where applicable): NOx; 20 ppm, except 40 ppm for products with at least 30% renewable input. This limit shall be after allowing for nitrogen already in the fuel (or when tested with nitrogen free fuel). Possible Variants (above remains the preferred option, IA study to advise): Raising the non renewables limit by around 25% to 25 ppm. A limit of 70 mg/kW gas, 105mg/kW oil proposed by EHI A delay of implementation limited to small (wall hung) oil boilers 2

3. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Why same limits for WH and (combi-)boilers? Principle: instantaneous combi (summer mode)= GIWH (or OIWH)* storage combi (summer mode) = GSWH (or OSWH) Test method envisaged: Identical (steady state test at full load) Urgency: GIWH and GSWH are today low-end market segments and contribute disproportionally to NOx. No technical reason for that and they can/should be upgraded to higher level, comparable to combi or even better. Message: Rethink and upgrade GIWH and GSWH. They might well be (part of) the better alternative to the current combi concept. GIWH= Gas-fired Instantaneous Water Heater (OIWH is Oil-fired); GSWH= Gas-fired Storage Water Heater (OSWH is Oil-fired)

4. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 NOx limits: Misc. Proposals (in mg/kWh) EHI boilers Gas/Oil 2013 OFTEC (UK) boilers: Oil 2013/2018 EG: Gas 2013 EG: Oil 2013 2013 18 <70 kW >70 kW <70 kW >70 kW = >30% share renewables Commission proposals in mg/kWh (20 ppm=ca. 35 mg/kWh) EHI for WH: 200 mg/kWh NGO: >50% renewables

5. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Why NOx limits ? Ecodesign not just energy: gas-/oil/ electric boilers & WH contribute 10% to EU-NOx NOx important for smog, acidification (clean air) and plays a role in climate change (ozone) NEC directive, Stockholm Treaty, AAQ directive, etc. EU behind in legislation (California in front). If EU wants to compete globally, the legislation should reflect that. The proposed limits are ambitious (current best) but should be feasible throughout within 4-5 years with extra R&D (2013) CO safety limits are already in standards (but test standards should be updated asap!). No need to go further until new standards are there. NOx policy limits (in ppm) are 25 times more stringent than CO in EU Directives.(25 times more important)

6. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 NO2 in EU 2003 http://www.knmi.nl/~eskes/folkert/meteorologica_05.html

7. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 NO2 World 2003

8. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 NO2 China 2001

9. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 9 ECODESIGN OF EUP, Lot 1 & 2, BRUSSELS, 29.2.2008 NOx: Fighting smog and acidification 14 kt SOx eq/a in 2020 193 kt SOx eq/a in 2025 Realistic 922 1056 Business as Usual 2020 2025 2010 1990 514 631 102 665 223 961 1296 + 936 555 [ EU-15 total in 2005: 10.945 kt SOx equivalent, from 9015 kt Nox (*0,7) and 4635 kt SO2] ] Impact EU: Acidification (in kt SOx eq./a)

10. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Why NOx-bonus? Why Nitrogen-free? NOx-bonus (+20 ppm) is consistent with system approach: Rating of the NOx of the whole boiler installation (including renewables). If the fossil-fuel fired boiler is just a back-up and may not even (or little) be used in normal operation, it is not advantageous for the environment nor economical for the user to require the most stringent limits. Nitrogen-free: The nitrogen in the fuel cause a substantial and often unavoidable part of the NOx emissions (ca. 28-35 mg/kWh). This is outside the scope of the boiler-design and manufacturers of boilers that use nitrogen-containing fuel are not responsible for that part of the NOx emissions. (e.g. compare low-S)

11. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 NOx formation: 3 types Thermal NO post-flame, high temperature Prompt NO fuel-rich flame, low temperature Fuel NO Oxidation of N in fuel Fuel NO not responsibility of boiler industry

12. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 World NOx limits gas-fired boilers =also dedicated water heaters

13. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 World NOx limits oil-fired boilers =also dedicated water heaters

14. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 EU Car emission limit values NOx and CO

15. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Compare cars NOx (in mg/kWh) 133 100 70- 105 35- 70 Euro 6 2014 EuP draft 2013 dieselgasolinediesel gas with or without renewables Explosion motor Dynamic test Combustion Steady-state test mg NOx/kWh

16. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Power plants NOx LCP-directive* NOx-limits for new plants after 2003: Most gas turbines < 43 mg/kWh (ca. 25 ppm) Gas > 300 MW < 85 mg/kWh**; 50-300 MW <ca. 130 mg/kWh; Oil > 100 MW < 170 mg/kWh; 50-100 MW < 340 mg/kWh 2004 example: GE Frame 9FB gas-fired steam turbine (combined cycle) 412 MW, 58 % efficiency on NCV (lower heating value). Dry Low NOx2+ combustion system NOx emissions less than 43 mg/kWh. (=25 ppm, installation Milan(IT) 2004.) *= Large Combustion Plants directive 2001/80/EC **=conversion 100 mg/m3 = 85 mg/kWh

17. EUROPEAN COMMISSION, DG TREN, UNIT D3 ECODESIGN OF EUP, Lot 2, BRUSSELS, 8.7.2008 Remember.. EU should be ahead!