PE2 joins DOE PubCon for MEPP guidelines

Date Published: 
May 12, 2020
  • A screenshot showing DOE EUMB Dir. Patrick T. Aquino delivering closing statements (upper center) and PE2 officer Theresa Acedillo-Lapuz participating (upper right) in the virtual public consultation held on 12 May 2020 for the draft guidelines for the Minimum Energy Performance for Products. (PE2 photo)
    A screenshot showing DOE EUMB Dir. Patrick T. Aquino delivering closing statements (upper center) and PE2 officer Theresa Acedillo-Lapuz participating (upper right) in the virtual public consultation held on 12 May 2020 for the draft guidelines for the Minimum Energy Performance for Products. (PE2 photo)

TAGUIG CITY, 12 May 2020 – The Philippine Energy Efficiency Alliance (PE2) joined other market stakeholders in a virtual public consultation (“PubCon”) hosted earlier today by the Department of Energy (DOE), through its Energy Efficiency & Conservation Performance Regulation and Enforcement Division (EPRED), one of the newly created divisions of the Energy Utilization Management Bureau (EUMB). DOE was led by its EUMB Director Patrick T. Aquino, while PE2 was represented by Theresa Acedillo-Lapuz, who has been tasked to assist in several government affairs and policy support activities of the Alliance.

Within EUMB and the broader policy framework of the Republic Act 11285 or the EE&C Act, EPRED will be responsible for the development of guidelines on on-site inspections, conduct of monitoring, verification, and enforcement activities in compliance with MEPP.

On 11 May 2020, EPRED shared with PE2 two draft department circulars:

  • Prescribing the Guidelines of the Philippine Energy Labeling Program (PELP) for Compliance of Importers, Manufacturers, Distributors and Dealers of Electrical Appliances and Other Energy-Consuming Products (ECP)
  • Prescribing the Minimum Energy Performance for Products (MEPP) Covered by the Philippine Energy Labeling Program (PELP) for Compliance of Importers, Manufacturers, Distributors and Dealers of Electrical Appliances and Other Energy-Consuming Products (ECP)

Before the PubCon, PE2 president and Policy Committee chair Alexander Ablaza received inputs from contributing PE2 member companies and the International Energy Agency (IEA) on the proposed MEPP.

Concepcion-Carrier Air Conditioning Company (CCAC) told Ablaza that they find the proposed minimum Cooling Seasonal Performance Factor (CSPF) for room air conditioners (AC) less than 14.0 kW in capacity acceptable. Further, CCAC endorses the 5-tier rating system (“one-star” to “five-star”) that DOE had previously adopted for window and split-type AC units in three capacity categories: below 3.33 kW, 3.33 kW – 9.99 kW, and 10.0 kW to 14.0 kW. CCAC believes that the 5-tier classification enables the general public to make an intelligent decision to go for either a cheaper unit or a more efficient model. CCAC suggests a periodic review of the MEP values vis-a-vis available technologies and other factors that influence the selection of efficient equipment. The PE2 member company also wants the MEPP framework to ensure that the testing conditions to which CSPF are taken, are compliant with either AHRI or at PNS conditions.

Daikin Airconditioning Philippines Inc. also shared its views with Ablaza. Daikin confirmed that the Philippine MEPP of 3.08 CSPF for the smaller capacity ACs is at par with those of Indonesia, Malaysia and Vietnam. Daikin suggests that the MEPP to introduce a new middle tier for the AC models in the 3.33 kW to 9.99 kW range, with an adjusted CSPF of 2.95 for models falling within the 3.33 kW to 7.1k W range. Daikin believes that such middle tier will bring the Philippine market closer to the MEP of our ASEAN neighbors. The company notes that the MEP in Thailand is high, now requiring a CSPF of 3.52.

Hi-Cool Engineering Corporation believes that the global average CSPF is 4.0 and IEA said it needs to rise to 6.0 by 2030 if ASEAN as a regional market aspires to achieve our energy efficiency goals. Hi-Cool supports the IEA recommendation for a minimum percentage increase every review year towards a target MEPS by 2030 (e.g. minimum increase of 8% every 2 years for 10 years).

Stellar Equipment and Machinery Inc. and Beyond Energy Solution Technology, Inc. opined that the lower-end market would be hugging closer to the MEP thresholds. The efficiencies of the better-known brands, which are using up-to-date technology, CSPF of 3.50 to 3.80 is clearly achievable for AC models below 3.33 kW in cooling capacity. Also, for the next cooling capacity bracket of 3.33 kW to 9.99 kW, these better-known brands are capable of CSPF ranging from 3.00 to 3.40.

Edward Marcs Philippines Inc. also supported the 5-tier classification system adopted by the DOE for the PELP, and also seeks an annual review of the MEPP thresholds to accelerate our catch-up with the MEP of ASEAN and global markets.

International Energy Agency (IEA) told Ablaza that the proposed MEPP of the Philippines “prematurely reduces the MEP requirement to CSPF=2.81 at capacities of 3.33 kW above. With several ASEAN countries adopting the same standard, the Philippines risks being the recipient of less efficient ACs within that 3.33 kW to 3.51 kW. Manufacturers unable to sell inefficient ACs in that range elsewhere in the region might look to the Philippines and sell cheaply, thereby competing on upfront price with the local industries who can produce more efficient ACs in said range.” IEA shared with PE2 a scatter diagram based on individual research and a CLASP study in 2019, to demonstrate how the Philippines may potentially be the dumping ground of imported, low-quality, low-efficiency ACs with the proposed MEP.

Cooling capacity vs efficiency by manufacturing location. CSPF equivalent for non-inverters calculated as 1.062 x tested EER. (Image: IEA)

Cooling capacity vs efficiency by manufacturing location. CSPF equivalent for non-inverters calculated as 1.062 x tested EER. (Image: IEA)

During the PubCon, Lapuz presented two recommendations on behalf of PE2:

  1. For cooling capacities of 3.33 kW to 3.51 kW, PE2 observed that the proposed CSPF does not align with the ASEAN Regional Standard, and that loophole could be the entry point for the dumping of inefficient ACs unsold elsewhere in the region. PE2 recommended the adjustment of: CSPF = 3.08 for below 3.51 kW; and CSPF = 2.81 for 3.51 kW to 9.99 kW.
  2. PE2 likewise recommends to make the MEPP review period shorter than the stated 3-years, with a defined minimum percentage increase towards a target. This solidifies a commitment to progressive update, and reduce risks for government and investors alike, and ensures that the Philippines can compete in the ASEAN market in the coming years. PE2 seeks a minimum percentage increase every review year towards a target MEPS by 2030 (e.g. minimum increase of 8% every 2 years for 10 years).

Also during the virtual meeting, DOE responded to the previously submitted comments of PE2 member, Signify Philippines Inc. for the energy labeling of lighting products.

DOE circulated its pre-PubCon comment among stakeholders, “Maybe we should gather fresh inputs from everybody for the Transitory Provision.”

Before the close of the PubCon, Dir. Aquino explained that since this labeling is new, DOE set the bar low as a starting point. EUMB is inclined to keep the 3-year review provision as that is based on an ASEAN standard. He said that DOE-EUMB will remain open to revising the MEPP along the way depending on MEP developments in the ASEAN region.

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Philippine Energy Efficiency Alliance Inc. (PE2), is a non-stock, non-profit organization of energy efficiency market stakeholders.

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