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Conclusion

NO_x emissions standards

Australia is one of the few countries that does have emission standards for NO₂ or NO_x from domestic appliances. Where the literature search was successful in locating other standards, comparisons with the Australian standards were often difficult because of assumptions that have to be made in converting between units. Sometimes the applicability of the standards to particular appliances was not clear as a result of translation problems (e.g., "air heaters" may mean central heaters, not space heaters, in Australian usage). In many cases full details of the units used were not known (e.g., the temperature to which gas volumes are standardised, which can cause differences of 10% or more in unit conversions).

In spite of these difficulties, standards found for natural gas fired domestic appliances are summarised in Table 21 and Table 22. The assumptions used in converting between different units are also detailed below. The third columns of the tables contain converted standards in units of ng(NO_x)/J or ng(NO₂)/J consistent with the specification of the standard. It is not possible to convert from a NO_x basis to an NO₂ basis without knowing the applicable NO₂/NO_x ratio. It is important to note that entries in column 3 expressed on a NO_x basis cannot be compared with other entries on an NO₂ basis as the conversion may vary by a factor of 10 or more, depending on the NO₂/NO_x ratio.

Table 21: Summary of NO_x emissions standards for natural gas fired room heaters

Flued heaters		ng/ J(heat input)
Austria	60 ng(NOx)/J	60
Europe – automatic forced draft burners	170 mg(NOx)/kWh	47
Germany – fan assisted burner	200 mg(NOx)/kWh 150 mg(NOx)/kWh	55 42
Poland	60 g(NOx)/GJ	60
Unflued Heaters		ng/ J(heat input)
Australia	5 ng(NO2)/J	5
Austria	30 ng(NOx)/J	30
Germany – radiant heater	60 mg(NOx)/kWh	17
Japan	10 ppm(NO2)	5.7

Table 22: Summary of NO_x emissions standards for natural gas fired water heaters

Flued heaters		ng/J(heat input)
Austria	60 ng(NOx)/J	60
Belgium – central heating boilers	100 mg(NOx)/m³ (0% O2)	28
Czech Republic – atmospheric – fan assisted	200 mg(NOx)/m³ (3% O2) 150 mg(NOx)/m³ (3% O2)	66 50
Europe – automatic forced draft burners	170 mg(NOx)/kWh	47
Germany – central heating boiler – wall mounted boiler	200 mg(NOx)/kWh 200 mg(NOx)/kWh	55 55
Japan	60 ppm(NOx) @ 0% O2	34
Poland	35 g(NOx)/GJ	35
USA (California AQMDs) – residential – mobile home	40 ng(NOx)/J(output) 50 ng(NOx)/J(output)	26 33

Assumptions

• Standards quoted for NO_x were assumed to be for NO_x as NO₂.
• Where standards are not designated Flued or Unflued, Flued was assumed.
• Where the heat basis (input or output) of a standard is not quoted, input was assumed. To convert heat output basis to heat input basis, 80% efficiency was assumed for space heaters and 65% for water heaters (Bavaro et al, 1995).
• Standards specified for central heating units were excluded from the room heater comparison. Some standards for "furnaces" have been included.
• Where different standards apply for a range of sizes, the smallest appliance size was chosen.
• Specific energy = 37.8 MJ/m³. Hence 1 mg/m<³ = 0.28 ng/J(input), 1 mg/m³(3% O₂) = 0.33 ng/J(input) (A. Law, personal communication).
• 1 ppm NO₂ = 2.05 mg/m³.
• 1 mg/kWh = 0.277 ng/J.

This study contributes to Environment Australia's program to improve ambient air quality. It will be important in the formulation of policy and regulations to integrate ambient air considerations with those of indoor air quality, greenhouse effect, energy efficiency and building insulation, noise and pollutants other than NO_x.

NO_x control technologies and applications

The three basic principles used for primary control are:

• Reduction of high combustion/flame temperature.
• Reduction of residence time at high combustion temperature.
• Reduction of oxygen concentration.

These may involve either or both of the following:

• Modification of fuel/air delivery-burner system.
• Modification of gas burner.

Many primary control technologies have been applied commercially to water heaters and air heaters, but few to cooking appliances. Current regulations have NO_x emissions limits set close to the minimum achieved by some technologies. If the NO_x emissions limits are going to be set lower in the future, some technologies may require further development or may even be unacceptable anymore. Other technologies that have already achieved lower NO_x levels could still be used readily. The status of these primary NO_x control technologies are summarised in Table 23.

Table 23: Comparison of primary NO_x control strategies for residential gas appliances*

Primary NOx control technology	Likely lowest NOx (ppm, O2-free) *	Likely change in CO emissions *	Likely change in thermal efficiency *	Technology status for domestic application *
Premixed, high excess air	~ 20	Decrease	Decrease	Current
Flue-gas recirculation	~ 25	Increase	Decrease	Not commercialised
Staged combustion	~ 25	Increase	Decrease	Current
Delayed combustion	~ 25	Increase	Decrease	Not commercialised
Humidified combustion	~ 25	Increase	Decrease	Not commercialised
Flame inserts	~ 40	Increase	Decrease	Current
Thermally active burner	~ 65	Decrease	Increase	Current
Port-loading reduction	~ 50	Increase	Increase	Current
Port redesign	~ 45	Decrease	Increase	Current
Radiant combustion	~ 4 **	Decrease	Increase	Current
Catalytic combustion	~ 5	Decrease	Decrease	Not commercialised
Pulse combustion	~ 20	Increase	Increase	Current

Notes
* Some information could be superseded in 1999.
** This low level is achieved by the Bowin technology which is put into this category by the author. Otherwise, the "Likely Lowest NO_x" would be ~ 10 ppm claimed by Acotech.

Most of these technologies were developed in Japan, USA and Europe which use a natural gas supply pressure ≥ 2 kPa gauge for domestic use. In Australia, many parts of the country receive at a much lower pressure, e.g., ~ 1.1 kPa gauge in most regions in Victoria. Hence some of the overseas low NO_x technologies may require fan assistance for applications under Australian conditions. A possible approach to improve this situation is to raise the gas supply pressure to similar levels used overseas if no change of hardware is required. This could cost millions of dollars, and will require the involvement and cooperation of Australian gas distribution companies.

Secondary control technologies (to remove NO_x) are expensive and could create environmental concern. Until now, secondary control is applied mostly to power generation and industrial combustion processes but not domestic gas appliances.

Low NO_x technology adoption strategies

In the Australian context, limiting NO_x emissions from domestic appliances and encouraging the introduction of low NO_x technology will be done most easily by continued use of AGA standards. However, if these standards are to be used to address ambient air quality concerns, full cooperation of the government environmental regulators and the gas industry will be required in the development of the standards, which until now have been based on indoor air quality.

In setting NO_x emission standards, a clear distinction can be drawn between criteria based on indoor air quality and criteria based on ambient air quality. Australian AGA codes have been based on the former. The intention has been to limit NO₂ concentrations indoors, with little concern for NO_x emitted through flues to the outside atmosphere. On the other hand, NO_x emission regulations for domestic appliances in the USA and at least some parts of Europe have been driven by ambient air quality concerns. Only "non-attainment areas" for ozone are regulated in the USA, with the objective of reducing photochemical smog. Ozone problems probably do not occur to the same extent in Australia; however a judgement on this is outside the scope of the present study (an overview of Australian ozone levels is given in NEPC (1998b)). It should also be remembered that NO_x from gas appliances constitute less than 0.5% of total NO_x emissions in Australian capital cities, except for Melbourne, where the figure is 1.75% (Todd et al., 1997).

Various strategies are available for governments to encourage the introduction of low NO_x technology in domestic gas appliances. These include "command and control" regulation, voluntary regulation, subsidies, tax concessions, assistance with promotion, public education and tradable emission permits. The Australian practice of calling up voluntary industry codes in legislation has worked well in the past and the gas industry appears to be moving towards introducing low NO_x technology in flued appliances (Saxby, 1998). However, it may be necessary to demonstrate a clearer link between domestic emissions and indoor or ambient criteria before further steps can be agreed.

Australia does not have an eco-labelling scheme. Present appliance labels indicate energy efficiency levels. Some overseas eco-labels include pollutant emission levels in their criteria and a scheme including NO_x levels from domestic gas appliances could be introduced to assist consumers in their choice of products.

Cost to business

The cost to business is a sensitive subject. The indicative costs and lead time for modifying an existing overseas low NO model, or developing a brand new low NO_x model, vary much among different types of appliances and different manufacturers. The information that has been collected is summarised as follows:

• To modify an existing overseas low NO_x water heater model for Australian conditions, the cost, in ballpark figures, is expected to be at least $A 1 million. The lead time required is estimated to be around 1–1.5 years, but could be up to 3 years or longer.
• To develop or import a NO_x control technology and to develop a brand new low NO_x water heater model suitable for Australian conditions, the cost, in ballpark figures, is expected to be $A 3–6 million or more. The lead time required would be at least 2 years, and can be up to 6 years or longer.
• To develop a NO_x control technology and a brand new low NO_x space heater suitable for Australian conditions, a manufacture had spent millions of dollars and many years lead time. After the technology was established, development cost of more new models could be substantially reduced, e.g., less than $A 1 million for four new power flue models.
• To replace three domestic air heater models each with six different sizes by modifying existing overseas low NO_x models, a supplier estimated that the lead time required would be around five years.
  
• To develop a NO_x control technology and a brand new low NO_x cooking appliance suitable for Australian conditions, the cost, in ballpark figures, could be from $A500,000 up to $A2 million. The lead time may be around 2 years.

There have been a number of concerns and comments raised by the industry:

• Market would be lost to alternative appliances such as electric appliances.
• The use of natural gas appliances will reduce the greenhouse gases emissions by up to 80% in Australia (Bavaro et al, 1995). If the market is lost to, e.g., electric appliances, the greenhouse emissions would go up very significantly.
• Appliances that affect only outdoor air quality could have NO_x emissions limits set different from the appliances that affect indoor air quality.
• Implementation of NO_x emissions regulations should be integrated with changes of other relevant regulations such as natural gas supply line pressure to avoid double development.
• The standards for house insulation could be revised to reduce space heating requirement, with the maintenance of good ventilation within the house.
• Some manufacturers believe that regular maintenance may be necessary to maintain the NO_x emission performance of products.
• More accurate NO_x measurement techniques for cooking appliances may need to be developed.
• Government funding will be welcomed for the education of the industry on all aspects of NO_x emissions, and for generic research and development, including NO_x measurement techniques.
• The level of NO_x emission achieved by NO_x control technologies is not inversely proportional to the cost, but dependent primarily on the type of NO_x control principle used and the likely minimum level that can be achieved.

Price differentials

Based upon the indicated manufacturing cost of low NO_x burners provided by two burner manufacturers, the cost of a low NO_x burner to end-users is expected to be $A 60–80 approximately. It can be down to $A 40 or less for high volume production.

Two Australian water heater manufacturers expected the cost of a low NO_x water heater and the installation cost would be higher than that of a non-low NO_x model by 5–15% if a natural draft system can be used. One manufacturer expected that it would be at least 25% higher if a fan-assisted combustion system is required. In an exceptional case, Tokyo Gas in Japan has maintained the retailing price of low NO_x water heaters the same as the previous conventional water heaters to encourage end-users using the low NO_x water heaters despite the increase in manufacturing cost.

In Victoria, the normal retailing price of an ultra low NO_x flued space heater was approximately $250, or 17%, higher than that of a conventional flued space heater from another supplier. Features and performance were not compared but they are expected to contribute to part of the price differential.

In a report in 1997, the retailing prices of low NO_x grills under development in Japan and low NO_x hotplates under development in Germany were expected to be higher than those of the conventional ones by less than 20%. In the same report, it was indicated that the end-user price of low NO_x hotplates under development in Austria was expected to be twice as much as that of the conventional models.

There has been a local concern about little perception of willingness to pay for low NO_x technology by consumers. In order to persuade Australian consumers to purchase low emissions appliances, perhaps a possible approach is:

1. Educational promotion of community awareness of NO_x emissions and their effects on environment.
2. Survey on consumers' awareness of NO_x emissions and willingness to pay for low NO_x appliances.
3. Development of NO_x emissions standards if the consumers and industry are ready to accept it.

The educational promotion may proceed together with other emissions issues such as greenhouse gases.

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