Here's my comments…

Here's my comments specifically related to AIR COMPRESSORS as reference to the Proposal to amend O. Reg. 509/18 under the Electricity Act, 1998 (“Efficiency Regulation”).

The overall energy efficiency of a compressed air system is determined by appropriately sizing and operating components related to compressed air supply, distribution and demand. The most efficient Air Compressor will perform very inefficiently if it is not installed and configured appropriately in the context of compressed air system supply, distribution and demand.

Auxiliary components like properly sized air receiver tanks and distribution pipes, flow controllers, compressor sequencers and air flow meters can make a bigger impact on improving the energy efficiency than changing air compressor Standards. Let's also not forget air leaks and inappropriate use of compressed air.

The upper limitation of 200 HP and/or 1250 cfm capacity falls short size found in many of Ontario's manufacturing facilities.

The Standard proposes to use full-load isentropic efficiency for fixed speed compressors and part-load isentropic efficiency for variable speed drive compressors. Almost all (i.e. 99.99%) of Ontario's operating air compressors operate at part-load or different discharge pressures than the Standard. Using isentropic efficiency for compressor selection may result in an incorrect decision at the time of purchase and installation.

The Standard's permissible error in measuring air compressor energy performance is greater than the expected energy performance improvement. The test method will not assure the purchaser that the anticipated energy efficiency performance improvement will be attained.

By focusing only on the air compressor and not taking a systems approach, the Ministry is taking a "band-aid" approach. Regrettably , this approach will not result in meaningful improvements to the overall energy efficiency of compressed air systems in Ontario.