Comment
The updates included focus on test methods, scope and/or efficiency requirements, however for a number of these products there are no performance test methods for the full range of products identified, specifically both natural gas and electric versions of these products. Therefore this regulation should clarify what products are being referred to, as was done for "residential electric steam boilers" where the fuel type was identified and therefore only addresses the test method and efficiency requirement for this fuel type appliance.
The following are suggested changes to the wording:
#B5 “Single package vertical air conditioners and heat pumps”, suggested wording “Single package vertical electric air conditioners and heat pumps”
#B6 “Small air conditioners and heat pumps (less than 19 kw)”, suggested wording “Small electric air conditioners and heat pumps (less than 19 kw)”
#B7 “Internal water loop heat pumps”, suggested wording “Internal water loop electric heat pumps” “Variable refrigerant flow (VRF) water-source heat pumps”, suggested wording “Variable refrigerant flow (VRF) water-source electric heat pumps”
#D1 “Large air conditioners and heat pumps (19kw or greater)”, suggested wording “Large electric air conditioners and heat pumps (19 kw or greater)”
#D2 “Water chillers”, suggested wording “Electric water chillers”
[Original Comment ID: 210712]
Submitted January 24, 2018 11:00 AM
Comment on
Proposal to amend O.Reg. 404/12 (Energy and Water Efficiency – Appliances and Products) under the Green Energy Act, 2009 (“Efficiency Regulation”).
ERO number
013-0812
Comment ID
63
Commenting on behalf of
Comment status