August 2, 2017…

August 2, 2017

VIA ONLINE FORM

Ms. Senka Krsikapa
Manager, Conservation and Renewable Energy Division
Ministry of Energy
77 Grenville Street, Floor 5 &6
Toronto, ON, M7A 2C1
Senka.Krsikapa@ontario.ca

RE: Comments of the American Lighting Association on the Proposal to amend O.Reg. 404/12 (EnergyEfficiency – Appliances and Products) under the Green Energy Act, 2009 (“Efficiency Regulation”) –EBR Registry Number 013-0812

Dear Ms. Krsikapa:

The American Lighting Association (ALA) represents over three thousand members in the residential lighting, ceiling fan and controls industries in the Canada, the Caribbean and the United States.Our member companies are manufacturers, manufacturers’ representatives, retail showrooms and lighting designers that have the expertise to educate and serve their customers. The membership of ALA includes 19 manufacturers of ceiling fans or ceiling fan light kits (CFLK) and nearly 975 retail showrooms that sell ceiling fans or CFLKs.

ALA appreciates the opportunity to submit these comments on the Ministry of Energy’s (MoE) proposal to update test methods, scope and efficiency requirements for ceiling fans and CFLKs. ALA submits these comments on behalf of a group of its members and other interested parties that would be directly impacted by the regulations – companies that manufacture, import, distribute, and retail ceiling fans and CFLKs in Canada. ALA and its members are therefore uniquely situated to comment on the proposals outlined in the Ministry of Energy’s Environmental Registry.

Ontario Ministry of Energy Proposed Regulations are Appropriate to Achieve Harmonization

On September 2, 2016, ALA submitted comments to the MoE (EBR Registry Number 012-7871). In those comments, ALA brought to the MoE’s attention a recent agreement between Natural Resources Canada(NRCan) and ALA regarding the requirements for CFLKS. Furthermore, ALA encouraged the MoE to adopt the language of the joint agreement and to pace the regulatory process with that of NRCan.

ALA would like to thank the MoE for effectively responding to those comments. The latest proposal reflects the changes ALA had hoped to achieve with respect to CFLKs and even goes a step further by calling for complete harmonization with the U.S. Department of Energy.

The latest proposal also expands product scope to include air flow requirements for ceiling fans.ALA supports this expansion of the scope and supports the MoE’s proposed regulations for ceiling fans.

Lastly, ALA appreciates MoE’s awareness to harmonize compliance and coming-into-force dates forthese two product classes.

Conclusion

As technology and innovation are revolutionizing the lighting and ceiling fan industry, ALA members are leading the way in developing energy efficient products. By working in conjunction and effectively with our government partners, ALA manufacturers are meeting consumers’ demands for energy efficient products like ceiling fans and CFLKs, while maintaining style and design product choices that meet their needs. The ALA appreciates the Ministry of Energy’s work and looks forward to seeing this process through to the end.

Respectfully Submitted,

/s/

Eric Jacobson, CAE
President & CEO

American Lighting Association
2050 N. Stemmons Freeway, Unit 100
Dallas, TX 75207
214.698.9898
americanlightingassoc.com

cc: Micheline Brown – Team Leader, Equipment DivisionBack Close

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