Appliance Standards Awareness Project American Council for an Energy-Efficient Economy

20.500.12592/mtkpdv

Appliance Standards Awareness Project American Council for an Energy-Efficient Economy

31 Jan 2023

Thus, DOE has proposed to amend certain DPPP definitions to align with the equivalent DPPP motor definitions.2 We support aligning the DPPP and DPPP motor definitions, which should reduce confusion or conflict between the DPPP and DPPP motor test procedures. [...] 1 these systems was discussed in prior comments by the California Investor-Owned Utilities.4 Thus, rather than excluding them from the scope of the test procedure, we encourage DOE to explore different system curves that could be used to test these pool filter pumps as part of the DPPP test procedure. [...] We encourage DOE to expand the scope of the test procedure to cover larger DPPPs used in commercial applications. [...] In the NOPR, DOE discusses how commercial and public pools are subject to specific water quality requirements to ensure the health and safety of swimmers, which may represent a barrier to using variable-speed DPPPs in commercial applications.6 For example, pumps used in public pools are typically required to operate continuously while the pool is in use. [...] However, given the potential energy savings for larger DPPPs used in commercial applications, we encourage DOE to include them within the test procedure scope and to develop representative test points and system curves for testing.

Authors

Jeremy Dunklin

Pages
3
Published in
United States of America