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

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

6 Feb 2023

Dommu: This letter constitutes the comments of the Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), National Consumer Law Center (NCLC) on behalf of its low-income clients, and the Natural Resources Defense Council (NRDC) on the notice of proposed rulemaking (NOPR) for energy conservation standards for circulator pumps. [...] We also support DOE’s proposal to specify compliance with the circulator energy index (CEI) standard using the least consumptive control method but encourage the Department to require the additional reporting of ratings with the most consumptive control method. [...] The first recommendation of the November 2016 CPWG term sheet was to group circulator pumps into a single equipment class; the recommended CEI standard for the single circulator pump equipment class varies only as a function of hydraulic output power.2 As discussed in the NOPR, while three primary 1NPV estimates are 1.8 and 0.7 billion USD at 3% and 7% discount rates, respectively. [...] We support DOE’s proposal to specify compliance with the CEI standard using the least consumptive control method but encourage the Department to require the additional reporting of ratings with the most consumptive method. [...] In the NOPR, DOE proposes that compliance with the standards will be determined when the circulator pump is operated using its least consumptive control mode.4 The advantage of this proposal, where CEI ratings are based on the least consumptive control method, is that it highlights the energy savings potential for circulator pumps with variable-speed controls.

Authors

Jeremy Dunklin

Pages
3
Published in
United States of America