Response ID ANON-WVXD-1KHR-Y
Submitted to Energy Efficiency of Swimming Pool Pumps
Submitted on 2016-12-13 15:09:51
Introduction
1 What is your name?
Name:
Bryan Goh
2 What is your email address?
Email:
3 What is your organisation?
Organisation:
Waterco Limited
4 How are you involved in the pool pump industry?
Pool pump-unit manufacturer
If other, please specify:
Labelling
5 Do you support the proposal to introduce mandatory energy labelling of pool pumps?
Labelling proposals:
Yes i support the mandatory energy labelling of domestic pool filtration circulation pumps, but exclude pumps not designed for domestic pool filtration, including solar pumps, pumps designed for swimjets, infloor systems etc.
Pumps with a hair and lint pot and sizes from 0.5hp to 1.5hp or up to 1.5kw
Minimum Energy Performance Standards
6 Do you support the introduction of a Minimum Energy Performance Standards (MEPS) for pool pumps? Please explain your answer, and
which option you prefer.
minimum energy performance standards:
I support the introduction of MEPS only if the new curve G is introduced, as larger pool pumps are unfairly treated by the D curve and hence end up with an extremely low star rating.
MEPS should only be applied to domestic pool pumps designed for pool filtration and exclude pool pumps not designed for pool filtration
Scope of Proposals
7 Do you have views on the scope of new labelling and MEPS requirements? What types or size of pool pumps should be covered?
scope of proposed measures:
I believe the scope should be changed to input power of less than 1500W.
Not many domestic pools will be equipped with filtration pool pumps larger than 1500W.
The existing system curve will unfairly disadvantage larger pool filtration pumps.
As mentioned previously we should focus on domestic filtration pumps.
Adjustment to Measures
8 What opportunities or difficulties could mandatory labelling or MEPS for pool pumps create for your company? How much time would
your company need to adjust to a change?
opportunities or difficulties arising from measures:
I don't believe there are many difficulties, the main hurdle would be timing of new stock with the new labelling. I believe 12 months would be sufficient for us to adjust to change.
The opportunity I see with mandatory labelling is the creation of a standard for all companies to measure the performance of their pumps so customers can compare all pumps equally.
The introduction of mandatory labelling will lead to the pool owner questioning the size of the pool pump and seeking alternatives, such as variable speed pumps.
The introduction of mandatory display of noise levels will also allow quantitative comparison rather than subjective comparison.
Data and Assumptions
9 Do you agree with the data and assumptions made in this RIS?
data and assumptions:
Yes
10 Please attach data or evidence to support your submission here:
upload data:
No file was uploaded
New Zealand
11 What are the implications of New Zealand opting out of the regulation of pool pumps?
new zealand market and issues :
We would offer energy star rating labelled pumps to the New Zealand market.
It would not make sense for us to only label pumps sold to the Australian market.
Additional Comments
12 If you have any further comments on the consultation RIS document and the proposed measures, please provide them below.
additional comments:
I would suggest reaching out to the original committee members of AS5102.1 and 2.
Much of the debate around the scope and the system curve revolved around MEPS.
Therefore I would suggest the introduction of mandatory labelling and system curve G to help cater for larger sized pumps and also lift the head of the system curve, to a more realistic level.
13 Can we contact you about your submission?
Yes
14 All submissions will be published online, unless they contain confidential information. Are you happy for the department to publish your submission?
Yes