Other Comments 1) Streamline registration process 1) Load processing test is not 1) Do not support load - 1) Regardless whether to only require information that sufficiently mature to be processing test a standard or confirms compliance with GEMS used: results variable; determination 2) Maintain requirement requirements refrigerator defrost approach is adopted, for test report for three unpredictable; freezer results the document should 2) Need to use up-to-date price appliances also variable; IEC does not be stand alone and coefficients and sales data for the cover how to deal with not reference other 3) Revise CBA for higher decision RIS modelling defrost during load standards or testing and development processing; allowing documents and be 3) Need to provide basis for 15 year costs different set points may written in easily refrigerator lifetime assumption 4) Exclude beverage provide gaming opportunity. understood English 4) Modelling has not included coolers Exclude load processing for 2) The Determination sensitivity analysis of electricity ERL until issues resolved. 5) Define parameters should not be prices nor product lifetimes enabling voluntary wine 2) 16C test results are too accepted until it has 5) Regulator should consider cabinet labelling variable. Suggest using a been formally automatic recognition of registered fixed ‘average’ figure as a accepted at an 6) Use recent sales data products that meet MEPS3 placeholder industry meeting in decision RIS and/or emailed to 6) Need to include 'other beverage 3) Consider defining 7) Revise RIS to reflect interested coolers' in exclusions adjustment factor for defrost that retail prices do not stakeholders at 230v cw 220v 7) Multiple tests are required to correlate with energy 3) Stakeholders understand product variability efficiency but high 4) Checktest tolerance needs should have a efficiency products cost to be reviewed 8) Support retaining pulldown test timeline in which they more to produce can "Return for 5) Support retaining 9) Need to define defrost 8) Confirm MEPS levels rewrite" until it is pulldown test temperature excursions as in during the development deemed accepted AS/NZS 4474.1 Clause 3.7.3 of the decision RIS 10) Define volume tolerances 9) Support retaining pulldown test 11) Review check testing tolerances 12) Repeatability/accuracy of the load processing test questioned
Other Comments 1) Streamline registration process to only require information that confirms compliance with GEMS requirements 2) Need to use up-to-date price coefficients and sales data for the decision RIS modelling 3) Need to provide basis for 15 year refrigerator lifetime assumption 4) Modelling has not included sensitivity analysis of electricity prices nor product lifetimes 5) Regulator should consider automatic recognition of registered products that meet MEPS3 6) Need to include 'other beverage coolers' in exclusions 7) Multiple tests are required to understand product variability 8) Support retaining pulldown test 9) Need to define defrost temperature excursions as in AS/NZS 4474.1 Clause 3.7.3 10) Define volume tolerances 11) Review check testing tolerances 12) Repeatability/accuracy of the load processing test questioned 1) Load processing test is not sufficiently mature to be used: results variable; refrigerator defrost unpredictable; freezer results also variable; IEC does not cover how to deal with defrost during load processing; allowing different set points may provide gaming opportunity. Exclude load processing for ERL until issues resolved. 2) 16C test results are too variable. Suggest using a fixed ‘average’ figure as a placeholder 3) Consider defining adjustment factor for defrost at 230v cw 220v 4) Checktest tolerance needs to be reviewed 5) Support retaining pulldown test 1) Do not support load processing test 2) Maintain requirement for test report for three appliances 3) Revise CBA for higher testing and development costs 4) Exclude beverage coolers 5) Define parameters enabling voluntary wine cabinet labelling 6) Use recent sales data in decision RIS 7) Revise RIS to reflect that retail prices do not correlate with energy efficiency but high efficiency products cost more to produce 8) Confirm MEPS levels during the development of the decision RIS 9) Support retaining pulldown test - 1) Regardless whether a standard or determination approach is adopted, the document should be stand alone and not reference other standards or documents and be written in easily understood English 2) The Determination should not be accepted until it has been formally accepted at an industry meeting and/or emailed to interested stakeholders 3) Stakeholders should have a timeline in which they can "Return for rewrite" until it is deemed accepted
household_refrigerators_and_freezers.docx