EPA, DOE Propose New ENERGY STAR Top-Tier Program

The EPA has also posted the comments it received on this proposed program, which were due by October 29, 2010.

EPA and DOE Want to Identify “Top Tier” of ENERGY STAR Products

EPA and DOE recently issued a “Top Tier” proposal to examine how to best identify the top-tier of energy efficient products. Their goal is to drive more energy efficient products to the market more quickly. This new effort would be (1) an extension of the ENERGY STAR brand, (2) target “early adopters,” and (3) highlight super-efficient products within specific product categories, where they exist.

“Top Tier” to Focus on Six Products, Including TVs, Air Conditioners, Etc.

EPA and DOE made a preliminary assessment of the consumer product categories covered by the ENERGY STAR program and proposed an initial focus on product categories typically promoted at higher performance levels by utility and state sponsored efficiency programs. This initial list includes the following six product categories: (1) clothes washers, (2) dishwashers, (3) refrigerators, (4) TVs, (5) central air conditioners, and (6) heating equipment.

Commenters Support Proposal, But List Concerns

The following are highlights of the comments received in response to the EPA and DOE proposal:

Could Result in More Energy Efficiency, but also Dilute ENERGY STAR Brand

Several commenters expressed support for the proposed Top Tier program and were pleased to see efforts to enhance the ENERGY STAR program in ways that expand the program’s reach and give additional recognition to products that offer greater energy savings and bring innovative new technologies into the market. They support efforts by EPA and DOE to provide incentives to manufacturers, retailers, and consumers for continual energy efficiency improvement.

However, one commenter expressed concern that the proposal may dilute the ENERGY STAR brand from a stakeholder perspective.

Want More Clarity on Proposal, Access to Data

Several commenters noted that they think the proposal needs clarification. One commenter encouraged EPA and DOE to take steps to clarify the specifics of the Top Tier program as they develop and to share plans with stakeholders. Overall, the stakeholder proposal and webinar presentation were vague in several areas.

Another commenter noted that although EPA has conducted several focus groups and one-on-one interviews with consumers, details of the study, its methodology, questionnaires, and other relevant information has not been made publicly available on EPA’s website.

EPA Not Adequately Investigating Other Alternatives

One commenter noted that EPA is not adequately investigating other alternatives, including ones that could be less costly for EPA to administer. For example, simply changing the traditional top-quartile approach of the existing ENERGY STAR program to a smaller percentage of the market could help address some of the opportunities to the Top Tier approach.

Coordinate with Similar Private and Gov’t Programs

The proposed program should take advantage of, and coordinate with other existing private and governmental programs such as the Superefficient Equipment and Appliance Deployment (SEAD) Initiative, Consortium for Energy Efficiency (CEE), and TopTen USA. By avoiding duplication and leveraging the efforts of other programs, a Top Tier could be more effective.

Core ENERGY STAR Program Needs Fixing First

One commenter stated that before spending large amounts of resources on a new Top Tier program, EPA and DOE should work to fix previously-identified problems with respect to the core ENERGY STAR program. For example, EPA and DOE should consider concerns raised in the recent Government Accountability Office report (GAO-10-470) and the DOE Inspector General audit report (DOE/IG-0827) on ENERGY STAR.

(GAO’s March 2010 report found that ENERGY STAR is for the most part a self-certification program vulnerable to fraud and abuse. GAO obtained ENERGY STAR certifications for 15 bogus products. GAO found that for these bogus products, certification controls were ineffective primarily because ENERGY STAR does not verify energy-savings data reported by manufacturers. ENERGY STAR required only 4 of the 20 products GAO submitted for certification to be verified by an independent third party.

The October 2009 OIG report found that DOE had not implemented planned improvements in the ENERGY STAR program, which could reduce consumer confidence in the integrity of the ENERGY STAR label.)

EPA, DOE Decision Expected in December, Rollout to Begin in January

EPA and DOE expect to reach a decision on this proposal in December 2010 and, if approved, begin the rollout in January 2011.

(See ITT’s Online Archives or 03/30/10 news, 10033015, for BP summary of DOE and EPA announcing they would strengthen ENERGY STAR, in response to the GAO report.)