CEA submits Suggestions And Expresses Concerns On Proposed Changes To ENERGY STAR Program

On Jan. 19, CEA submitted comments to the U.S. Environmental Protection Agency and U.S. Department of Energy regarding the agencies’ recent memorandum of understanding and Enhanced Program Plan for ENERGY STAR products. Both documents propose significant administrative and program changes to ENERGY STAR. CEA’s comments focused on the following concerns and issues: the proposed requirement for product testing by accredited labs; the imposition of a top-tier “Super Star” program; the proposal for overall limits on energy use; the agencies’ responsiveness to stakeholder comments; the use of advocates as consultants; product testing and product returns; and the use of industry test procedures.

According to the U.S. EPA and the U.S. DOE, the following program changes have been suggested:

ENERGY STAR Products Program

Program design: The ENERGY STAR products program will be enhanced in the following ways:

  1. Specifications will be set so that the ENERGY STAR logo is applied consistently with established program principles and with approximately only the top quartile of products eligible.
  2. Product coverage will be expanded to include new consumer products with high energy saving potential.
  3. Verification of compliance with program requirements will be increased and efforts will be enhanced to identify and address product performance issues.
  4. An ENERGY Super Star program will be nested within the ENERGY STAR program to enable consumers to identify the top performing products.

Roles and Responsibilities:

  • Management. The EPA will manage the ENERGY STAR products program and the new Super Star program, in consultation with DOE.
  • Testing for Program Purposes. EPA will maintain product testing results data with support from DOE as agreed to by the Agencies. DOE will lead the development of product testing procedures and metrics with EPA assisting where necessary.

National Building Rating Program

Program design: The National Building Rating program will be enhanced in the following ways:

  1. A comprehensive whole building scale-based rating tool will be developed and promoted that reflects both the physical characteristics of a building (asset rating) and a way to compare the actual energy use of existing buildings with similar buildings.
  2. A labeling scheme will be developed to easily convey the energy use information from the whole building scale-based rating tool.
  3. The whole building scale-based rating tool will take account of the inherent building envelope, major energy-using equipment and appliances, and past performance based on utility bills.
  4. The whole building scale-based rating tool will be updated periodically to reflect improvements in building technology and analytical tools, and to enhance usability.
  5. The eligibility of buildings for the ENERGY STAR logo as applied to buildings will be based on the rating systems of the National Building Rating Program.
  6. The criteria for the ENERGY STAR logo will be updated periodically to reflect improvements in building energy efficiency, diagnostic capability, and market appetite for energy efficiency, and will be based on established program principles for the ENERGY STAR brand.

Roles and Responsibilities:

  • Management. DOE will manage the National Building Rating program including the development of the whole building scale-based rating tool and associated labeling scheme, in consultation with EPA. EPA will continue its efforts to encourage key stakeholders to build new buildings to ENERGY STAR levels and improve existing buildings.
  • Testing for Program Purposes. DOE will maintain building performance data with support from EPA as agreed to by the Agencies. EPA will support various aspects of the program and assist DOE with input to help inform development of the framework, tools, and updates of the rating schemes
  • Specification Levels. The performance levels for the ENERGY STAR when applied to buildings will be set by EPA, with technical input provided by DOE and the National Building Rating Tool, consistent with established principles for the program.

Overall program coordination

  • DOE and EPA will periodically evaluate and as appropriate modify their program efforts to ensure that the ENERGY STAR and National Building Rating programs are mutually reinforcing and coordinated.

To view the entire Memorandum of Understanding on Improving the Energy Efficiency of Products and Buildings, click here.

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