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Another U.S. Environmental
Protection Agency (EPA) Office of Inspector General (OIG) report has
been issued, but the EPA wants the world to know that the new report is
only a summary of three earlier audits – it doesn't take into
account all the improvements the EPA had made to the Energy Star
certification process in the last 18 months.
The new OIG report does, however, make two new recommendations, based
on its earlier findings, for improving the Energy Star
program. The EPA issued detailed responses to these
recommendations.
The OIG, in its 2006 audit, found big problems with the way the EPA was
approving products for the Energy Star program – the EPA was
essentially allowing companies to self-certify and had no comprehensive
program for verifying that products bearing the Energy Star label
actually met Energy Star specifications.
Follow-up investigations and reports from the OIG accused the EPA of
taking no action to address the problems. An embarrassed EPA finally
did get to work to clean up the Energy Star certification process and
implemented several recommendations from the OIG reports. The latest
OIG report, the EPA pointed out, does not attempt to assess the
improvements currently underway to strengthen Energy Star.
An EPA statement detailed those steps:
- Keeping
Energy Star relevant by updating requirements across all product
categories.
- Requiring
products get third party certification of efficiency claims from an EPA
Recognized Certification Body (CB). This certification program was
finalized for all 60 product categories on October 26, 2010.
- Strengthening
an "already extensive infrastructure of controls, audits, and other
measures to ensure that the Energy Star name and logo are applied
properly and consistently in the marketplace."
The new recommendations
from the OIG for improving the program: 1, develop a strategic vision
to assure that the Energy Star label represents superior energy
conservation performance; and 2, develop a set of goals and measures to
accurately assess benefits.
The complete text of the OIG recommendations and the EPA responses are
below.
RECOMMENDATION 1:
Develop a strategic vision
that assures that the ENERGY STAR label represents superior energy
conservation performance consistent with the intent of the Energy
Policy Act of 2005.
EPA Response:
The goal of the ENERGY STAR
program is to identify and promote energy efficient products that meet
the highest energy conservation standards and drives the greatest
greenhouse gas savings. To do this, EPA applies a set of principles
when implementing the program. These principles are
consistent with this goal by virtue of the fact that they narrow the
pool of eligible, highest-conserving products to those likely to
enhance consumer acceptance and confidence in the program, thereby
increasing overall reductions in energy consumption. They include
1.
Significant energy savings can be realized on a national basis
2.
Product performance can be maintained or enhanced with increased energy
efficiency
3.
Purchasers will recover their investment in increased energy efficiency
within a reasonable time
4.
Energy efficiency can be achieved with several technology options, at
least one of which is non-proprietary.
5.
Product energy consumption and energy performance can be measured and
verified with testing
6.
Labeling would effectively differentiate products and be visible for
purchasers
Each time an ENERGY STAR
performance standard is established, whether for the first time or as
part of a revision, these principles are balanced to ensure that
specified level will deliver significant aggregate energy savings while
distinguishing products that are cost-effective to the consumer and do
not compromise functionality or performance. Considering
these principles, identification and promotion of products with the
highest energy conservation standards may result in setting an ENERGY
STAR efficiency level so that the top 25% of models in terms of
efficiency can meet it because this level offers the desired amount of
selection and availability while also promising significant energy
savings, cost-effective options and no compromise in performance.
EPA's recent actions (not
evaluated as part of this report) further insure that the ENERGY STAR
label will identify only those energy efficient products that offer
meaningful energy savings (at an individual and/or national level) over
those products typically purchased.
Furthermore, on September
30, 2009, as part of a new Memorandum of Understanding on the
implementation of the ENERGY STAR Program, EPA and DOE agreed upon a
strategic vision for the ENERGY STAR Products Program. As part of this
agreement, the Agencies agreed that the ENERGY STAR label would
continue to identify those energy efficient products that offer
meaningful energy savings (at an individual and/or national level) over
those products typically purchased. In addition,
ENERGY STAR specifications
will be established which:
* Overlay the consumer perspective and the need to consistently
identify top performing products.
* Recognize products that are cost-effective from the purchaser
standpoint; offer at least equivalent functionality and features as
standard products; and are proven and broadly available.
Cost-effectiveness in terms of payback periods will be defined on a
case-by-case basis, taking into account both the expected useful life
of the product and the general desirability of shorter payback periods,
but will in general be 3-5 years.
* Identify top performing products - approximately the top 25% most
efficient of models within a product class - under an ENERGY STAR
specification at the time it becomes effective, with consideration of
expected improvements in product efficiency and market penetration
trends of those products that will take place between establishing a
specification and the specification becoming effective.
RECOMMENDATION 2:
Develop a set of goals and
valid and reliable measures that can accurately inform shareholders and
the public of the benefits of the program.
EPA Response:
EPA has clear goals for the
ENERGY STAR program and articulates the benefits of the program on an
annual basis. For example, in 2008 the goal of the ENERGY STAR products
program was to avoid the emissions of 19.4 million metric tons of
carbon equivalent. To meet this goal, EPA balances energy efficiency
potential, product performance and cost effectiveness as well as
American consumers need for high quality products to set the level for
ENERGY STAR. We do this consistently across 60 product categories so
that consumer expectations are met and a greater environmental impact
can be gained through significant greenhouse gas savings.
As the ENERGY STAR program
grows, EPA is in the process of enhancing its approach to accounting
for program savings. An important aspect of this is a clearly
defined market for key product areas. We continue to refine these
market transformation estimates as data becomes available.
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