ENERGY STAR Pilot Verification Testing Program (text version)
Below is the text version of the Webinar titled "ENERGY STAR Pilot Verification Testing Program," originally presented on August 24, 2010. In addition to this text version of the audio, you can access the presentation slides and a recording of the Webinar (WMV 12.4 MB).
Anthoney Perkins:
- screen, the URL www.buildings.energy.gov/webinars. On that page you will see a link to today's slides and also today's presentation is being recorded and a video of the presentation will be posted in the future. You can also view past webinars on our archive page which is available from there as well. Finally, we have a few quick questions we're going to ask to help us learn more about our audience and target our future presentations. We're going to start with two questions now and at the end we'll have two more questions before we go into question and answers. So please click on the screen to indicate your appropriate response when you see it.
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The first one, at your location how many people are participating in today's Webinar? So how many do you have in your office? We will give you a few moments to answer this before we move on. If you haven't done so please go ahead and choose your answer now. We're going to close this question in just a second. Okay, we're going to go ahead and move onto the next question.
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What best describes your affiliation or organization? So if you'll choose what best describes that for us and then we'll move on after that. I'll give you a few moments. Give you just another moment to choose your answer and then we'll move on. Okay, we're to go ahead and close this question. Thank you for your participation. As I said, at the end we'll have two more questions to go through. So now I'll introduce our speaker today.
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Rich Karney is the Program Lead in Testing and Verification for the Building Technologies Program at the U.S. Department of Energy. Mr. Karney heads up the development of a new testing procedures for appliances that will verify that off the shelf products are performing to the ENERGY STAR Program requirements. So with that I'll turn it over to you Rich.
Rich Karney:
Thank you Anthoney.
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What I'd like to do today is discuss the Pilot Verification Program for selected ENERGY STAR products –
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- and during the course of today's discussion I'll give you a reason why we're doing it, what the program looks like, the process that we're using for testing the products, the results to date and some of the lessons learned that we've picked up over the course of the last few months that we've been doing the testing.
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But for the background –
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- first of all just to give you a quick ENERGY STAR 101 I think probably everyone on the call knows that ENERGY STAR is an energy efficiency program that's been managed by the Department of Energy and the Environmental Protection Agency and the goal of the program is to provide very simply an indication to the consumer of what products are energy efficient so the consumer can go forth and purchase these products with the goal of saving energy, saving money and saving the environment. There are various pathways that we do this for energy efficiency. We have over 60 products that are labeled with the ENERGY STAR label. There's an ENERGY STAR homes program. There's an ENERGY STAR buildings program and there's also an ENERGY STAR retrofit program which looks not only at residential situations but also the commercial and also industrial buildings. Again, the goal is to improve energy efficiency of the country, to reduce the use of energy, reduce the utility bills of the consumer and the building owner and of course to save the environment.
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Now why are we doing this verification testing? Well over the course of the last few years there have been a couple of reports that have been written, a couple of reports that have been published that have basically looked at the program and said, "You know EPA, DOE, the program's not exactly living up to what you guys claim it's living up to."The various inspector generals of the Department of Energy and the Environmental Protection Agency have questioned some of the numbers that have come out of the program, some of the calculations we have done, some of the savings we have claimed. The IG reports have also hit both of them that – the reports that both came out basically looked at that the government is not qualifying products as it should. It's not verifying that some of the products that are being labeled really are performing up to snuff.
The Government Accountability Office more recently has come out with a report which basically has shown that it's possible to have products qualified in the program that are not – that will not perform up to the criteria. There are a number of products that they have qualified due to the fact that we normally would be accepting the manufacturer's self-certification of products. Some of the products that the GAO was able to get qualified by the program not only don't save energy they don't even use energy. So they basically show that without verification of the product performance it is possible to have products qualify for the program.
So what we've done is set up a verification – what we've done and this is something that was being discussed between DOE and EPA previously and we had started to do the changing of the qualification process for the program long before – well not long before necessarily but certainly before the GAO came out with their report that we're going to start to require laboratory testing of products to – in order to qualify for the program. The GAO report just emphasized that we needed to accelerate this and this is exactly what has been done in the fact that to qualify a product now laboratory testing is required to show that the product does perform up to specification. Also we started doing this verification testing to support the State Energy Efficiency Appliance Rebate Program.
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Now the SEEARP or the Appliance Rebate Program was authorized by EPA back in 2005. It was reauthorized by the EISA, the Energy Investment Security Act in 2007 and in 2009 the American Reinvestment and Recovery Act provided $300 million to support the State Energy Efficient Appliance Rebate Program. What this does is provide money to the states and the territories to incentivize and rebate provide money to consumers to purchase energy efficient appliances. So what the Department has done is it has set up a program where it has asked the 56 states and territories to develop their own rebate program to – basically design it for their own use on how they will go ahead and rebate programs. The amount of money that goes to each state is based on population. Now the verification program that we're running here at the DOE we looked at the products that were being incentivized, being rebated by the states. As you see on the chart on the right hand side shows that clothes washers are being – offering this – 47 out of the 56 states and territories are offering rebates on clothes washers, 44 on dishwashers, etc. What we've done is for the Verification Testing Program is take a look at this chart and decide that we were going to test the most popular products being rebated by the states.
So in our program we are testing clothes washers, refrigerators, dishwashers, room AC, freezers, gas tankless and gas storage water heaters. We are not testing furnaces at this time because that test is more expensive than – probably takes a little bit more time than the other ones do. What we plan to do in the future is starting in the next fiscal year in October we're going to expand the program to not only test the eight products that we're testing right now but we're going to be adding in furnaces. We hope to add in electric heat pump water heaters and central AC and air source heat pumps into the program. There might be other products. We are looking at it right now as we expand the program. We're looking at what products we're going to add to the program. So right now we're doing eight. We hope to add around three or four more products into the Verification Program as we proceed on into next fiscal year.
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Other related Department of Energy initiatives in conjunction with the Verification Testing Program we are starting up a DOE lab accreditation program which – well the labs that we're using right now to do the testing already are accredited by various accreditation bodies throughout the country and throughout the globe and they are at least accredited to international standards, organization standard 17025 which is basically accredits the laboratory itself. What we will be doing in the DOE lab accreditation program is accrediting laboratories to do specific tests. In other words, do the federal test procedures on clothes washers. That lab's accredited to do that. Another lab might be accredited to do the federal test procedure on dishwashers. Obviously a lab can be accredited to do more than one test but that's what the lab accreditation program is being set up in order to make sure the laboratories can perform and can conduct the federal test procedures.
As an adjunct to the Verification Program the Department of Energy is doing round-robin testing of laboratories for the Standards Enforcement Program and that's being managed by the National Institution of Standards and Technology for the Department. These labs will – the test labs themselves will be doing the federal test procedures for the standards work and we also hope to use those laboratories also for the ENERGY STAR Program. The department is also accelerating our test procedure development. What that means is we are looking at the ENERGY STAR test procedures, not only the federal test procedures that govern some of the ENEGY STAR products but the test procedures for all of the ENERGY STAR products and we're working hand in hand with the Environmental Protection Agency to prioritize what products need to have the test procedures either revised or test procedures developed.
Many of the products are used in industry wide test procedures to qualify the products for the ENERGY STAR Program and we're looking in all the products to see if we need to help revise them or create new test procedures. Of course the Department has a federal mandate to develop energy conservation standards. We do that by rule making for the various products. These standards provide minimum performance requirements of all products, all covered products that is and ENERGY STAR uses the – in many of the products uses the minimum energy efficiency standards as the basis for developing ENERGY STAR criteria.
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Now I'd like to give you a quick overview of the testing –
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- program itself. Basically, what we're doing is that we are testing products. We are buying the products off the retail floors or at a retail settings to show that these products do indeed meet the ENERGY STAR requirements. We want to maintain the integrity of the ENERGY STAR label so when a consumer goes into a retail setting they know that this product will perform up to or better than the minimum requirements set in the ENERGY STAR Program to assure them that they are getting the utility savings and in the cases where the products use water the water savings that are predicted by ENERGY STAR. We also want to make sure that no manufacturer gains an unfair competitive advantage by misusing the label. If we find that the machine being taken off the retail floor does not perform up to the ENERGY STAR criteria we will begin ENERGY STAR enforcement actions on that. We are – obviously we want to establish the foundation with this pilot program to begin an extended Verification Program which will – again, we will begin next fiscal year.
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How is the pilot program set up? Well let me get a little pointer here or arrow. I'm located in this box, the DOE/EERE/BT box where we're providing – I'm providing the program management and coordination for the program itself. We've approved the appliance purchase list and we the ones are doing the initial communications with the manufacturer. We use the National Energy Technology Laboratory to do our program administration and also those – these are the folks that go out and actually purchase the products and ship them to the laboratories. There's a contractor that works for the National Energy Technology Laboratory who's doing the subcontracting administration who has helped with the test facility selection and helps with the quality control and the quality assurance of the laboratories themselves. There's a subcontractor to that contractor.
I don't mean to go through this various bureaucracy but there's a subcontractor who helps with the appliance selection, who helped with monitoring the laboratory facilities and who is doing the review of the reports and providing technical support. Underneath the NETL contractor is we have four laboratories that conduct the appliance testing themselves. We have four right now. We will probably be expanding later on and then when the program expands in the next fiscal year. The DOE Office of General Council is also working with us to monitor the program to see if when the test results come in if any of the products don't meet the minimum standards. If there are any problems with not meeting the energy efficiency minimum standards our Office of General Council will get involved. Generally, we work hand in hand with EPA on the program to – we discuss the results with them and if there are any enforcement actions that need to be done on products not passing the test, not meeting ENERGY STAR requirements EPA will take over any enforcement actions at that time.
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The testing process itself –
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-deals with product selection and the procurement. Basically, we bought the products and ship them to the laboratories. The lab selection, what we have done on lab selection is prior to beginning the test we sent out a request for proposals from the laboratory which ones are qualified to do the testing. We also obviously went out to get a price to see what it would cost to do the test and we selected four laboratories to conduct the test for us during the pilot phase. Stage I testing where we're doing basically screening tests. We are testing one model per unit for – one product for each basic model and if the – we'll go through this again, but if the product meets the ENERGY STAR requirements where no action's required. If it does not we go into Stage II testing.
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Now what we did for selecting we were hoping to basically test every model over the course of five years. So in other words, we would be doing 20 percent of the basic models per year for the appliance types that have been selected for the testing program. So as you see here on the products that we are testing this year there are 405 basic models of refrigerators, 121 basic models of freezers, etc. What a basic model is a unit that includes all variations that manufacturers may tweak to the machine itself but these basic models have the same energy use characteristics. So you can have a refrigerator that has different colors, different trims. You may have 16. You may have 45 different models available per basic model on a unit.
Refrigerators obviously have many different decorative changes that go into a unit which makes it many models for a basic model. For refrigerators we plan on testing 82 refrigerators during the course of this pilot program. So that's – and room air conditioners, for instance, there's so many out there we're doing 80 out of the 400 room air conditioners that are available in the marketplace that are on the qualified product list. These numbers here come off the ENERGY STAR qualified product list. So there are 405 basic models, for instance, on the ENERGY STAR qualified product list that are eligible to be tested by the program.
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We randomly selected these models, used a random generator. The NETL contractor used a random generator model to select a contract, to select the products to be tested. Some of the models were not available for sale through a normal retail distribution so we did not pick those models to be tested and some of the models were discontinued before we were able to purchase a unit. We also selected about ten basic models based on strategic considerations. What's a strategic consideration? Well for instance, when a consumer may have a complaint that they bring up to the Department or to ENERGY STAR saying, "This model is not performing or is not – doesn't seem to be performing up to what we had hoped when we purchased this model." So we added these on to the – for the selection process in order to verify whether or not the consumer had a valid complaint or if the product did perform up to the criteria stated.
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As I mentioned we selected the test laboratories based on a number of the criteria. Obviously, price of the test was one criteria but that was not the overriding one. We wanted to make sure that the laboratories that we selected were not affiliated with appliance manufacturers. Now all appliance manufacturers do testing. They test their products to ensure that they meet the minimum standards, that they meet ENERGY STAR standards also and prior to requiring laboratory verification test results to be submitted for qualification manufacturers themselves certify these units. So we wanted to make sure that we had independent laboratories not affiliated with appliance manufacturers to conduct the testing.
We wanted to make sure that the laboratories were located in the United States or Canada to minimize shipping. We wanted to make sure that the laboratories were recognized as a credible source to do the testing themselves. So there had to be some history of doing the federal test procedures on these appliances and having a reputation that it was accepted by manufacturers that they do recognize this laboratory as a source to do these testings for us. We wanted to make sure the laboratories could meet our schedule and that we could be able to enter into laboratories to do some QC and QA procedures. Matter of fact, at all the laboratories that we selected, the four that we selected we did have our contractors and in fact I visited one or two of the laboratories prior to beginning the testing program to make sure that they did have QC and QA procedures in place and also that they could indeed conduct the federal test procedures themselves.
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So the four laboratories that we selected are BR Laboratories out of Huntington Beach, California; CSA International, their two facilities, the one up in Toronto and the one in Cleveland, Ohio; Intertek Testing Services is located in Cortland, New York; and Springboard Engineering is located in Newton, Iowa. These are the products that they have met the requirements to conduct the testing on. As I mentioned just a moment ago we did go into the facilities to confirm that they did have the apparatus, they did have the equipment and they did have the capability of conducing the test themselves.
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So this is the way we spread out the appliances to be tested by each laboratory, BR Labs doing refrigerators and clothes washers, CSA doing a whole slew of the appliances, Intertek doing freezers and room AC and Springboard due to their proximity to the old Maytag facility they're able to do clothes washer testing.
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How's the program set up? What actually goes on in the process of testing a machine for the Pilot Verification Program? We start out by doing a Stage I test which is, as I said before, testing one machine. If the machine falls – performs and the results come in within 5 percent of the ENERGY STAR specifications or better there's no action to be taken. If the test falls outside of the 5 percent tolerance that we're allowing first thing I'm going to do I'm going to contact the manufacturer. I'm going to tell him. I'm going to give him a copy of the test report. I'm going to tell him that the machine did not perform within 5 percent of the ENERGY STAR specifications and you have a choice.
He can request additional testing and what we'll do then is buy three to seven more machines and test them in what we're calling out Stage II test to see whether or not the machines do perform within – up to the ENERGY STAR specification. The manufacturer can also decide that he does not want us to do additional testing. In that case, we will refer that model to the Environmental Protection Agency for them to continue on enforcement actions for ENERGY STAR. When we conduct the Stage II test if we find out that the Stage II tests do show that the model itself is compliant with ENERGY STAR specifications within the – we will then assume that it does meet the ENERGY STAR specs and there'll be no action taken.
If the machines show that they are not compliant with ENERGY STAR specification we will again refer the action to the Environmental Protection Agency. Now at Stage I if we see that the machine performs below the minimum energy efficiency standards that are set by the Department of Energy to be tested to be – excuse me, to be sold in the U.S. market we will refer the action for enforcement testing to our general council and they will then pick up the ball and notify the manufacturer that enforcement testing might begin on that model that has performed below the minimum energy efficiency standard. That's the way the process itself has been set up for the test.
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Now people have asked, "What about products that aren't requiring further actions, for products that do meet the ENERGY STAR criteria? What's going to happen with them?" Actually nothing. We're not going to provide any information on models that basically meet the ENERGY STAR Program requirements because we've learned when we had a similar program testing contract for us at Lambs Spot, a PEARL program that was run by various utilities throughout the country and the Department of Energy we found that the products that did meet the ENERGY STAR specifications were given an unfair market advantage because the utilities were incentivizing models that passed PEARL testing and we felt and for this test that if we release the information products that met the ENERGY STAR Program requirements that these models might be solely incentivized by utilities and gain an unfair market advantage. So we are not going to release information on models that do indeed meet the ENERGY STAR Program requirements.
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So what has happened to date?
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Well in the program itself we are planning on testing a total of 267 models. So far we've tested less than half, around 40 percent; 110 units have been testing. So we have 157 remaining. This is a breakout of machines that have been tested so far and how many remaining to be tested per product category.
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To date 17 percent of the units are requiring further action. In other words, we begin manufacturer notification that these products did not meet within 5 percent of the ENERGY STAR specifications. This is the way it's broken out by product category.
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Looking at the various different categories or products 16 percent of refrigerators that tested over 5 percent worse than the ENERGY STAR annual energy use specification.
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4 percent of the residential clothes washers – excuse me. On this one 4 percent of the clothes washers have not met the energy criteria of the specification modified energy factor. 18 percent have not met the water factor. So we've notified the manufacturers in both cases, refrigerators and residential clothes washers or this and we're working with them to conduct Stage II testing.
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Room AC, 29 percent have tested worse than ENERGY STAR.
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But based on the test results that we've had today we're projecting around 44 of the 267 units will require Stage II testing. As you see how this breakout is room AC seems to be the one product category that has the highest percentage of product that will require additional testing. Again, the Stage II testing will be we'll be testing – we'll be buying three to seven more units of that product and testing them in the laboratory. So I've been asked, "What does that really mean?"
Well what we're doing for the Stage II testing is that we're doing the test and we're taking the results on the – the results of Stage II testing will be determined using the steps outlined in Appendix B to Subpart F of 10, CFR part 430 and what we'll be doing and this is basically the enforcement regulations for the standards program on machines what we'll doing is that for the ENERGY STAR Program we'll be substituting the ENERGY STAR requirement for the energy performance standard and instead of using the minimum standard we'll be substituting what the ENERGY STAR criteria are and we'll be using eight at the maximum number of units that can be tested instead of 20, 20 being for the enforcement actions on the minimum efficiency standards themselves. So we'll be using the calculation procedure outlined in the Code of Federal Regulations to calculate the results for Stage II testing to make our determination. Again, once we determine that a product does not meet ENERGY STAR Program requirements we then refer that result to the Environment Protection Agency for potential enforcement action.
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What have we learned –
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- from the pilot program itself? We've learned that we would really like to shorten the selection process of selecting the units and buying the units. Small batch testing can lead to shorter procurement selection time. We're finding we're having problems actually purchasing the products. So we're trying to find ways of shortening that process to obtain the units in the – again, the National Energy Technology Laboratory goes and purchases the product and we're working with them to find a way of shortening the procurement selection time. What we want to do for future selection of products is that we're looking to test the newer products that come out in the marketplace. Many products have been in the marketplace for quite awhile but there are new products being offered for sale every year. New cycle of appliances are out on the marketplace. So we're looking to test the newest products. We're also looking at high volume products to get a more representative picture of the marketplace itself.
I mentioned that we're running a laboratory accreditation program that we're developing to enhance test lab quality control and this will be part of our future selection of laboratories as we go on over the years. Our test reports, our contractors have developed a test report template for standardization of the test results from the various laboratories and we're continually working on that it – on the template itself to make it easier and more comprehensive for the laboratory to report the test result and more comprehensive for our reviewers and the Department to review the test reports themselves. So we're working on that. I would imagine that for the next enhanced program we may have a new test report template going out to the laboratories.
What we have found during the Pilot Verification Test is that there are some quirks in the federal test procedure that need a little tweaking. There are some methodologies and processes and test procedures themselves that needed to be worked on and we have developed testing guidelines that we provided to the laboratories themselves to help them and standardize the test and to help them conduct a test in our interpretation more properly. So we're working on that and we have found that the back and forth of laboratories, the back and forth with the Department and the contractors have been able to develop these new guidelines. So that's something that's ongoing also as we proceed on.
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So I'd like to remind you to please submit your questions to the question and answer link at the top of the bar on your screen and I will answer as many questions as possible after the polling, after the next set of polling questions go on. So with that I'd like to turn it back to Anthoney.
Anthoney Perkins:
Thank you Rich. Okay, as we said before –
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- we've got two more polling questions that we want to go ahead and go through before we get to the Q and A session with Rich, our speaker. So the first question should be up now. It's asking you what you were hoping to learn from today's webinar. So you have a few options there. So if you take a few moments and choose what best fits your situation. We still have votes coming in so I'll give you a few more moments. Okay, if you'd go ahead and vote now we're going to go ahead and close this out in just a second and get onto the next question we have.
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Okay, based on your expectations how satisfied were you with today's webinar? Give you another moment of so. Okay, we're going to go ahead and close out this question.
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As we mentioned we're going to go ahead and do some questions and answers. As we instructed there is a box at the top of the screen that you will go ahead and click on the Q and A link and then touch your question and click the "Ask" button. We've collected questions. Those have been given to Rich. So he's going to take a few moments and I'll answer as many as time allows. So Rich, are you ready to start?
Rich Karney:
Ready to roll.
Anthoney Perkins:
Okay, great.
Rich Karney:
Thank you Anthoney. I hope that everybody hit the red and blue buttons up there on the satisfaction chart otherwise I'm coming after your products. No, that's not – all right, some of the questions that came in. "Why is this program not covering IT service, data storage and EPS systems? They are used in buildings. I suggest these products be added to the testing program." What we started out by doing in the Pilot Verification Program is looking at DOE covered products. That's where you when mainly after appliances because of that, because there are federal test procedures that are out there.
The laboratories that we selected are experienced in testing to the federal test procedures. So that's why we selected the products that we did and we also selected the products that we did because of their popularity with the various state rebate programs. Those are the appliances that were being covered by the SEEARP program and we decided to hit them because the Pilot Program was set up to help support – the testing program was set up to help the rebate program. In the future I anticipate we might be expanding into IT equipment. I know the Environmental Protection Agency will be doing testing themselves also of various ENERGY STAR products and I believe they will be looking at IT equipment.
Question asked, "What type of enforcement does EPA perform for appliances that fail to meet the standards?" What EPA will be doing is basically looking at the products and basically delisting the products, disqualifying the products from the ENERGY STAR Qualified Product List. That's the type of "enforcement" as this question came in.
Another question that came in, "Will auditors at the respective or accredited labs be available to stakeholders?" I don't believe the audits themselves will be available to stakeholders but what we'll be doing is at the DOE accreditation program we'll be accrediting the laboratories to conduct the federal test procedures themselves. So that assurance will be provided to stake holders.
Now EPA is also setting up their own testing and verification program and they're also setting up their own laboratory accreditation program. Why are they doing that? Is this in conflict with what we're doing? No, they're in conflict what we're doing. They'll be accrediting the laboratories themselves. We'll be accrediting to specific test procedures. Also EPA's testing program is working with third party contracting bodies. In other words they are looking at third party entities to help manage the testing of the products.
So they'll be looking at, for instance, manufacturer associations, the American Home Appliance Manufacturing – the Association of Home Appliance Manufacturers, AHAM. I'll get it right. It's easy to say the acronym. They have set up a verification program themselves and EPA will be using their program to help in testing products and verifying that products to meet the ENERGY STAR criteria themselves. So that EPA has working through third party entities to also conduct testing.
Question comes in, "Is your testing then just focused on energy usage or are there other – any quality components to your testing?" Right now we're just testing to the Federal Energy Test Procedure which just focused on energy. There have – now we have a number of rule makings going out right now on changing the federal test procedures themselves. There's been discussion about adding performance criteria to the test procedure. Right now the Department is basically only mandated to or authorized to conduct energy efficiency testing. So we will not be adding performance at this point however, there has been a lot of discussions from the various manufacturer association and through some of the – and a few of the stakeholders looking at performance factors but right now we are not looking at that.
"Is product availability an issue with the high consumer demand created through the energy efficiency state rebate program?" No, but at the same time – I say no but also at the same time there was some time delay in purchasing products. I can't say it was because of the rebate program but there was some instances where we could not get products in as timely a manner as I would have preferred.
"How does the minimum energy performance for ENERGY STAR determined? Who comes up with those criteria?" Well many of the [audio skips] being tested through the DOE Pilot Program those criteria was determined by the Department of Energy. We've set up criteria for virtually all the products that are being tested.
A number of years ago some of the products, some of the product categories we have various phases where the criteria for the ENERGY STAR Program automatically become effective as a function of time. For instance, clothes washers the criteria will be changing January 1st, 2011. Dishwashers I believe just changed this past summer or this past – a couple weeks ago actually I believe it changed. But right now EPA is managing the ENERGY STAR Program requirement development and they are looking at the existing program requirements and part of the agreement that we have with EPA is that we would be providing some technical assistance for their product criteria development and they right now are looking at the revising if necessary of the various criteria.
"You mentioned that you have to develop several different testing standards for each appliance type. Can you discuss one example and how the labs or Department arrived at that determination?" We're not developing – we haven't developed different testing standards for each appliance type. What we're looking at is seeing if the test procedures need to be revised or updated or created if there are no test procedures for the products themselves. So that's what we're looking at right now. We look at all the ENERGY STAR products, 1 through 60 or 61, whatever they are just seeing what test procedures exist for those products themselves.
For the ones that are covered by DOE Federal Test Procedures we already have a schedule laid out on when the test procedure has to be changed and that's available on the DOE Appliance Standard Website. It lays out the schedule of the – not only the test procedures that need to be – that are looking to be updated or the schedules to be examined to be updated but also the federal standards themselves for the various products that are out there that are scheduled to be updated but right now for this program, the Test Procedure Development Program we are again, looking at the ENERGY STAR products themselves, where the test procedures need to be updated.
Question is – comes in, "At what stage in the verification process would a failed unit be delisted from the ENERGY STAR list?" Again, that determination is being made by the Environmental Protection Agency and that would be key by us basically notifying EPA that a product did not meet the ENERGY STAR requirements after Stage II testing assuming that the manufacturer has requested a Stage II testing to occur. There have been instances where the manufacturer decided not to request Stage II testing.
"Will the public know who passed and who failed? Also will manufacturers be made aware of a past test of their models?" The public will not know who "passed". I don't consider this passing. It's basically meeting the requirements or not. Eventually they will know who failed as the Environmental Protection Agency disqualifies products.
"Will manufacturers be made aware of past tests of their models?" We have not been notifying manufacturers of their products "passing" the test for similar reasons that we did with the CFLs because there were CFL manufacturers who were notified that – or learned through various utilities who sponsored the program learned that their product did pass the PEARL or the CFL testing and they used that as an advertising bonus to advertise their product. So we will not again – we do not want to create unfair market advantage for products. So we will not be notifying others of who has passed the test.
"Just to clarify, the 5 percent is 5 percent less than ENERGY STAR requirements?" That's correct. It's performing worse than ENERGY STAR. So in other words using more energy, 5 percent more energy than what's in their ENERGY STAR Program requirements. Some more questions that came in from today Webinar.
"Is direct dialogue allowed between manufacturers and test facilities?" No, we are not really allowing manufacturers and – to discuss these tests with the labs themselves. We provide the test reports of the lab to the manufacturer that the laboratories provide. In those test reports not only do we have the energy test results we also have pictures of the laboratory set ups. We have numerous pictures of how the machines are being wired, how they're being put into the environmental chambers if the product requires the environmental chamber to be used for the test themselves. So we're not allowing the manufacturers to discuss the specific tests with the laboratories.
Another question comes in. "If a model performs well below ENERGY STAR levels will you notify the states or the utilities so these are not eligible for the efficiency rebates?" We will notify them as soon as the Stage II testing is complete.
"How are the standards developed now? May have missed it if it's consensus based with manufacturers." The ENERGY STAR Program requirements are developed by when a – developed by the Department and now being developed by EPA. They work hand in hand with the manufacturers to develop the ENERGY STAR Program requirements. The Department of Energy and minimum energy efficiency standards are again, worked in a consensus based process with the manufacturers and that's a different process. It's a more formal process than the ENERGY STAR criteria themselves. But again, both the minimum energy efficiency standards and the ENERGY STAR Program requirements all worked on in conjunction with manufacturers and other stakeholders who might be interested in the products themselves both the standards and the ENERGY STAR requirements.
Get a question, "Why are you starting a lab accreditation program when so many already exist. Why not just recognize the competent ones?" We do. We use the accreditation bodies that are – that exist in the United States, that exist throughout the world but we're looking to start an accreditation program where we are crediting the laboratories to perform the federal test procedures themselves. The accreditation bodies accredit the laboratories to conduct tests, to set up quality assurance and quality control processes by set up through the accreditation bodies and they go to the laboratories and ensure that the testing facilities do indeed have QA/QC and they are able to conduct tests. We are looking to have the laboratories accredited to do the actual federal test procedures themselves.
"Is there any consideration of energy use during transportation from factory to retail locations in the ENERGY STAR appliances?" Not at this time. There have been calls from Congress recently and to look at the lifecycle energy use of the products themselves from cradle to grave which also includes transportation from factory to retail location. At this point I do not believe the ENERGY STAR requirements will be looking at this however, there have been calls from Congress, there have been calls from various stakeholders to do take a look at this. That's something that the Environmental Protection Agency is thinking about. I know that they have been outlining some potential lifecycle cost study for products. I know, for instance, one of the products that we're not testing in the program, windows, has certainly been discussed in depth about doing lifecycle cost studies on the cradle to grave energy use of windows and that is something that the EPA might be looking at more hard than some of the other products.
"When will the list be updated after testing is complete?" I assume we're talking about the qualified product list. It'll be updated as soon as – the only way it'll be updated if a product is taken off the qualified product list and that is done virtually immediately after a product is deemed to be disqualified from the program.
"Is there already an online application process for labs seeking accreditation?" No. Eventually we will be working with the laboratories. We will be working with accreditation bodies themselves to determine how to set up an application process after this. We also are looking to expand a number of laboratories that we have that we're using in the Verification Program. I will be working with the National Energy Technology Laboratory and our contractors to begin when we expand the program next fiscal year to begin seeing if we can indeed add laboratories to the program itself.
Question is, "What type of ducted air conditioning equipment are you currently testing?" None right now. We're just doing room AC. Eventually when we do get into doing furnaces and central AC we'll be looking at expanding into those products and then that will be the type of ducted AC equipment I believe that is being referred to in this question.
Got a question, "How does this program compare to industry certification programs such as the new AHAM Refrigeration Program?" We hope to be working hand in hand with AHAM on this. I know we – the AHAM Refrigeration Certification Program has been recognized by EPA as an acceptable program and we will be working hand in hand with AHAM and EPA on that. That's all the questions I've received to date.
Anthoney Perkins:
Okay, great Rich. Thank you. We'd like to thank all of our speakers today for their time –
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Operator:
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