Is ENERGYSTAR broken? No, but DOE sure is.

My colleague, Pierre Bull, blogged last week on the recent negative media attention the ENERGY STAR program has received due to refrigerators that could be more accurately labeled "Energy Hogs." (Consumer Reports and BusinessWeek)

As Pierre said, this particular failure doesn't mean you should stop looking for the ENERGY STAR label; it is still a great program and has helped to bring energy efficiency to the forefront of everyone's purchasing decisions.

The real problem that these reports uncovered shouldn't be traced back to the ENERGY STAR brand or EPA. These failures fall squarely on the shoulders of the Department of Energy and the problems stemming from the most mundane part of my job as an efficiency advocate-the test procedures.

Test procedures!  How exciting!

If your eyes glazed over a bit after reading that, no one could blame you. Mine still do sometimes. But think about it, EPA and DOE run ENERGY STAR and cover a huge number of completely unrelated appliances, each of which has to meet an ambitious level of energy efficiency to be labeled. But how do they decide what that level is? How do they know how to compare different appliances with each other, especially when some of them defy classification? How do they decide what to measure and under what conditions?  How do they even determine how much energy a particular appliance should use?

The answer is...they do the best they can. They try to utilize existing industry procedures, they engage experts in the field, and they conduct their own independent analyses in order to come up with a test procedure that is as accurate as it can be. But things change. Manufacturers ingeniously design new products and redesign old products that provide the consumer with services they didn't even know they needed. And none of us would have it any other way.

Suddenly the old test procedure has big holes and energy leaks out. Everyone knows, if you don't measure it, it doesn't exist. The goals of minimum energy efficiency standards for appliances and voluntary labels like ENERGY STAR are no longer met. The ice makers mentioned in Consumer Reports that use as much energy as the refrigerator are glaring examples. When the original test procedure was written, exempting ice makers was not a big deal. French doors hadn't crossed the ocean and made their debut on MTV cribs yet.

How do we fix it?

The answer is to have regularly updated standards and test procedures that respond to changes in the marketplace to keep this from happening. And this is where we have a problem. ENERGY STAR utilizes the same test procedures determined by DOE for federal standards if a standard exists for that appliance, and these tend to vary in age. EPA often covers the newer appliance categories, and in some cases they are able to va determine the test procedure for the first time (like the consumer electronics program Pierre mentioned). Writing new test procedures is not as complicated as re-writing old ones, where manufacturers have money invested in compliance with the existing structure.

Even considering this inherent disadvantage, DOE is not exactly Usain Bolt. In fact, they missed some congressionally mandated deadlines for updating energy standards by decades, not years.

In 2006, NRDC and others sued DOE, successfully procuring a consent decree that requires DOE to update standards for 22 products.  The Energy Independence and Security Act added more in 2008, and few more were added by petitions from stakeholders. In other words, it is time to get to work.

This is a huge win for energy efficiency. If you wonder how big, just take a look at the recently released study on how successful the efficiency programs have been in California, including the state's aggressive pursuit of new appliance standards.  But these savings won't happen if the standard doesn't regulate the actual energy consumption of the appliance. And if the test procedures don't measure the energy consumption, the standard won't regulate it. Which brings us back to refrigerators.

The solution...coming soon(ish)

The framework for a new refrigerator standard was released last month. The standard won't take effect until 2014 (yes, that's a long time). I attended the hearing and prepared NRDC's comments. A key issue in the rulemaking is the accuracy of the test procedure and the waiver for ice makers. In other rulemakings, DOE has implied that they will have trouble updating test procedures while meeting their new deadlines. Thanks to the media attention, that will probably not happen in this rulemaking, but other appliances will not be so lucky (central air conditioning comes to mind).

There isn't any easy solution to this catch-22. The only acceptable outcome is for DOE to do its job and produce aggressive energy efficiency standards across the board, and this means actually measuring energy consumption with realistic test procedures. Setting a standard that only covers certain functions of an appliance but not others doesn't make sense. Testing appliances in ways that don't reflect how they will actually be used does not make sense.

In order for ENERGY STAR to become a meaningful label again for refrigerators and to avoid the same pitfall in other appliance categories, we need better standards and realistic test procedures. DOE needs to find the motivation to get the right answer, not just get it in on time. The only way we can do that is if groups like Consumer Report keep exposing the problems, if groups like NRDC keep advocating for solutions, and if every consumer responds to programs like ENERGY STAR and supports policies that foster energy efficiency.

If you read this far, I salute you.  As a reward, here is some recycled refrigerator artwork, courtesy of the ENERGY STAR® Recycle My Old Fridge Campaign, by Michael Stebbins.  This was my favorite piece in the contest displayed earlier this year in the National Building Museum.

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