The U.S. Environmental Protection Agency relies on a systematic process for developing ENERGY STAR specifications that prioritizes transparency, inclusiveness, and consistency. Decisions regarding ENERGY STAR specifications are made by EPA with the benefit of stakeholder input consistent with the ENERGY STAR Strategic Vision and Guiding Principles Document (PDF, 147 KB) such that the ENERGY STAR label identifies products that meet the highest energy conservation standards. The ENERGY STAR program is currently in the process of reviewing its guidelines and procedures and has documented the specification process in a standard operating procedure.
The ENERGY STAR product specifications process (see above) relies on rigorous market, engineering and pollution savings analysis, and involvement from a range of stakeholders. Stakeholders include manufacturers, utilities, the efficiency community, international governmental partners, and more. The goal of this process is to establish ENERGY STAR requirements, consistent with program principles, such that products that meet them reduce greenhouse gas emissions and save consumers money without a sacrifice in performance. These specifications are the heart of the ENERGY STAR program’s work to direct consumers to more efficient products in partnership with retailers and utility efficiency program managers.
There are certain elements characteristic of any ENERGY STAR specification process: Initial research and analysis, followed by test procedure development or validation, analysis of energy use data, and then development and vetting of draft specifications. EPA invites stakeholder comment on each draft. Comment periods for draft proposals are at least 4 weeks for written comments, with a 2-week comment period for a final draft specification. EPA responds to these comments in note boxes in the subsequent draft or in a companion comment response matrix and posts the original comments along with the Agency’s responses on the ENERGY STAR website. Additionally, EPA frequently hosts stakeholder meetings or conference calls/webinars for further discussion of proposals throughout the process.
The number of drafts required is determined by the complexity of the specification and the level of change being proposed, in the case of revisions. An EPA specification development process ranges from a single draft plus final draft to, in some instances, four drafts plus a final draft. The driver for these drafts is ensuring the specification is sound and stakeholders have had ample opportunity to engage with EPA prior to the Agency making a final decision on the requirements.
For new products or significant changes in approach to existing product specifications, EPA sometimes begins with a framework document. This document allows EPA to get early stakeholder input prior to formulating a formal proposal. The framework presents the Agency’s preliminary thoughts about approach, scope, and definitions and typically seeks stakeholder feedback on specific questions associated with each of these topics and others key to the development of an effective specification. In addition, the Agency sometimes finds it helpful to seek formal input on a specific topic or limited set of topics between draft proposals. This is typically accomplished through broad distribution of a stakeholder letter with a specified comment period.
Test Procedure Development or Validation
Core to each ENERGY STAR specification is a test method that allows for fair, repeatable testing of products seeking ENERGY STAR certification. In the case of products that are subject to federal minimum efficiency standards, EPA references the Federal test method. For products not subject to federal minimum efficiency standards, the U.S. Department of Energy, lead for ENERGY STAR test methods, validates industry consensus based standards or drafts a new product specific test procedure- in each scenario working through the ENERGY STAR stakeholder process to do so.
In accordance with program principles and as resources allow, EPA develops new ENERGY STAR specifications to expand the program to new products.
ENERGY STAR specifications are then revised periodically to ensure relevancy under current market conditions. EPA strives to make certain that specifications differentiate the most efficient products.