Open Letter to Steven Chu, Obama's Choice to Head DOE.

Forwarded to transition team 10/12/08

SUGGESTED IMPROVEMENTS TO
ENERGY STAR, DOE COMPLIANCE and REGULATION OF MAJOR APPLIANCES

BY ALEX CHEIMETS
Publisher of www.ApplianceAdvisor.com
December 10, 2008
 
SUMMARY:
When first introduced Energy Star may have been a reasonable and simple system to raise the issue of appliance efficiency among consumers. It is no longer up to the challenge of urgent energy use reduction and the goals of energy independence. Energy Star Certification and DOE efficiency requirements fail to create an environment where energy efficiency is a guiding principle in innovation, manufacturing, promotion, and purchasing of major appliances. In many ways, these programs work in reverse by promoting the sale of less efficient appliances.

  • Independent Testing
Problem: Manufacturer self-testing of appliances results in a lack of transparency, gaming of the tests, and falsified numbers
Action: Move to independent energy testing. This is most simply accomplished by adding energy testing to the responsibilities of UL, ETL, and CSA where all major appliances are already tested for safety.

  • Certifications vs Ratings
Problem: A single certification label fails to create incentives to manufacturers to design; or a signal to consumers to buy; more efficient appliances
Action 1: Add an efficiency rating (A, B, C, D, E) system so consumers can differentiate energy usage across all sizes and configurations as done in Europe.
Action 2: Rate the performance of appliances (A, B, C, D, E) to communicate to the market that energy efficiency was not gained at the expense of the function and performance of the appliance.

  • Loopholes
Problem: Loopholes are rife, benefiting a single company or created through a poor regulatory process.
Action: Loopholes are free standing problems easily solved. Root them out and kill them.

  • Competing Rating System
Problem: Manufacturers make efficiency reducing decisions to improve their “Consumer Reports” rating.
Action: Partner with Consumer Reports and similar institutions with the goal of adapting or adding to their testing to increase the relative importance of energy efficiency.

  • Communication
Problem: Misleading, incoherent, and incorrect data released to the public make it impossible for a consumer to understand costs, options, and to make an informed buying decision.
Action: Revamp communication strategy

  • Brain Storm
Problem: So much in-the-box thinking
Action: Get out of the box

 

BODY:
1)         Independent Testing:
                             i.                All energy testing is done by the manufacturer, and there have been several claims of falsified results.  A preferred system would have these appliances independently tested. All major appliances are agency tested for electrical safety by UL, ETL, and CSA BEFORE they are sold in the United States or Canada. These independent agencies are in the best position to do energy testing while adding the least cost and hardship to manufacturers.
                            ii.                Energy Testing should be tied to Performance Testing. Yes….terrible and difficult and complicated and subjective, but possible. The consumer should not buy the most efficient appliance if in the end it doesn’t work (like all cheap dishwashers). The consumer should buy the most efficient appliance which meets that consumer’s performance requirement.
                          iii.                Manufacturer test data provided to DOE is not required to be strictly reflect
ive of the manufacturer’s actual test results. This is true. As long as the actual test results are better than DOE minimums, the reported data can be anything between the DOE minimum and the actual test results. Said another way, manufacturers can dumb down their test numbers as long as they are above DOE minimums. There may be some competitive reason for this, but this option is absurd. The numbers must be accurate.
2)         Certification
                             i.                Should appliances be “certified”, or should they be “rated” as they are in Europe (A, B, C, D), or a combination of both, or some other? Big difference. We have serious complaints about the entire concept of “Certification” and the disincentives it creates for the manufacturers to build the most efficient appliances and the consumers to buy the most efficient appliances. Should a 48” Side by Side with ice and water dispenser really have the same Energy Star certification as a 14 ft3 top mounted manual defrost using 1/3 the power?
                            ii.                Too many appliances are Energy Star certified. We already have DOE minimum numbers, such that any product not meeting DOE requirements cannot be produced. Energy Star is now a label given to the majority of products, between 50% and 90%. For consumers who are interested in making the “greenest” appliance choices, there is little information to assist in choosing between certified appliances. For manufacturers interested and willing to manufacture the most efficient appliances this program does not assist in differentiating their products from the gaggle of “certified products”.
3)         Loop Holes
Loop holes should be eliminated. They create a corrupting influence on manufacturers. Here are a few which come to mind.
                             i.                Refrigerators: Most refrigerators came in one big box, but not all. Some are delivered to your home in two boxes. If the compressor and the insulated fridge box come to the home in two different boxes, they do not need to adhere to DOE regulations.  Really. (Northland refrigerators)
                            ii.                Refrigerators: DOE testing of refrigerators with ice and water dispensers is done with these features shut off. DOE yellow cards for refrigerators equipped with ice and water dispensers will therefore not show energy use which matches actual use, and will look nearly as efficient as units without ice and water dispensers.
                          iii.                Dishwashers: Energy testing does not take into account cleaning performance.
                          iv.                Dishwashers: Size Loopholes. Dishwashers are compared by width, not height. Energy Star rated the Fisher and Paykel Dishdrawer as the most efficient dishwasher in America, though it was 1/2 the height of the units it was being compared to. This problem was fixed at the prodding of this website. http://applianceadvisor.com/appliancereport/fisherpaykel.htm#fisherpaykeldishdrawer
                           v.                Elimination of the possibility to sell true “commercial” appliances for residential installation unless approved for residential installs. Commercial appliances (designed for restaurants etc) do not meet DOE energy requirements, but several manufacturers continue to cater to the super premium segment of the market. This is not a significant chunk of the market, but it annoys me.
                          vi.         &nb
sp;     
Refrigerators: Refrigerators have shipped with several electrical features disconnected. Features related to managing door sweating, condensation, and water build-up. They passed DOE based on these features being disconnected and therefore used less power. When problems were reported on a case by case, OR when the unit was shipped into territories with high humidity, the features were re-connected increasing their power usage over the DOE minimums. There seems to be some question as to whether the electrical draw of the “fixes” should have been included in the DOE testing or not. This is now the subject of a class action. http://applianceadvisor.com/content/viking-class-action-lawsuit
                        vii.                Refrigerators: Highly efficient manual defrost refrigerators were not included in the Energy Star program until recently. They could not mark their products as Energy Star certified. I believe that this problem was recently solved.
                        viii.                UPDATED MAY 2009:  Too many refrigerator catagories.  The MOST efficient Energy Star side by side refrigerator is less efficient than the WORST top-mount or bottom-mount refrigator of the same volume.  Top or bottom mount refrigerators, which just under the DOE maximum energy usage requirements, are more efficient than the most efficient side by side available.  Why do we have different categories for side by side, top-mount, bottom-mount, AND ice and water dispensor?  We have different categories to protect manufacturers making inefficient side by sides?  Solution, consolidate all categories into one.  Let top, bottoms and side by sides compete on a level playing field.
4)         Influence of Consumer Reports Magazine
Manufacturers adapt the design of their appliances to improve their Consumer Reports ratings. For example, Bosch’s “Eco” buttons on dishwashers and washers which extend the wash time and reduce the energy usage, but need to be opted-in to benefit from. The default setting of the Bosch units is faster and less efficient because Consumer Reports stresses speed. A discussion should be opened with Consumer Reports to attempt to increase the importance of energy efficiency in their testing.
5)         Communications: DOE Yellow Card
                             i.                Energy Reported on the “Yellow Card” does NOT represent the appliance as normally used in many appliance segments as discussed earlier. (ex: ice making fridges tested with ice maker off)
                            ii.                The Yellow Card reports ownership cost based on AVERAGE ¢/kW for all Americans. The range of electricity costs in the United States is so wide (6¢ to 18¢) that the information is worse than useless. Northeast and west coast electricity costs are nearly double the national average. To add insult to injury, the average costs used are quite dated, usually 2005, 2003 or earlier. It is not common to find current average costs on product on a dealer floor. Consumers understand “cost” better than other units such as “Annual Kw usage”, but it needs to be presented in a better way. It would be helpful to remind the consumer that the electricity costs in the future are likely to rise.
                          iii.                The Yellow Card shows power usage of “this” appliance within a range of MOST and LEAST energy efficient identically sized and identically outfitted appliances.  The comparison is not expansive enough to drive efficient appliance purchasing decisions.    The Yellow Card does not include appliances in these comparisons WITHOUT the energy using features, nor more efficient appliances of the same size but more efficiently configured. 
(Example: A 36” Side by Side with ice and water dispenser should have a Yellow Card comparing it to identical appliances BUT ALSO to Side by Sides without ice and water dispensers and ALSO the most efficient refrigerators of the same size, Top or Bottom Mounts without ice and water dispenser. It should also recommend that the consumer consider smaller appliances.
6)         Communications: Consumer Outreach and Release of Data
The communication strategy needs to be redesigned to provide dealers and consumers with information required to make efficient appliance decisions. The system is now too protective of manufacturers.
-Recommend the creation of a user friendly database of appliance models an
d efficiency. None exists. The best database for appliance efficiency is managed by the California Dept of Energy at: http://www.energy.ca.gov/appliances/database/, but this is not designed for consumers.  There should be a web-based database allowing consumers to compare ALL approved appliances, features, sizes and energy usages. If this is beyond the scope of the DOE’s own websites, we invite the DOE to locate such a service at www.ApplianceAdvisor.com.
 
Other Ideas of Various Kinds
  • Auto defrost refrigerators should have an over-ride option to shut down the feature.
  • Stand-by power use. Should be regulated.
  • Power use information: If consumers understood the real-time power costs of the decisions they make when setting the dishwasher cycle or laundry temperature or the frequency of fridge access, the consumer might be able to adjust his behavior to improve efficiency. This feature could be required on all less efficient, higher priced models.
For example:
1.           Dishwashers, washers, dryers which display expected power use or power cost based on cycle or time of use metering. 
2.           Refrigerators which record power use against time. Not sure how this would fit into a regulatory environment.
3.           A standard for the collection of real time power usage which can be transmitted to the homeowners PC. Would be worth research into how behavior changes when power use information is available.
  • Cooktops: Usually marketed by BTU or KW. These units only indicate the energy potential, not the energy efficiency, or the success of that energy in raising the temperature of the food. Should rate the efficiency of electric and gas cooktop burners in heating a standard load (like a gallon of water). For an example of this rating, see the results of the ApplianceAdvisor.com reader cooktop testing survey:. http://applianceadvisor.com/content/peoples-cooktop-test
  • Ventilation:   Big kitchen ventilators (600CFM – 1500CFM) flush heated and air-conditioned air out of the house, as well as risking the life of the consumer by creating a negative interior pressure which can suck in carbon-monoxide and other furnace combustion byproducts which should be going up the chimney. Several Canadian provinces and US communities require “Make-up” air for any hood more powerful than 170 CFM (cubic feet/minute) to eliminate the threat of CO poisoning. This is also a financial disincentive for high power ranges, and an important change to protect the public health.
  • Cooking: Pro-style Viking type gas appliances feature 15,000 BTU burners or larger for ALL the top burners. These large burners are terribly inefficient in heating up pots of a small or medium size. The burners are so large that most of the heat misses the smaller pots entirely. Why then are ALL the burner of this size? Marketing and advertising. Consider requiring that all cooktops of greater than 4 burners have at least 1 burner sized 5000 BTU, and 1 burner sized 10,000 BTU.
  • Ventilation: Heat Recover Ventilators which salvage the heat from vented air to warm up incoming replacement air are banned for cooking range hoods and dryer vents. This problem is related to the proximity of the combustion gasses to the fresh make-up air. Should this regulation be reconsidered so that this waste heat can be recovered?
  • Indoor BBQ options: Consider banning indoor BBQ. It drives high power ventilation, and therefore excessive waste in heating and cooling, as well as creating indoor air pollution issues.
  • Dishwasher: Minimum performance requirements. The majority of Americans rinse their dishes before placing in the dishwasher. They were trained to do that by poorly performing dishwashers. This tendency to pre-wash or pre-rinse, often times in warm or hot water can be more wasteful than the dishwashing itself. Pre-washing of dishes is a HUGE issue which needs thinking by all players.
  • Dryers: Require humidity sensors so that they shut down when dry.
  • Washers: Cold water washing should be adequate for the majority of washing. How do we educate the consumer.
  • Global Competition:   There’s huge room for improvement in the performance of Fridges, Freezers, Washers and Dryers. Some tinkerers out there claim incredibly low energy usage. Manufacturers need a kick in the pants, because they are all still stuck in the box. They can’t get out of the box. We’ve spoken to inventors with rules changing ideas that sound theoretically doable. Let’s suggest a $5 million competition for the most efficient appliances which reach a set of pre-determined performance standards and get the nation’s tinkerers tinkering. Public money would be easier…..but we could put this together with private funding, if it was backed by a political support.
  • NSF Certification: National Sanitation Foundation certifies dishwashers and washers based on the appliance’s ability to sterilize the loads with heat over a period of time. It is my belief that this feature succeeds in wasting energy in reaching these high temperatures, but provides no additional protection to the consumer. Are the advertising claims made using NSF false, or are these features with a vanishingly small benefit?  Probably both.
  • Truth in Advertising: If their mouths are moving you know that they’re lying……….well it’s not just in politics.  Whatever procedure exists to challenge claims, it does not seem to work very well.
  • Dealer floor salesman reward “Spiff” system: The salesman controls the sale and can redirect the consumer based on spiffs. Manufacturers do this everyday. DOE should consider entering this system with the support of the nation’s utilities, states, and manufacturers.
  • Ovens: Consider requiring that all ovens improve their insulation to improve their efficiency

 

3 Responses to Open Letter to Steven Chu, Obama's Choice to Head DOE.

  1. Appliance Stallion says:

    Excellent prose. Now some action from those that only talk a good game. Get off the educational boards that only jibber jabber and fix these problems and challenges Alex so keenly speaks about. My only concern is like most other industries of late. The thought is we have forgotten how to sell because it was so easy, have we forgotten how to engineer products also ? Because almost anything sold. Companies need to look inward. The reason for such good sales had less to do with the companies being "great" than it did with the need for products.Now is the time to step up. 

  2. Amster says:

    Aren’t we forgetting the whole point here.  Yes, Energy Star is behind the times.  Yes, manufacturers are not so honest with testing results.  The point is that consumers want bigger and better.  Isn’t that the reason that we’re all in this mess???  Bigger and better can’t be as energy efficient as smaller and smarter.  That’s why companies like Miele, Gaggenau, AEG, Liebherr…oh hell why not just say everything European and Asian make smaller appliances that exceed Energy Star requirements and are actually energy efficient.

    Honestly, the customer buying a 60" side-by-side refrigerator/freezer with the 60 dual-fuel range is not buying it with energy efficiency as the priority, they’re buying it to make a social statement.  The easiest thing is for manufacturers to make the "Big Toys" and then make the "Smart Toys".  Give consumers the choice and let’s see which sells the most.

    • Appliance Stallion says:

      Well then …whatever the consumer wants just make it even if it is marginal ? I think not. America at one point made things the right way. My original comment about engineers sitting on educational boards at universities,agency boards,technical boards. These boards are set up to talk and no tangible results about what they have done is ever measured or shows up in performance improvements in most products. Another words no accountability. Sounds like Wall Street huh ? It is a way to network and waste valuable development time in the name of career advancement. Then there is the owners/CEO’s who want bigger and better and they do not understand the cost to get there , shortcut things and say they are the best !!! Bull puckey. We as a nation have lost our common sense if the truth be told. We have the talent , we need the leadership that has lost it’s way.

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