March 01, 2011
You have to give credit to Energy Star. It sure stays busy. Even while the debate rages on over its new and costly third-party testing requirements (or at least third-party witnessed or supervised), it continues the daily business of working on new standards and revising existing ones.
But busy is one thing; hurried is another. And Energy Star appears to be in a hurry to finalize its new dishwasher standard.
Energy Star held a Stakeholder Meeting Feb. 10 at the Orlando Convention Center before The NAFEM Show to discuss its Draft 1 proposal. Present in the room were a who’s who of major warewasher makers, NAFEM officials, test-lab experts and so on. A lot of technical expertise was on-hand. And it was evident in the plentiful feedback.
Input was so plentiful, in fact, that it’s hard to imagine all of it being considered within the declared timeline. Energy Star told the group Draft 2 would be completed and posted for comment in late February (meaning roughly two weeks after the stakeholder meeting). Comments would be due to EPA about two weeks after that, mid-March. Final draft by late March, followed by a comment period, and then the spec would be finalized by May 1.
Trouble is, numerous attendees were concerned about one point or another, and several felt the proposal needs significant work, maybe more than the time would allow.
Among the hurdles: In the big picture, what do you really want to measure? Both the existing and proposed standards measure energy at idle and indirectly measure operating energy by measuring gals./rack. It’s a useful approach. It meshes with NSF test measurements, and it’s a methodology that tracks with the existing standard.
But some stakeholders note those data can be gamed and wonder whether gals./rack is the point anyway. And those with a longer-range view point out that a “total measured energy” approach would be more comprehensive and more to the point. And since that approach is scheduled for the future anyway, why bother with this interim effort?
Then there are the proposed new specs themselves. They really clamp down on high-temp idle energy while tending to leave low-temp idle rates where they are. Water consumption for undercounters and door types gets squeezed too, while conveyor levels remain unchanged.
Most significantly, perhaps, several dishwasher makers say they’re already at the technological limit meeting the existing warewasher standard. They say they can meet NSF standards OR the proposed new Energy Star standard. Not both. That’s a real serious quandary because sanitation will trump energy every single time. So if manufacturers have to choose, which way will they go?
And this real doozie came up too: Should Energy Star mandate certain prescriptives? Should it require, for example, deactivation of final rinse when dishes are not traveling through the machine? Several such techniques were suggested. They were effective ideas, and will probably be implemented by the makers anyway. But should Energy Star go down that path? Should it dictate <i>how<i/> a manufacturer makes its numbers?
No. For numerous reasons. Why have government commoditize the technologies and erode differentiation? Why not just set the energy levels and let manufacturers decide how best to meet them?
For more info, check out this Energy Star web address.
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