As this edition of FER Dealer Report wings its way into cyberspace, all’s not well at Energy Star. In fact, references to Dr. Frankenstein come to mind. As in “What kind of monster is this?”
Good intentions, road to hell, unintended consequences, all those phrases come to mind, in fact. EPA’s Energy Star program, for foodservice at least, appears to be turning into something other than what it was supposed to be.
Fortunately, dealers may be in an excellent position to help get things back on track.
In the beginning, way back in 2001, Energy Star in foodservice was a program designed to encourage industry to be energy efficient. It was a voluntary program, dependent on self-policing and a large amount of honor, and it was meant to be an inexpensive program without elaborate enforcement expenses.
Now, however, the good doctor’s creation seems to be taking on a life of its own, and the leather restraints are breaking away.
Starting Jan. 1, procedures and requirements for getting a product qualified for Energy Star are changing. You’ve read about many of the particulars before—here, and in FER Fortnightly and in Foodservice Equipment Reports. And you can see all the details on the new testing and verification standards at www.energystar.gov/testingandverification. Also, you can check a Frequently Asked Questions document at www.energystar.gov/ia/partners/downloads/mou/ETV_FAQ.pdf.
Many of the changes were intended mainly to prevent any fraudulent use of the Energy Star label. Fine enough, and no doubt they’ll accomplish that. But at the same time, they’re creating a whole new bureaucratic process and some stupendous testing costs.
The new requirements are so onerous, in fact, that many industry observers wonder how the whole business will play out. Will the additional testing expenses force manufacturers to drop out of Energy Star because the costs cannot be amortized cost-effectively? Will only the bigger players be able to bite the bullet, thus tipping the field against small-business participants?
There are a ton of questions about the revised program. Industry spokespeople have warned Energy Star there are not enough third-party test facilities in the country to keep up with testing needs, for example. Test facilities will have to be certified, by a certifying body, which is a whole new bureaucracy itself. The list of practical issues is lengthy. But the core problem is the expense tied to testing. New models will have to be tested. And then later, “verification” testing will require certified models to be retested periodically to verify they’re still in compliance.
NAFEM has worked hard with many of its members to point out flaws in the new proposal to Energy Star folks. NAFEM and many of its individual manufacturing members have gone to bat offering not just criticisms but alternative plans that would accomplish the goals without the huge expense.
And yet, somehow, this new monster continues to breathe on its own, seemingly oblivious to common sense, let alone economic sense.
So where do dealers come in? As dealers, you have a lot at stake and a lot of purchasing influence: you have end-user traffic; you influence model decisions; you support and sell Energy Star, or you decide not to. And you have a unique third-party perspective on the wrangling. You’re not the customer paying higher prices for Energy Star merchandise, and you’re not the manufacturer paying the fees and hoping to amortize the expenses. You don’t have a vested interest. You’re more of a referee.
All of which means you have a unique ability to influence the Energy Star program. Contact your congressional representation in both houses. Write letters, make phone calls, and repeat. Hound ’em. Hit on the small-business implications. Hit the jobs angle. Tell ’em this industry isn’t selling consumer appliances by the millions, and absorbing the test costs is a real problem in this market, especially in this fragile economy.
It might be worth getting FEDA involved, too, as an additional tactic. But there’s still no substitute for large numbers of businesses sending individual messages to representatives that want to get re-elected.
Jump in now. Don’t wait. Energy Star will not fix itself. You’re going to have to get involved. Intervene.
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