Top 5 Percent Alternative Not Suitable for Top-Tier Energy Program, Says EPA

The EPA agrees that recognizing the top 5 percent of product models for the Top-Tier energy efficiency program would give device makers “greater predictability,” it said in response to stakeholder comments. But it chose to adopt a model that would ensure that the “number of products earning the designation would be few and really exceptional” because the aim of the top-tier program is to “identify and advance highly efficient products,” it said. The EPA released standards earlier this month for top-tier TVs, clothes washers, heating and cooling equipment and refrigerators and freezers.

The performance levels for the top-tier products were set to “reflect only the latest in technological advancements and to include only a very limited set of qualifying models,” the agency said. The EPA will consider product specific factors such as climate and intelligent controls for heating and cooling products as it finalizes criteria for the program, it said. The agency defended the use of Energy Star resources for the top-tier program, saying that while only a “small percentage of Energy Star resources are dedicated to the top tier effort, the potential advancement of highly efficient products into the mainstream marketplace creates the opportunity for high returns."

The agency also sought to put to rest stakeholder concerns about the top-tier program diluting Energy Star. To maintain the “credibility and value” of the Energy Star brand, the EPA worked with several groups, including global branding consultancy Interbrand, to “build and strengthen” Energy Star brand identity, it said. EPA did consumer testing before designing the new program, it said. “Design structure options that harmed the Energy Star brand or were confusing to consumers were eliminated.” The top-tier eligibility criteria will be “revisited” when related Energy Star specifications are updated, “which will most likely result in an update to the top tier performance levels as well,” EPA said.