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Attention "Smart Appliance" Manufacturers: DOE Request for Information Merits Your Prompt Attention

August 2011

"Smart Appliance" manufacturers are being given an opportunity to weigh in with the U.S. Department of Energy (DOE) on whether and how it should consider product test procedures and standards.  DOE has the lead in the development of test procedures for both the DOE mandatory efficiency standards program and for the ENERGY STAR program.  The invitation comes via a Request for Information (RFI) published by the DOE in early August.  Comments are requested by September 6.

Background

Appliances are a key element of the federal energy efficiency regime administered by DOE, the U.S. Environmental Protection Agency (EPA) and the Federal Trade Commission (FTC), pursuant to the Energy Policy and Conservation Act.  Much greater attention is now being placed on the extent to which "smart appliances" should be taken into account in the development of federal standards, test procedures and other aspects of the energy efficiency regime, such as the voluntary ENERGY STAR program. 

This focus has been stimulated partly by a petition filed earlier this year by the Association of Home Appliance Manufacturers (AHAM), a number of energy efficiency advocacy organizations and the California Energy Commission.  It asks that the ENERGY STAR program grant a five percent performance level credit to "smart appliances" rated under the ENERGY STAR program.  The petition urges that a smart appliance be defined as an appliance that "has the ability to receive, interpret and act on a signal received from a utility, third-party energy service provider or home energy management device, and automatically adjust its operation depending on both the signal's content and settings from the consumer."  EPA has since indicated that it would work with stakeholders to consider ENERGY STAR product specifications that will address smart grid functionality, and it is considering a five percent smart grid credit for refrigerators.

At about the same time as the petition, Senator Jeff Bingaman (D-NM) introduced a bill (S. 398) calling on the EPA, in cooperation with DOE, to determine whether to update the ENERGY STAR criteria for numerous appliances to incorporate smart grid and demand response features.  That legislation has not been enacted but has kept the focus at DOE on these issues.

Issues in the RFI

A key issue in the RFI is what the definition of a  "smart appliance" should be.  Adopting a definition includes establishing characteristics, such as those related to demand response, energy efficiency and consumer control or preferences.  The RFI asks whether the definition should be uniform or product-specific and whether the same definition should apply for the DOE standards program and for the ENERGY STAR program.

In addition, the RFI asks for input on if and how test procedures should be amended to measure and verify the capability of "smart appliances."  For example, should a portion of the test procedure be an "add on" to the existing procedure's structure in order to qualify a product as "smart," or should that portion of the test procedure be integrated into the test procedure and internalized in the outputted metric on a product-by-product basis?

The RFI also seeks information on how "smart appliances" should be taken into account in the energy standards analysis, including such things as analysis of costs and benefits.

There will be a number of additional steps in the development of federal policy on "smart appliances" in relation to the appliance efficiency program.  Responses to the RFI will play an important role in shaping that policy, and companies with an economic interest in this sector should be taking advantage of this invitation both to express their views on the merits and to establish or improve their credibility with regulators.