U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

ENERGY STAR Program Integrity 

Can Be Enhanced Through 

Expanded Product Testing 

 Report No. 10-P-0040 

 November 30, 2009 
 

 

Report Contributors: Daniel Carroll 

Jerri Dorsey 

 Jill Ferguson

 Jeffrey Harris 

Abbreviations 

DVD Digital Versatile Disc 

EPA U.S. Environmental Protection Agency 

NIST National Institute of Standards and Technology 

OIG Office of Inspector General 

Cover photos:	 ENERGY STAR product categories, from left: monitors, DVD products, 

and printers. (Photos courtesy EPA) 
 

 

 

 

U.S. Environmental Protection Agency 10-P-0040 

November 30, 2009 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

We initiated this evaluation to 

independently test ENERGY 

STAR products to determine 

whether their energy-efficient 

performance complied with the 

ENERGY STAR program’s 

required specifications. 

Background 

The U.S. Environmental 

Protection Agency (EPA) 

established the ENERGY 

STAR Labeling Program as an 

innovative approach to 

environmental protection. 

More than 2,400 manufacturers 

and over 40,000 individual 

product models across 

60 product categories are 

ENERGY STAR qualified. 

In 2007, EPA reported that the 

ENERGY STAR program 

helped Americans save 

180 billion kilowatt-hours, 

about 5 percent of U.S. 

electricity demand, and 

prevented the emission of 

40 million metric tons of 

carbon equivalents of 

greenhouse gases. 

For further information, contact 

our Office of Congressional, 

Public Affairs and Management 

at (202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20091130-10-P-0040.pdf 

ENERGY STAR Program Integrity Can Be 

Enhanced Through Expanded Product Testing 

What We Found 

Almost all of the ENERGY STAR products in our test sample met, and in most 

cases exceeded, the program’s performance standards. However, selected nonENERGY STAR products performed comparably to, and in some cases better 

than, ENERGY STAR products. That level of product performance affects the 

ENERGY STAR label’s image as a trusted national symbol for environmental 

protection through superior energy efficiency. 

In addition, the performance results of ENERGY STAR and non-ENERGY 

STAR products call into question the assumptions used to calculate energy 

savings and greenhouse gas reductions attributed to this program. Without an 

enhanced testing program, including the testing of non-ENERGY STAR 

products, EPA cannot be certain ENERGY STAR products are the more energyefficient and cost-effective choice for consumers. 

What We Recommend 

We recommend that EPA verify estimated energy savings and greenhouse gas 

reduction calculations using a market-based performance-testing program that 

includes testing non-ENERGY STAR products. 

We also recommend that EPA revise the ENERGY STAR Website to include the 

established standard alongside qualifying product performance data and to 

provide a summary listing of the highest performers. 

The Agency disagreed with our conclusions but concurred with both 

recommendations. 
 

 

 Assistant Inspector General, Office of Program Evaluation 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

November 30, 2009 

MEMORANDUM 

SUBJECT: ENERGY STAR Program Integrity Can Be Enhanced Through 

Expanded Product Testing 

Report No. 10-P-0040 

FROM: Wade T. Najjum

TO: Gina McCarthy 

Assistant Administrator for Air and Radiation 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of 

the U.S. Environmental Protection Agency (EPA). This report contains findings that describe the 

problems the OIG has identified and corrective actions the OIG recommends. This report represents 

the opinion of the OIG and does not necessarily represent the final EPA position. Final 

determinations on matters in this report will be made by EPA managers in accordance with 

established audit resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the applicable 

daily full cost billing rates in effect at the time, including the costs of purchasing ENERGY STAR 

and non-ENERGY STAR products and having them analyzed by the National Institute of Standards 

and Technology – is $489,338. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this report 

within 90 calendar days. You should include a corrective actions plan for agreed-upon actions, 

including milestone dates. We have no objections to the further release of this report to the public. 

This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact me at 202-566-0827 or 

najjum.wade@epa.gov, Jeffrey Harris at 202-566-0831 or harris.jeffrey@epa.gov, or Jill Ferguson at 

202-566-2718 or ferguson.jill@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

ENERGY STAR Program Integrity Can Be Enhanced 10-P-0040 

Through Expanded Product Testing 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................ 1 

Purpose ....................................................................................................... 1 

Background ................................................................................................. 1 

 Scope and Methodology ............................................................................. 2 

2 Enhanced ENERGY STAR Testing Needed to Ensure Program Integrity..... 4 

 Product Specification Process..................................................................... 4 

Both ENERGY STAR and non-ENERGY STAR Products Met 

ENERGY STAR Product Performance Varied but Similar to 

Specifications................................................................................... 5 

Non-ENERGY STAR Products........................................................ 5 

ENERGY STAR Benefit Claims May Not Be Valid...................................... 9 

Impact on Consumer Cost Savings............................................................. 9 

Conclusions................................................................................................. 10 

 Recommendations ...................................................................................... 10 

 Agency Comments and OIG Evaluation ..................................................... 10 

Status of Recommendations and Potential Monetary Benefits.............................. 12 

Appendices 

A Agency Comments on Draft Report ................................................................. 13 

B Distribution ......................................................................................................... 15 
 

 

 

10-P-0040 

Chapter 1

Introduction 

Purpose 

The purpose of this review was to test U.S. Environmental Protection Agency 

(EPA) ENERGY STAR-qualified products for compliance with required 

specifications. This independent testing was a check on the validity and 

reliability of manufacturers’ self-certification testing conducted by EPA’s 

ENERGY STAR partners. As the testing evolved and we received initial results 

showing that a number of the ENERGY STAR products tested exceeded the 

standard, we decided to expand our scope and test non-ENERGY STAR products. 

Thus, our initial purpose was expanded to also determine how non-ENERGY 

STAR products performed in comparison with ENERGY STAR products. 

Background 

In 1992, EPA’s Office of Air and Radiation established the ENERGY STAR 

Product Labeling program (ENERGY STAR program) as an innovative approach 

to environmental protection. In 1996, EPA partnered with the U.S. Department of 

Energy to promote the ENERGY STAR label and broaden the range of products 

covered. In the ENERGY STAR 2008 overview of achievements, EPA stated 

that the ENERGY STAR label is recognized by more than 75 percent of the 

American public. According to EPA, the ENERGY STAR label is the trusted 

national symbol for environmental protection through superior energy efficiency. 

EPA also reports that ENERGY STAR has helped individuals save on their 

energy bills by clearly identifying energy-efficient products with superior 

performance in the marketplace. 

ENERGY STAR is the most significant of EPA’s greenhouse gas avoidance 

programs. In 2006 and 2007, the program accounted for over 50 percent of 

EPA’s contribution. EPA reported that in 2007, the ENERGY STAR program 

helped Americans save 180 billion kilowatt-hours, about 5 percent of U.S. 

electricity demand, and prevented the emission of 40 million metric tons of 

carbon equivalents of greenhouse gases. 

The ENERGY STAR program is advertised as a credible, objective source of 

information for Americans wanting to make well-informed decisions on how to 

improve the energy efficiency of their homes and businesses. More than 2,400 

manufacturers and over 40,000 individual product models across 60 product 

categories are ENERGY STAR qualified. EPA does not bestow membership into 

the ENERGY STAR program without a request from the manufacturer. 

Membership is voluntary. Manufacturers are responsible for certifying product 

1 
 

 

 

 

 

10-P-0040 

performance and compliance with ENERGY STAR specifications when they 

apply to use the label. 

In EPA Office of Inspector General (OIG) Report No. 2007-P-00028, ENERGY 

STAR Program Can Strengthen Controls Protecting the Integrity of the Label, 

issued August 1, 2007, we identified the need to improve EPA’s product testing 

verification. Specifically, we found the following: 

•	 Verification testing was conducted on a minimal basis. 

•	 Test selection methods were inconsistently applied. 

•	 Only a limited amount of the program budget was used for verification 

testing. 

•	 The quality assurance plan needed improvement. 

Our report found that testing of ENERGY STAR products did not begin until 

2002, 10 years after the program began. When verification testing began, it was 

only a small component of EPA’s activities. In 2006, the cost of testing 

represented less than 0.5 percent of the total ENERGY STAR budget. In its first 

5 years of verification testing, EPA averaged only two sets of product verification 

tests per year. When our 2007 report was issued, 44,000 qualified product models 

existed within the qualified ENERGY STAR product categories. At the end of 

2006, EPA had only conducted verification testing on 160 product models in 

9 product categories. 

Scope and Methodology 

Between December 2008 and February 2009, we selected 20 different ENERGY 

STAR-qualified products for testing from each of 3 product categories. Products 

were selected and purchased online from the list of qualified products on the 

ENERGY STAR Website1

 and based on availability at major retailers. Products 

selected were chosen to represent those that would be available for purchase by 

the general public. Two identical models of each product category were 

purchased for a total of 40 ENERGY STAR-qualified products per category, 

120 products in all. 

1 http://www.energystar.gov 

2 
 

 

 

 

 

10-P-0040 

The product categories selected and the specification dates were as follows: 

Products Specification Date2

 Digital Versatile Disc (DVD) products3 January 1, 2003 

 Computer monitors January 1, 2006 

 Printers4 April 1, 2007 

In addition to the ENERGY STAR products, we also tested the performance of 

some non-ENERGY STAR products. We purchased 10 non-ENERGY STAR 

products (2 each of 5 models) from each of the above categories for a total of 30 

non-ENERGY STAR products. These products underwent the same testing as 

our sample of ENERGY STAR products, and the results were compared with 

ENERGY STAR specifications. 

We performed our evaluation between April 2008 and September 2009 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the review to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our review objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on 

our objectives. 

We entered into an Interagency Agreement with the National Institute of 

Standards and Technology (NIST) to perform the testing of all the products in our 

sample. NIST tested these products for compliance with ENERGY STAR 

program specifications between December 2008 and June 2009. 

2

 Most recent efficiency standard date listed in the product specification requirements that were used for testing 

purposes. 

3

 DVD products included in our testing were CD players/changers, stereo amplifiers/pre-amplifiers, and stereo 

receivers. 

4

 Forty ENERGY STAR printers were tested; 24 were ink jet and 16 were laser printers. 

3 
 

 

 

10-P-0040 

Chapter 2

Enhanced ENERGY STAR Testing Needed to Ensure 

Program Integrity 

Although almost all of the ENERGY STAR products in our test sample met, and 

in most cases exceeded, the program’s performance standards, many of the nonENERGY STAR products tested comparably to, and in some cases better than, 

the ENERGY STAR products. Comparable performance affects the image of the 

ENERGY STAR label as a trusted national symbol for environmental protection 

through superior energy efficiency. In addition, the results call into question the 

assumptions used to calculate energy savings and greenhouse gas reductions 

attributed to this program. Based on our testing of non-ENERGY STAR 

products, EPA cannot be certain ENERGY STAR products are the more energyefficient and cost-effective choice for consumers. 

Product Specification Process 

EPA follows six key principles when establishing consumer product 

energy-efficiency specifications: 

1. Significant energy savings can be realized on a national basis. 

2. Product performance can be maintained or enhanced with increased 

energy efficiency. 

3. Purchasers will recover their investment in increased energy efficiency

 within a reasonable time. 

4. Energy efficiency can be achieved with several technology options, at 

least one of which is nonproprietary. 

5. Product energy consumption and performance can be measured and 

 verified with testing. 

6. Labeling would effectively differentiate products and be visible for 

purchasers. Typically, the specification is set to recognize the products 

 that rank in the top 25 percent in terms of energy efficiency. 

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10-P-0040 

Both ENERGY STAR and non-ENERGY STAR Products Met 

Specifications 

We tested 120 ENERGY STAR-qualified products and 118, or 98 percent, met, 

and in most cases exceeded, program requirements for compliance. During our 

product testing, we did not find any evidence that the self-certification process 

EPA uses allows for products that do not meet the specifications to enter the 

program. The only products that failed to meet specifications were two printers of 

the same model. Both failed to meet the “Time to Sleep Mode” requirement.5 

The categories tested and positive compliance rates are presented in Table 2-1. 

Table 2-1: ENERGY STAR-qualified Product Compliance Rates 

Product Category Compliance Rate 

DVD products 100% 

Computer monitors 100% 

Printers 95% 

Source: NIST. 

Non-ENERGY STAR Product Results 

We tested 30 non-ENERGY STAR products comparing performance to program 

requirements. A majority of these products were also in compliance with 

ENERGY STAR requirements, as shown in Table 2-2 below. 

Table 2-2: Non-ENERGY STAR Product Compliance Rates 

Product Category Compliance Rate 

DVD products 60% 

Computer monitors 80% 

Printers 40% 

Source: NIST. 

ENERGY STAR Product Performance Varied but Similar to 

Non-ENERGY STAR Products 

Although we expected the ENERGY STAR designation to be a challenge for 

products (qualified or nonqualified) to meet, we found the majority of products 

tested, including non-ENERGY STAR products, met the ENERGY STAR 

efficiency standard, with some exceeding the standard by a wide margin. We also 

found that not all ENERGY STAR products performed comparably within the 

same product categories; some models were up to several times more efficient 

than others. Almost all of the models in our sample, including the non-ENERGY 

STAR products, would still qualify under more stringent energy efficiency 

standards. 

5

 The “Time to Sleep Mode” requirement is only one of three tests needed to be ENERGY STAR qualified. Further, 

as of July 2009, this model was no longer listed as an ENERGY STAR-qualified product. 

5 
 

 

 

 

 

10-P-0040 

Manufacturer-supplied performance data for each ENERGY STAR-qualified 

product is available on EPA’s Website. However, these data are not readily 

usable for performance comparison by consumers because the ENERGY STARqualifying standard is not included. 

DVD Testing Results 

DVD products must consume less than 1 watt of electricity in standby mode to 

qualify for the ENERGY STAR label. In our sample, we found the average 

consumption by the ENERGY STAR-qualified products was 0.56 watt, slightly 

more than half the allowable amount. The performance of these qualified 

products ranged from a low of 0.12 watt to a high of 0.89 watt. Six of the 10 nonENERGY STAR products we tested also met the standard. Two of the 10 nonENERGY STAR products performed better than 38 of the 40 (95 percent) 

ENERGY STAR products we tested. 

Specific details on the DVD products tested are presented in Figure 2-1 and 

described below. All items below the green bar met ENERGY STAR 

requirements. 

Figure 2-1: DVD Product Performance 

0.00 

0.20 

0.40 

0.60 

0.80 

1.00 

1.20 

1.40 

Watts Consumed in Standby Mode 

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 

DVD Products 

ENERGY STAR DVD 

Products 

Non-ENERGY STAR 

DVD Products ENERGY STAR Standard requires 

that products consum e less than 

1 w att in standby mode 

Source: OIG analysis. 

6 
 10-P-0040 

 

 

7 

Computer Monitor Testing Results 

ENERGY STAR performance standards for monitors vary based on product 

resolution and pixel configurations. Figure 2-2 illustrates the deviation in 

performance (positive or negative) relative to the applicable standards. The zero 

line on the chart below shows the value needed to meet the ENERGY STAR 

specification for this product. 

Figure 2-2: Computer Monitor Performance 

-20 

-10 

0 

10 

20 

30 

40 

50 

60 

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 

Computer Monitors 

Percent Exceeding Standard 

ENERGY STAR 

Monitors 

Non-ENERGY STAR 

Monitors 

Source: OIG analysis. 

The testing results showed that ENERGY STAR monitors surpassed the 

ENERGY STAR standards by 16 to 55 percent. Eight of the non-ENERGY 

STAR monitors performed similarly to the qualified products, performing 14 to 

37 percent more efficiently than the standards. One non-ENERGY STAR 

monitor performed more efficiently than half of the qualified products. 
 10-P-0040 

 

Printer Testing Results 

As with monitors, printer performance standards vary based on the addition of 

certain features included with the base product model. Figure 2-3 shows the 

performance relative to the key standard, the “Sleep Allowed Measure.” Similar 

to Figure 2-2, the zero line on this chart shows the value needed to meet 

ENERGY STAR specifications for these standards. While Figure 2-3 only 

applies to the ink jet printers tested, the test results for laser printers were similar. 

8 

Figure 2-3: Ink Jet Printer Performance 

100 ENERGY STAR Ink Jet

Printers

ards

90

80

Non-ENERGY STAR

Ink Jet Printers

a dn

70

 St

60

e ing

50

 Exc ed

40

30

Percent

20

10

0

1 3 5 7 9

Source: OIG analysis. 

11 13 15

Ink Jet Printers

17 19 21 23

Testing results showed that ENERGY STAR ink jet printers surpassed the 

ENERGY STAR standards by a low of almost 7 percent to a high of 88 percent. 

The laser printers (not shown) exceeded the applicable standards by a low of 

2 percent to a high of 81 percent. In addition, the performance of some of the 

non-ENERGY STAR ink jet and laser printers exceeded the key ENERGY STAR 

efficiency standards by a considerable margin. 
 

 

 

10-P-0040 

ENERGY STAR Benefit Claims May Not Be Valid 

Based on our test results, the energy and greenhouse gas reductions claimed for 

qualified products may not be valid. EPA uses the formula shown in Figure 2-4 

to calculate the annual energy savings benefits and greenhouse gas reductions 

resulting from the ENERGY STAR program: 

Figure 2-4: ENERGY STAR Energy Savings Calculation 

Non-ENERGY STAR product energy consumption 

minus 

ENERGY STAR product minimum energy consumption 

multiplied by 

ENERGY STAR product sales 

equals 

ENERGY STAR Product’s Energy Savings 

Source: EPA. 

This formula and our test results ultimately affect the accuracy of the computed 

energy savings attributable to the program. We did not find the ENERGY STAR 

products in our sample to have performance levels equal to the minimum 

standard, nor did we find all ENERGY STAR products for a particular category to 

perform similarly. Both the generalizations inherent in the formula and the final 

benefits reported are affected by (1) the overlap between ENERGY STAR and 

non-ENERGY STAR products for energy savings, and (2) the variation in 

performance within the ENERGY STAR products. 

Impact on Consumer Cost Savings 

ENERGY STAR products are advertised as offering consumers a means to reduce 

home and business energy costs, as well as an opportunity to help reduce 

greenhouse gas emissions. In a 2008 survey of consumers, EPA found 63 percent 

of households associated the ENERGY STAR label with “efficiency or energy 

savings.” In addition, of the households that recognized the ENERGY STAR 

label and purchased a product in a relevant product category within the past 

12 months, 73 percent purchased an ENERGY STAR-labeled product. 

Our results for the non-ENERGY STAR products tested show that many of these 

products met and exceeded program requirements. However, within the 

ENERGY STAR products selected, there were significant performance variations. 

These variations between qualified products and overlap with nonqualified 

products may mean that the cost savings advertised to consumers is misleading. 

Consumers who base their purchase of energy-efficient products on the ENERGY 

9 
 

 

 

 

10-P-0040 

STAR label do not necessarily realize savings over some non-ENERGY STAR 

products. Additionally, there can be a significant difference in efficiency among 

ENERGY STAR-qualified products. 

Conclusions 

The ENERGY STAR program is widely recognized but misunderstood. The 

ENERGY STAR label does not necessarily assure consumers superior energy 

savings over products that are not labeled ENERGY STAR. Despite the 

performance of all products in a given ENERGY STAR category, only those 

products produced by manufacturers that choose to join the ENERGY STAR 

program may advertise their products with the ENERGY STAR label. 

If our sample results are representative of the universe of ENERGY STAR 

products, these results call into question the ability of the program to identify 

products with superior energy efficiency. Because manufacturer participation in 

the program is voluntary, the ENERGY STAR designation does not necessarily 

identify the best performing products in the marketplace. Additionally, a high 

rate of compliance by non-ENERGY STAR products will affect the EPA’s 

method of computing energy savings. EPA could improve the integrity of the 

program with enhanced product testing and adjustments to the greenhouse gas 

benefits calculation. 

Recommendations 

We recommend that the Assistant Administrator for Air and Radiation: 

2-1 Verify estimated energy savings and greenhouse gas reduction 

calculations using a market-based performance testing program that 

includes testing non-ENERGY STAR products. 

2-2 Revise the ENERGY STAR Website to include the established standard 

alongside qualifying product performance data and to provide a summary 

listing of the highest performers. 

Agency Comments and OIG Evaluation 

The Agency concurred with our recommendations and agreed to implement them. 

However, the Agency disagreed with the report’s conclusions. The Agency did 

not concur with conclusions drawn based on a select number of non-ENERGY 

STAR products performing comparably to or better than the ENERGY STAR 

products. The Agency concluded that the value of the ENERGY STAR label is 

ultimately in the assurance the label provides consumers that the ENERGY STAR 

product they purchase will consistently save them energy. We disagree with this 

conclusion and maintain our concerns about the integrity of the ENERGY STAR 

10 
 

 

 

 

10-P-0040 

program as well as the associated energy and cost savings reported to consumers. 

The Agency’s complete response is included in Appendix A. 

11 
 

 

 

 

 

 

 

 

 

 

1 

10-P-0040 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 

2-2 

10 

10 

Verify estimated energy savings and greenhouse 

gas reduction calculations using a market-based 

performance testing program that includes testing 

non-ENERGY STAR products. 

Revise the ENERGY STAR Website to include the 

established standard alongside qualifying product 

performance data and to provide a summary listing 

of the highest performers. 

O 

O 

Assistant Administrator for 

Air and Radiation 

Assistant Administrator for 

Air and Radiation 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

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10-P-0040 

Appendix A 

Agency Comments on Draft Report 

(Received on November 6, 2009) 

MEMORANDUM 

Subject: Comments on the Draft Evaluation Report: ENERGY STAR 

Program Integrity Can Be Enhanced Through Expanded Product Testing 

From: Elizabeth Craig 

 Deputy Assistant Administrator 

To: Jeffrey Harris, Director 

Cross-Media Issues, Office of Program Evaluation 

Thank you for the opportunity to comment on the Draft Evaluation Report: ENERGY STAR 

Program Integrity Can Be Enhanced Through Expanded Product Testing. We are pleased to see 

that testing done by the Inspector General’s Office indicates that the ENERGY STAR qualified 

products tested are at least as efficient as advertised and no issues with the manufacturer selfcertification process were indicated. 

While we appreciate and share your interest in protecting the integrity of the ENERGY STAR 

Program, we do not concur with the conclusions drawn based on a select number of nonENERGY STAR qualified products performing comparably to or better than the ENERGY 

STAR products. The ENERGY STAR label’s image as a trusted symbol for environmental 

protection through superior efficiency is ultimately affected by the performance of products 

bearing the label, not by non-participating products. In fact, based on the compliance rates the 

OIG found, the consumer choosing a product with the ENERGY STAR label receives the energy 

efficiency they expect; choosing a non ENERGY STAR product would provide the consumer 

with a range of possible outcomes as the non-ENERGY STAR products may or may not be 

efficient. 

Although we disagree with the report’s conclusions, we recognize potential benefit associated 

with the recommendations it makes and would be pleased to implement them. 

13 
 

 

 

 

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OAR Response to IG Recommendations in Draft Report and Status of Implementation 

Recommendation 2-1: Verify estimated energy savings and greenhouse gas reduction 

calculations using a market-based performance-testing program that includes testing nonENERGY STAR products 

OAR Response: As part of the Obama Administration’s commitment to enhancing the 

ENERGY STAR Program (as articulated in a new MOU signed by EPA and DOE on 

September 30, 2009), we plan to institute new ENERGY STAR qualification testing 

requirements that will leverage market-based mechanisms to broaden and improve the 

performance test data available to us for use in verifying estimated energy savings and 

greenhouse gas reduction calculations. In conjunction with this effort, we will be 

working with the Department of Energy to expand verification testing of ENERGY 

STAR qualified products, with the intent being to test both qualified and non-qualified 

products. 

Recommendation 2-2: Revise the ENERGY STAR Website to include the established standard 

along side qualifying product performance data and to provide a summary listing of the highest 

performers. 

OAR Response: We agree that it may be useful to provide interested consumers a webbased means of comparing and ranking qualifying product performance against 

established ENERGY STAR standards. We are currently exploring options for 

effectively addressing this while minimizing added administrative burden. 

cc: Brian McLean 

Ann Bailey 

David LaRouche 

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10-P-0040 

Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Air and Radiation 

Deputy Assistant Administrator, Office of Air and Radiation 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Audit Follow-up Coordinator, Office of Air and Radiation 

Acting Inspector General 

15