6450-01-P 

### Office of Codes and Standards Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy Draft of Evaluation Criteria for the Voluntary'Program" to Provide Energy Efficiency Information for Commercial Office Equipment January 1995
1. Background

Since the passage of Energy Policy Act of 1992 (EPACT), Pub. L
. 102-486, 106 Stat. 2776, the Department of Energy has monitored the efforts of the commercial office equipment industry to develop a testing and information program through the Council on Office Products Energy Efficiency (COPEE), a working group composed of office equipment manufacturers , with an advisory group representing environmental organizations , designers , national laboratories, state and Federal agencies , and office equipment professionals. On May 26, 1994, DOE ._held a public meeting, at which interested persons were invited to offer suggestions concerning methods of evaluation , and to provide updates on the progress of the voluntary program. A transcript of the meeting was made available to the public , and subsequent comments were invited through June 15, 1994.

Workshop comments centered on the verification of-coverage of the program, the possibilities for data collection and tracking energy efficiency, trends, and the ability to evaluate whether the new energy efficiency information is reaching its target audiences

. COPEE submitted a follow-up program description to DOE on July 15, 1994.The types of commercial office equipment that have been identified as

widely used with a potential for significant energy savings are those that the Council submitted to be included in the program: (1) Micro computers; (2) Page printers (ink jet and laser ); ( 3) Low

-speed , plain paper copiers (1-24 copies per minute ); ( 4) Medium

-speed , plain paper copiers ( 25-39 copies per minute ); and (5) Facsimile equipment

. DOE understands that category ( 1) will also include computer monitors , whether sold separately or with a micro computer system . If the products included in the COPEE program comprise a significant portion of the commercial office equipment market as claimed, and show significant potential for energy savings, their selection appears to provide a reasonable base for the initial phase of the program.

The American Council , for an Energy-Efficient Economy (ACEEE) addressed issues concerning the long-term operation of the voluntary program and the ability to confirm market targets and percentages

. Regarding the'selection of office equipment to be included in the program , ACEEE urged that a mechanism be established to add new office equipment types that gain market share in the future. It also urged that the voluntary program meet specified percentage targets of manufacturer participation overtime . ACEEE suggested that an acceptable target would be for 75 percent of the equipment covered by the program to have energy efficiency information by October 1995. Finally, it brought up data collection and tracking energy efficiency trends as possible

areas of information needed. These issues are addressed in the evaluation criteria, infra.

Q:\CE-40\CE-43 \43COMMON\BALDUCCI \OFFCEVAL.003 March 22, 1995Other public meeting comments centered on how to verify that a

significant percent of the commercial office equipment market is covered by the categories selected for the program, and how to evaluate whether the new energy efficiency information is reaching its target audiences. The Council on Office Products Energy Efficiency will be responsible for tracking press
coverage , and will develop a survey on awareness of the program to be used by manufacturers ' representatives , distributors , and specifiers.

2. Evaluation Criteria and Procedures

The evaluation criteria that follow are directed toward the objectives of the voluntary national testing and information program for commercial office equipment , i.e., those types of commercial office equipment that are widely used , and which show a potential for significant energy savings be tested according to specified procedures, and that the resulting energy efficiency information be disseminated effectively to potential customers. The Department ' s view is that effective dissemination of.product information, in addition to testing, is an essential part of the voluntary, industrysponsored program. In order for the Department of Energy to make its determination as required by law, the Department is requesting that all voluntary national testing and information program for commercial office products be submitted to DOE, no later than July 14 , 1995
. The report should outline how the voluntary national testing and information program for commercial office equipment , in operation as of that date, includes and addresses each of the elements described below . If the Department determines that the voluntary program is not consistent with the objectives of the

Q:\CE-40\CE

-43\43COMMON\BALOUCCI\OFFCEVAL.003 - 3 - March 22, 1995legislation, the Department may support an alternative industry-based program

prior to establishing a mandatory Federal testing and labeling program as provided in Section 125 of EPAct.

a. Program Organization: Since EPAct specifies that the voluntary program should be developed in consultation with the Computer and Business Equipment Manufacturers Association, the Department will assess the composition and procedures of the group developing the program to determine if it reflects a consensus position within a broad spectrum of the commercial office equipment community.

b. Coverage: In order to determine which types of commercial office equipment are widely used and show a potential for significant energy savings, the Department will require data supporting the selection of the specific commercial office equipment categories to be included in the initial phase of the voluntary program, and for verifying the stated market coverage with documented data sources. The specific office equipment categories to be covered in the initial phase of the voluntary program should be identified, and information submitted to explain the rationale for their selection, and to verify the stated market coverage with documented data sources. The target for the program should be approximately 80 percent of the commercial equipment currently manufactured and sold, as measured by dollar sales as a fraction of total sales for each type of product. For each product category, the report submitted shall identify the market share represented by manufacturers participating in the program as of July 1995. The report shall also indicate planned actions to increasethat market share to the target levels in

Q:\CE-40\CE-43 \43COMMON\BALDUCCI\OFFCEVAL.003 4 - March 22, 1995the future. As the program expands to include testing and rating methods for

additional categories such as multi-function items and servers, a plan should be developed to include these products.

c. Testing and Rating: In order to evaluate the testing procedures, the Department will compare the proposed test procedures to commonly accepted procedures for developing national testing procedures, and assess whether the. resulting energy efficiency information will enable purchasers to use the data to make more informed decisions about the costs and efficiency of alternative products. The proposed testing and rating program should provide consumers with a consistent standard of measurement for comparing the energy efficiency of the commercial office equipment covered by the program.

d. Information Program: In order to assess the effectiveness of the energy efficiency information provided to customers, the Department will evaluate guidelines proposed to determine how different audiences, managerial, purchasing, and technical, have been targeted. Recommendations and decisions on the use of catalogs, labels, or other materials shall be explained. Energy efficiency information materials shall be submitted.

e. Manufacturer Participation: In order to assess whether the voluntary program proposed is a broad-based national program, the Department will require indication of manufacturer participation. It is reasonable to establish targets of manufacturer participation, which would gradually increase as the program expands over time. Although the program is voluntary,. a measure of manufacturer participation should be set, with gradually

Q:\CE-40\CE-43\43COMMON\BALDUCCI\OFFCEVAL.003 March 22, I995-increasing targets of participation over time. Manufacturers are expected to

have energy efficiency information published by October 1995 for approximately 25 percent of the commercial office equipment covered by the program, approximately 50 percent by October 1996, and approximately 75 percent by October 1997. A plan for collection and documentation of a survey evaluating participation levels shall be submitted.

f. Publicity: If the voluntary program is to be effective, a companion effort must be made to inform a wide range of buyers and installers about the energy efficiency rating system. The Department will assess what strategies have been developed and launched to promote the program. A plan for evaluating buyer and user awareness of the program shall be submitted.



### g. Market Data: To establish a baseline and provide a means to track office equipment energy efficiency over time, a system for data collection and reporting should be established. A plan for this data collection and reporting shall be submitted, along with ways DOE might be able to evaluate energy savings and energy efficiency trends in the industry.

h. Continuation of the Program: A plan should be established that will enable the commercial office equipment testing and information program to be self-perpetuating, and to include new products as they become significant in the marketplace. 

### A future evaluation by DOE in one to two years may be necessary to monitor the progress of the program.

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