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 O ffice 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.

EE-DET-94-002 COMMENT 01
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.

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March 22, 1995

EE-DET-94-002 COMMENT 01
Other 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

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- 3 - March 22, 1995

EE-DET-94-002 COMMENT 01
legislation, 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

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EE-DET-94-002 COMMENT 01
the 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

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March 22, I995-

EE-DET-94-002 COMMENT 01
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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EE-DET-94-002 COMMENT 01