I think the primary concern surrounding this Agreement has to do with the new CW Energy Star levels. It is clear that the tranisition has not been completely thought through. Some of the things I am trying to sort out include: 1. Is the new ES level of 1.26 MEF using the J1 test procedure? Everyone "thinks" it is, but no one can confirm this, not even DOE at this point. It makes a difference!

2. When is the effective date? The DOE notification stated Jan. 1, 2001, but some of the manufacturers state that is still in negotiation and could be July 1, 2001.

3. Since the mfrs agreed to submit WF to Energy Star, will they post that information on their web site?

4. How will the mfrs submit this data to Energy Star? Will it be through FTC, in which case they will need to submit a petition to do so? Or will it be voluntary similar to the process they undergo with the CEE qualified list?

I am continuing to investigate these issues and will keep all posted of any developments. In the meantime, any knee jerk reactions?

-- Dana Banks (dbanks@ceeformt.org), June 23, 2000

Answers

I repost words that got filed under a misleading title.

I think we should celebrate the recent agreement on new clothes washer standards because our efforts contributed to bringing about a concrete change in the market place. However, we should also acknowledge that the new standard falls short of the mark for which we aimed just a few years ago. If, as Charlie Stevens believes, a significant number of actitator-type machines survive the 1.26 MEF cut of 2007, we will face very tough sledding if we advocate for even higher minimum efficiencies. More about that at another time. For now I think we need to concern ourselves with what we can do to promote resource efficiency between now and 2007 and beyond.

Got any ideas?

Yen

-- Yen Chin (yen.chin@ci.seattle.wa.us), June 28, 2000.

Hi. I've been doing a bit of homework in preparation for changes to the specifications for clothes washers for our tax credit program. The changes will take place on January 1, 2001, no matter what happens to energy star. It's my intention right now to require both a minimum MEF, based on the J1 test procedure, and a maximum water factor. Most top loading, vertical axis machines, with the exception of the new Kenmore Elite, will be screened out. The MEF I may use is the second tier Energy Star number of 1.42.

I talked to John Kurtz of Whirlpool specifically about the test method assumed for meeting the new standard and Energy Star requirements, and he is under the impression that it's definitely the J1 version. There is some discussion of when the Energy Star levels will go into effect, but I believe it will be January 1, 2001 for clothes washers, even if it's later than that for refrigerators (which it might be - March 1st or April 1st are dates being discussed now).

Our new refrigerator specification for tax credits will be 15% better than the 2001 standard. It has to be that high to even justify a transaction. I'll be looking at the dishwasher spec, too, but that may or may not change. I will likely add split system heat pumps and air conditioners to the program, at a very high SEER level (15) and with a very high EER requirement, as well (13+). There will likely be a second tier at SEER 16 and EER 14. This means that for our purposes here, Energy Star will be virtually irrelevant for the State of Oregon and its programs. That's not to say that some utilities or utility consortia won't be using it, but we feel very strongly that it's time to send DOE and others a much stronger message about what's needed in standards. It's not just about the level of the standard, but it's also about how the standard is specified. For us, water savings are critical in clothes washers, and EER is critical in air conditioning systems. It's time. More soon. Do let us know what you all are doing. And see you in Portland in September. CMS

-- Charlie Stephens (charles.m.stephens@state.or.us), July 12, 2000.

Charlie's posting touches on a much wider range of topics than the thread contained originally. I'm going to try to contain my response within what I take to be the original bounds but may not succeed.

Expected changes in the Federal Energy Efficiency Standards for clothes washers create significant challenges for those of us who operate rebate-based programs (and I consider tax credits to fall into the realm of rebates). This is because, for all our talk of market transformation, we continue to have to answer to the gods of levelized cost and other DSM-type cost-effectiveness criteria.

When the first bump up in the standard kicks in, the incremental savings for current CEE listed machines decreases significanly. For me in Seattle where marginal values of energy remain relatively low and frequency of use is typically just over half the national average, a $50 rebate will translate into a resouce acquistion cost of about 70 mils, and ugly figure to my masters.

The CEE list has served me well in the past. Consequently, I have strong reservations about setting clothes washer program qualifications that employ a yardstick different from such a list. 1.42MEF with J1 testing may work fine for Charlie, but I may need 1.55MEF or some other level. The absence of single repository can add too much chaos even for me.

Gotta run, but I'll send more words next week.

Yen

-- Yen Chin (yen.chin@ci.seattle.wa.us), July 13, 2000.