I recently had occasion to read an old paper by Janda and Brodsky describing the “first class” of ENERGY STAR certified office buildings.  This is one of only a handful of papers in the peer-reviewed literature regarding ENERGY STAR building scores.  Janda and Brodsky describe the brand name ENERGY STAR as

a set of voluntary partnerships between the U.S. government and product manufacturers, local utilities, home builders, retailers, and businesses.  These partnerships are designed to encourage energy efficiency in products, appliances, homes, offices, and other buildings.

This was the basis for the EPA’s building ENERGY STAR scoring system.  It was a “game” that building managers voluntarily agreed to play with rules (methodology for scoring buildings) set by the EPA in consultation with those playing the game.  There was no scientific vetting of the “rules of the game” — nor did there need to be — it was just a game designed to “encourage energy efficiency.”  No one was forced to play the game.  Data submitted to Portfolio Manager (the EPA’s web-based tool for calculating scores) and ENERGY STAR scores issued by the EPA were confidential — unless a building sought and received ENERGY STAR certification.  Participation was entirely voluntary.  Building managers disappointed with their ENERGY STAR scores could just walk away from the game — no harm, no foul.

But this has all changed.  In recent years 1) the EPA has published specific claims regarding energy savings associated with its ENERGY STAR benchmarking program (real savings not just fantasy football), 2) external organizations like the USGBC have adopted the ENERGY STAR score as their metric for energy efficiency in green building certification programs and are using these scores to make energy savings claims of their own, and 3) major U.S. cities have passed laws requiring commercial building owners to use Portfolio Manager to benchmark their buildings and, in many cases, the resulting ENERGY STAR scores are being made public.  With federal, state, and local governments requiring LEED certification for public buildings this is no longer a voluntary game — it is mandatory and real (testable) energy claims are being made based upon ENERGY STAR scores.  Now the science behind such claims actually matters — and this science has never been vetted.

Its kinda like a small, “mom and pop” operation that has been selling chicken soup using “grandma’s recipe” without obtaining proper license or FDA approval.  Now imagine Walmart decides to market and sell the soup — the scrutiny changes.

As a voluntary game with no connection to reality it is OK that the EPA negotiates rules for its ENERGY STAR ratings with different constituents — like allowing Washington DC office buildings to ignore their “first floors” in seeking ENERGY STAR certification.  After all, who am I to interfere in the activities between consenting adults when these activities do not affect me?  But for ENERGY STAR — these days are gone.

In the next year we will learn much about the science that underpins the EPA’s ENERGY STAR benchmarking system — and the results are likely to be very disappointing.  This benchmarking system is not ready for prime time.