December 6, 2013 Jeff Koses Director of Acquisition Operations General Services Administration 1800 F Street NW Washington, DC 20405 Re: ENERGY STAR Jeff, Thank you for your response to The Coalition for Government Procurement’s letter regarding the updated ENERGY STAR specifications for Schedule 36. We sincerely appreciate GSA for looking into the concerns raised in our letter and the subsequent Myth-buster’s dialogue between your team and Schedule 36 vendors. As mentioned in your letter, Coalition member companies are proud supporters of the U.S. EPA program as ENERGY STAR Partners and have been committed to designing, manufacturing and promoting highly energy efficient imaging equipment for 20 years.
Most recently, our
members actively contributed to the development of the Version 2.0 ENERGY STAR specifications for imaging equipment with the U.S. EPA and are in the process of transitioning to the new standard. While the 9-month period provided by the EPA is sufficient to update collateral information such as websites and marketing materials for existing ENERGY STAR products, the actual manufacture and release of Version 2.0 ENERGY STAR products is a much more involved process. The timing of the release of new Version 2.0 ENERGY STAR products depends on the product life cycle for each individual manufacturer. New models in the imaging equipment industry are generally released every 2 to 3 years. Therefore, despite a serious commitment by many of these manufacturers to the ENERGY STAR program, the new models that will meet the updated standard are not scheduled for release until the next year or so. At a minimum, it will take an additional quarter for Version 2.0 ENERGY STAR models that are also compliant with the Trade Agreements Act to be released for Federal customers since production is set up at a separate facility in a designated country. As GSA’s letter describes, only about 30% of imaging equipment products in the market will initially be able to meet the Version 2.0 specification. The Coalition is very concerned that the 1990 M Street NW, Suite 450 Washington, DC 20036 | P (202) 331-0975 | F (202) 822-9788 | www.thecgp.org
limited number of products available during the transition to the new standards will negatively impact competition for customer agency print management requirements. In particular, if GSA decides to move forward with its plans to remove products from Schedule 36 that do not meet the Version 2.0 ENERGY STAR specification on January 1, 2014, GSA will be unnecessarily limiting competition and access to best value solutions under the GSA Schedules program, the FSSI Print Management BPA and other Federal agency BPAs. As you know, ongoing, robust competition is fundamental to delivering best value solutions for customer agencies and the American people. In this circumstance, a reasonable transition period for manufacturers would foster that ongoing competition benefiting customer agencies, the American people and the industrial base. As such, GSA should provide a reasonable transition period to ensure that adequate competition is maintained and customer agencies can still purchase best value solutions under these contract vehicles.
If a significant number of products are removed from Schedule 36,
agencies will have fewer choices available to meet their requirements and less competition available to drive low pricing at the task order level. It will also leave the Managed Print Services FSSI BPA unworkable if the appropriate products needed to implement the Needs Assessment are suddenly no longer available. Similar to previous updates to the ENERGY STAR specifications for computers, we would prefer that GSA not remove products from the Schedule and allow government customers to choose which ENERGY STAR products they would like to purchase. However, if GSA does move forward with removing products that do not have the ENERGY STAR from Schedule 36, we respectfully request that implementation be delayed until January 1, 2015 when there will be a higher percentage of ENERGY STAR products on the market and TAA compliant models will also be available. At a minimum, we ask for a 9 month delay until October 1, 2014. The Coalition also recommends that GSA rely on the U.S. EPA’s ENERGY STAR certification process to determine which products have earned the ENERGY STAR. Thank you again for your attention to this matter and the ongoing dialogue with the vendor community. I am available anytime if you would like to meet to discuss further. I may be reached at (202) 331-0975 or
[email protected]. Sincerely,
Roger Waldron President
