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July-August 2002

Change Imminent
Window Industry/DOE Meets
to Discuss New ENERGY STAR Criteria
by TARA TAFFERA

Representatives of virtually all the major window and door and glass manufacturers gathered at the Department of Energy (DOE) headquarters in Washington, D.C., on March 20 to discuss the ENERGY STAR® Windows program and possible revisions to the criteria for windows, doors and skylights. The meeting was part of DOE’s process to fully evaluate the criteria for ENERGY STAR Windows. This was a follow-up to industry feedback regarding changes to the program which were proposed last October. 

Pilkington’s Paul Gore has been one of the industry’s members who has been following this matter since the initial proposal. He said that the subsequent criteria changes were to have taken affect on January 1, 2003, but this was delayed following the discovery of a calculation error in the computational models used to evaluate the energy performance of the changes. As a result of the error, DOE delayed the implementation date, commissioned an evaluation of several alternative criteria changes and scheduled the March 20 meeting to facilitate review and discussion on the analysis. 

There were eight proposals regarding the ENERGY STAR criteria that DOE evaluated. The proposals included the original criteria, the proposed criteria and several alternate proposals submitted by stakeholders and interested parties. The DOE contracted Arthur D Little, along with Lawrence Berkeley National Labs, to evaluate the technical potential of the proposals. 

Eight proposals that weighed the relative impacts of various U-value/solar heat gain coefficient (SHGC)/climate zone combinations were evaluated. A database of 48 cities was used to calculate the energy consumption of a typical residential building. 

The goal of the analysis was to provide potential energy saving estimates for comparing various alternative criteria. The analysis conducted by Arthur Little focused on the following areas:

    • Potential national and regional energy savings;

    • Impact on product availability; 

    • Consistency with energy codes; and 

    • Energy-related impacts within the Central Region of the United States. 

The energy analysis methodology was developed from the National Fenestration Rating Council (NFRC) 900 database, but included separate paths for new construction and existing buildings. 
The DOE’s David Garman opened the meeting by stressing that ENERGY STAR is a priority for the Bush Administration, and that the DOE wants to get the specification right.

“The final specification could be the same as what was originally proposed in October, or different. If it’s different, it could be more or less stringent,” he said. “The goal of today’s meeting is a full and open discussion.”

SHGC
When the discussion turned to SHGC’s, Garrett Stone, with Brickfield, Burchette, Ritts and Stone, and who has previously represented Cardinal Glass and Andersen Windows, pointed out that other than the ENERGY STAR and the single-zone proposal (previously rejected by the industry and DOE), none of the other proposals have solar control above 3,500 HDD (.55 SHGC is clear glass). Guardian’s Tim Singel asked if the authors looked at the impact of dropping the SHGC above .55 in the other proposals. Ed Barbour, who gave the presentation on behalf of Arthur D. Little, said that dropping to 0.40 changes the absolute savings but not the relative relationship between the proposals. He also stressed that each of the regions were analyzed separately and then summed and that population was not factored in. The key issue regarding SHGC is the benefit derived from passive solar heat gain through high solar heat gain low-E products. This beneficial solar heat gain is considered a renewable energy source and a key consideration for DOE’s current programs. 

Climate Zones
According to Stone, the more zones you have, the more complicated it is for consumers. “Products might be qualified in certain zones but shipped to other zones,” he said. “Minimizing the number of zones minimizes potential confusion … Additionally, confusion is inevitable around borders of different climate zones. 

The more borders you have, the more confusion you have. This is why Dan Carlsen of Stanley Doors says he will only label products that qualify in all three zones, a point with which Ken Nittler of WestLab, says he agrees. “Proposals that make it impossible to make one product that qualify in all zones should be eliminated,” said Nittler. 

An alternate view was presented by Chuck Andersen with Simonton Windows who stressed that offering different products for the different climate requirements in the United States required a simple software change for printing and labeling products. He added that offering alternate products enabled the company to differentiate its products based on market requirements.
 
Bill Prindle of the American Council for an Energy Efficient Economy told participants that when evaluating proposals with regard to peak energy savings and emissions, it’s helpful to look to cooling energy savings as a good indicator. “All proposals are similar except for the Proposed ENERGY STAR and Proposal 4, which would do a better job of reducing NOX, SOX and Carbon,” he said. 
Several participants said that peak energy savings and the inefficiencies of the power generating facilities cannot be solved by window manufacturers. It was also stressed that windows should 
be evaluated based on the energy performance of a window all year long. 

Discussion on Proposed ENERGY STAR Specification
If you look at the comments made both during and following the meeting (go to www.energy-star.gov/opie/windowspec to view these comments as well as other detailed information from the meeting), many participants seem to favor the ENERGY STAR proposal. However, Paul Gore points out that this proposal came in seventh in regards to overall energy savings. “Annual energy performance is most important to customers,” he said. 

Gore also added that the DOE needs to work on increasing consumer demand for ENERGY STAR. “Most increase in market share can be attributed to manufacturer demand for ENERGY STAR rather than consumer demand,” he said. “Demand is also higher on the replacement side than on new construction, and DOE should work on the new construction side.”

Atofina Chemicals, also has some concerns with the ENERGY STAR proposal. Atofina’s Thomas Culp posted his comments on the DOE website which address summertime peak demand and energy supply issues. While Culp said these are important for the nation, he added that soft-coat manufacturers have attempted to exaggerate the link between residential windows and peak energy shortages. 

“As the report prepared by A.D. Little states, the potential annual peak energy savings due to reduced solar heat gain windows in the central region is 164 MW. In comparison, the 1999 total annual peak load in the U.S. was 681,449 MW according to the Energy Information Administration,” said Culp. “The potential savings of windows to the peak load experience, therefore, is an infinitesimal 0.024 percent—a number far too small to be considered relevant.” 

Key Issues
DOE solicited comments from attendees regarding the various proposals with the intent of reaching an industry consensus. Key issues were: compliance with existing energy codes; recognition of energy-efficient technology based on the respective climate conditions; and overall energy savings with the program.

Regarding existing energy codes, Gore said that issue is fairly well-defined. But, an issue of contention is ensuring a market for energy-efficient technology. “High solar heat gain low-E has proven to contribute to energy savings in the Central and Northern United States. That product should not be excluded from the program,” said Gore. “Likewise, aluminum-frame windows with low solar heat gain glass should not be eliminated from the Southern United States.”

With regard to overall energy savings with the ENERGY STAR Windows program, Gore said that is a key requirement as well. “The issue of contention is whether the energy savings is based on overall year-round energy performance which is a valid point of peak energy savings which seeks to minimize the performance of a window to a specific time of use measurement,” he said. “These are the key issues which DOE is reviewing relative to presenting the final draft criteria.”

Next Step
On May 8, 2002, the DOE announced revised proposed criteria for a new specification for ENERGY STAR windows, doors and skylights, which is similar to DOE’s original October proposal except for some modifications. Interested stakeholders will have 45 days to comment with comments being due to the department by Friday, June 21, 2002. Once all the comments are received, the DOE will offer its final proposal and announce the effective date. The DOE would likely have a six month phase-in period (which was requested by large window manufacturers and those that sell to big-box stores). 

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