WDMA Raises Concerns About Energy Star’s Course
by Ben Gann
The Window and Door Manufacturers Association (WDMA) is concerned about the overall direction of the Energy Star program for windows, doors and skylights and has suggested to the Environmental Protection Agency (EPA) that it revise the currently proposed criteria for the next version of program standards (Version 6.0) set to take effect as early as January 1, 2014. Additionally, WDMA has stated the effective date for any changes to the program should not begin before January 1, 2015.
In keeping with EPA’s guiding principles for the program, the agency should also ensure Energy Star products are cost-effective, affordable and available for consumers. EPA’s current proposal for Version 6.0 will needlessly result in Energy Star products that are less cost-effective, less affordable and less available to consumers in many parts of the country. Thus, they should be revised to be made less stringent than what is currently proposed for certain parts of the U.S.
On January 7, 2013, EPA released Draft 2 of Version 6.0 for windows, doors and skylights for industry feedback. While EPA made some favorable changes from the previous draft, it retained overly stringent performance criteria for much of the U.S.
The agency’s revision of the Version 6.0 specifications is inconsistent with the program’s guiding principles because it places too much weight on reducing the market share of Energy Star products and too little emphasis on other important principles like cost-effectiveness for the consumer.
WDMA is also concerned by EPA's decisions to maintain the proposed stringent window and skylight performance criteria for the North-Central and Northern climate zones and maintain the January 1, 2014 effective date for new program requirements.
The proposed performance criteria for the northern zones will increase product costs significantly and create “payback periods” to recoup the extra costs for these products that are longer than the actual time a homeowner typically stays in a house (7-10 years). As a result, Energy Star products will be less affordable for consumers.
Energy Star should be a key driver in replacing the nearly one billion single-pane windows still in use in our nation’s housing stock. However, the proposed standards will result in substantial cost increases and price out a significant percentage of the population.
As Energy Star partners, WDMA members have long been supporters of the program and have contributed substantially in growing the brand in the market.
Successfully transitioning to the new requirements touches every aspect of a manufacturer’s business: design, engineering, manufacturing, certification and marketing. Manufacturers need adequate time to implement changes across their organizations, while also working with dealers, consumers and their supply chain. EPA’s decision to maintain an effective date of January 1, 2014 will not provide manufacturers with a sufficient transition period if the new requirements are finalized later this spring.
WDMA has urged EPA to move the effective date to no earlier than January 1, 2015, giving the Agency adequate time to appropriately review and consider industry comments, making needed revisions to the currently proposed criteria, and giving manufacturers appropriate lead time to transition to the new criteria once it is finalized.
EPA should also address industry concerns about the overall direction of Energy Star and return the program to its original mission as laid out in its guiding principles. These focus on setting criteria for saving energy by helping consumers identify energy-efficient products that are affordable, widely available and provide reasonable payback periods, not reducing market share as means to drive technology.
Ben Gann is director of legislative affairs and grassroots activities for the Window and Door Manufacturers Association in Washington, D.C.
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