DWM - 2008 - December

Volume 9, Issue 11 - December 2008

AAMA Analysis

Energy Star^® Changes Raise Concerns
by John Lewis

The road to green seems to pass through the Department of Energy's (DOE) Energy Star for Windows, Doors and Skylights program. The National Association of Homebuilders (NAHB) National Green Building Standard requires Energy Star credentials. So does the U.S. Green Building Council (USGBC) LEED™ residential rating system released last January.

Tightening the Criteria
The DOE has stated that energy code requirements are superseding the Energy Star criteria for windows in some areas and that the program’s phenomenal 59 percent market penetration is “too high for the label to have meaning in the marketplace.” So the DOE is tightening the program’s window, door and skylight criteria in two phases, the first of which could become effective as early as August 2009. These first-phase criteria would push the minimum requirements to meet or exceed those of the proposed 2009 International Energy Conservation Code (IECC). Phase two would take effect at the beginning of 2013 and would establish performance levels well beyond code requirements.

Proposals on the Table
The most recently proposed adjustments to the criteria:
• Lower U-Factor in northern zones (initial target range: 0.20-0.30) substantially;
• Capture winter solar gain using a minimum Solar Heat Gain Coefficient (SHGC) in the North;
• Lower SHGC in southern zones (initial target range: 0.20-0.30) substantially;
• Allow SHGC/U-Factor trade-offs in the heating-dominated northern zone (except the Pacific Northwest); requirements for southern region are prescribed, with no equivalent performance criteria permitted;
• Add minimum Visible Transmit-tance (VT) criteria to ensure adequate light; and
• Require insulating glass unit (IGU) certification.

There has been significant response from those in the industry, many of whom are concerned about the manufacturing feasibility and marketability of products that would meet the ratcheted requirements. In response to requests received at an August stakeholders meeting, DOE extended the comment period for the criteria revision until November 14—a further extension past the original extended deadline of October 17.

While DOE maintains that the Phase 1 requirements “can be achieved by most manufacturers without significant product redesign,” it recognizes that Phase 2 criteria will “require most manufacturers to alter product designs and upgrade processes.”

Previous comments from AAMA have helped achieve some migration of the criteria as originally proposed in October 2007. But AAMA and many manufacturers remain concerned about the aggressive U-factor and SHGC values, which threaten some manufacturers with having to vacate some markets altogether and others with having to increase prices significantly. If this happened it would ensure Energy Star’s goal of greatly decreasing its market share but reducing sales in a time when sales are already quite sufficiently reduced.

AAMA has challenged this philosophy—that Energy Star must be enticing, but not quite attainable (except about 25 percent of the time)—by asking if the overarching energy saving goals could not more easily be achieved by strengthening the Energy Star brand to the point that consumers demand windows that comply.

One problem with the tighter requirements is that they theoretically are justified by a payback analysis; that has been judged faulty by some and performed for DOE by its principal contractor. As of this writing, a major window manufacturer and AAMA member is conducting our own analysis that could challenge this justification. AAMA submitted updated commentary based on this independent analysis. By the time this column appears in print, manufacturers may have achieved something of a reprieve.

Whatever the outcome, AAMA will continue participating in the evolution of Energy Star to help ensure that the criteria reflect the practical realities of current technology, industry infrastructure and market preferences.