State Air Resources Board Opts for Auto Glass Regulations—Could
the Rest of the Nation Be Next?
by Penny Stacey
Just over a year ago, the California Air Resources Board (CARB) started
to investigate ways to make cars run more efficiently; it was part of
the group’s effort to comply with AB 32, an initiative designed to decrease
the state’s greenhouse gas initiatives.
CARB started by looking at the cars’ paint, in hopes that reflective paint
might reduce the heat entering the vehicle. When they found that wouldn’t
work, they turned to the glass. Soon, their vote to enact regulations
that affects auto glass may become a reality.
Though the final draft of the regulation has not yet been finalized, at
press time, CARB was calling for reduced solar transmission through the
glass in an effort to reduce the load on the vehicle’s air conditioner.
These regulations would affect any vehicles sold in the state, beginning
in 2012. CARB also was considering allowing manufacturers to utilize an
alternate method to achieve the same energy savings starting in 2016.
The draft of the regulations, released in May, would apply to light-duty
and medium-duty vehicles less than or equal to 10,000 pounds.
The regulations specifically address the total solar transmittance (TST)
required for the glass; CARB defines this figure as “the ratio of the
transmitted solar flux to the incident solar flux, i.e., the ratio of
the amount of solar energy that passes through the glazing (including
energy absorbed and subsequently re-radiated to the interior) to the amount
of solar energy falling on the glazing.”
The May draft of the regulations would require that:
• for vehicles with the model year 2012, at least 75 percent of each manufacturer’s
total vehicle sales must use a windshield with a TST less than or equal
to 50 percent;
• likewise, sunroofs in 2012 and subsequent model year vehicles would
be required to have a TST less than or equal to 40 percent; sidelites
and backlites meeting 7 percent visible light transmittance (VLT) would
need to have a TST less than or equal to 60 percent. Those not meeting
70 percent VLT would need to have a TST less than or equal to 40 percent.
• for 2013 model year vehicles, all vehicles sold in the state would be
required to have a windshield with a TST less than or equal to 50 percent;
• for 2014 and subsequent model year vehicles, the windshield would be
required to have a TST less than or equal to 40 percent.
Under the regulations, TST would be measured using the ISO’s Standard
13837 Road Vehicles – Safety Glazing Materials – Method for the Determination
of Solar Tranmittance, Convention A (published in April 2008).
The regulation provides some exceptions for “deletion windows,” which
CARB defines as “areas on a vehicle’s glazing specifically designed to
facilitate transmission of electromagnetic signals into and out of the
The regulation notes that deletion windows “as necessary for the purpose
of allowing increased electromagnetic signal penetration” are exempt from
the requirements; however, they do require that “the area of the deletion
window shall not exceed 30 percent of the total window area, and the total
material removed or not applied shall not exceed ten percent of the total
material applied to the entire window.”
“The windshield looks
pretty much like any other windshield in terms of size
and fit and from a handling perspective it shouldn’t be any different.”
—Mukesh Rustagi, Pittsburgh Glass Works
Though the regulations were drafted earlier this year, and CARB voted
in June to enact some version of these regulations, they are still in
development. The board met recently to discuss changes and review comments
it received. A final draft incorporating the changes was scheduled to
be released at the end of October.
Among the proposed changes to the regulations is one that allows an “alternate
performance option” for 2016 and subsequent model-year vehicles. This
would provide auto manufacturers with the option of utilizing “an alternate
vehicle systems-based performance approach that results in equivalent
solar control” as would be provided by the energy-efficient glass option.
The regulations, in their current form, call for windshields, sidelites
and backlites for 2016 and later model year vehicles to have a total solar
transmission of less than or equal to 40 percent.
The proposed change also would mandate that the alternatives be “approved
in advance” by CARB.
Potential labeling requirements for energy-efficient glass that meets
the regulations also are being proposed. The recent draft proposal calls
for the glass to be marked “in a font of a size and nature similar to
that for the DOT code, model number and ANSI code.” For example, the glass
might be marked C58 “for a glazing certified to have a TTS no more than
Manufacturers also would need to apply a vinyl label to the glass after
it is made that reads, “This glass is designed to reduce interior temperatures
compared to standard glass and meets all ARB regulation.” The label would
need to be placed such that it is fully visible when installed and, for
sidelites, “it shall be visible in the fully closed position,” according
to the draft of the 15-day proposed changes.
“The original draft of the regulations showed labeling as ‘reserved,’”
explained Dr. Marijke Bekken, the CARB representative overseeing the process.
“In general, the [industry] response was that there’s a lot of stuff already
on the glass, so we tried to keep [the labeling requirement] small.”
The regulations also would require that vehicles equipped with the specified
energy-efficient glass have the same installed when and if replacement
glass was required. Likewise, vehicle manufacturers would need to include
details about what is required in the vehicles’ owners’ manuals.
“If you replace your [solar management] windshield with one that doesn’t
have solar management, [it could be a problem]. Your air conditioner is
sized for that solar management glazing, and [without it] you might end
up running it more than you would have before,” Bekken said. This would
defeat the ultimate goal of the regulations—to reduce greenhouse gas emissions.
The regulations also note that the replacement glass would need to meet
the same labeling requirements as those to which OEM glass would adhere.
Of course, the glass will then be more expensive, but Bekken says the
added cost will be minimal.
“Maybe you pay an extra $25 for the windshield—that’s not a whole lot
of difference,” she said.
She also advised CARB consulted with insurance companies during the development
of the regulations, and didn’t receive negative feedback from them.
“We spoke to a number of insurance companies during the rule development
process and … we found the difference in cost isn’t expected to have any
effect on the premiums people pay, because the amount of their cost is
extremely small,” she said.
Recordkeeping also will be a factor.
“The replacement shops are required to … maintain records for a period
of five years showing the appropriate performance level glazing has been
installed at replacement,” says Rob Vandal, director of advanced product
development, Guardian Automotive.
As for technical issues, though, Mukesh Rustagi, director of strategic
product management for Pittsburgh Glass Works, says there shouldn’t be
any for replacement shops.
“The windshield looks pretty much like any other windshield in terms of
size and fit and from a handling perspective it shouldn’t be any different,”
And, because the regulations call for advanced energy-efficient glass,
it actually may help glass shops increase their bottom lines, Rustagi
“Because these are value-added products, they might add value to glass
shops in the future,” he says.
“If they save emissions
on cars but create extra windshield replacements …
is it even a benefit?”
—David Casey, SuperGlass Windshield Repair
Though it appears the impending CARB regulations will have the greatest
initial impact on manufacturers and replacement shops, some glass repair
technicians fear they will be impacted as well.
David Casey, owner of SuperGlass Windshield Repair in Orlando, Fla., has
concerns about what might happen when reflective glass using coating applied
to the Number 2 surface of the glass is used—and when that glass has a
chip and needs a repair.
“When resin hits [this], its reaction [is] to turn pure white,” Casey
said. “Even moisture tends to cause it to discolor.”
His concern is that this could lead to more of a need for replacements—and
would have a greater impact on the environment than the greenhouse gas
emissions CARB is hoping to save.
“If they save emissions on cars but create extra windshield replacements
… is it even a benefit?” he asks.
However, Bekken pointed out that the regulations are a performance requirement—and
the way the solar transmissions savings are achieved is not specified.
“We don’t specify the compliance method,” she said.
Likewise, the latest changes, if accepted, call for an “alternative performance”
option—for vehicle manufacturers who choose not to go the energy-efficient
However, for those who do opt to use such a coating as Casey points out,
manufacturers say there are various ways in which the glass can be manufactured.
“There are product examples today with the coatings on Surface 2 as well
as Surface 3,” says Guardian’s Vandal. “The decision is primarily driven
by cosmetic and functional considerations of each OEM. Solar reflective
performance diminishes the further the coating is removed from Surface
1, so as CARB pushes to maximize solar reflectivity, I expect to see more
applications use Surface 2 coatings.”
In this case, a repair could prove difficult, Vandal says.
“If the part being repaired has Surface 2 coating, there will be a chance
the repair could be more visible than with uncoated parts,” he says. “This
will depend greatly on the level of damage. I expect a large chip penetrating
to Surface 2 will show some discoloration from displacement of the coating
under certain light, whereas a crack, which is still quite closed, will
not show much. It is reasonable to expect that some windshields which
may have been repairable previously, while still functional if repaired,
may not be cosmetically acceptable for the above reasons.”
Though the CARB regulations could have implications for repair technicians,
depending on how often vehicle manufacturers opt to utilize the energy-efficient
glass option in lieu of an alternative performance option, manufacturers
say the technology will be somewhat simple for them to achieve, based
on the products already available today on high-end cars.
“Guardian manufactures and sells a wide variety of infrared reflective
automotive glazing in Europe for Audi, BMW, Ford, Porsche, Bentley, Lamborghini
and others and has done so for more than ten years,” says Vandal. “Guardian
has the appropriate technology and key assets in North America to be prepared
to meet the requirements of CARB. We are in the process of tuning the
European product for the North American market and CARB requirements right
PGW also has offered infrared reflective glass for many years.
And, Rustagi says in his view, the regulations may bring some value to
an industry that has been working against being viewed as a commodity.
“I think the California regulations are helping the glass industry bring
value-added products to the mainstream market,” he says. “These are products
that have been used in high-end cars for quite some time and now with
the regulations they’ll be forced into the mainstream market and the consumer
will finally get to see the value that glazing provides in keeping the
Penny Stacey is the editor of AGRR magazine.
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No reproduction of any type without expressed written permission.