Volume 11, Issue 6 - November/December 2009


California Cool?
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.

Cool Cars
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; and

• 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 vehicle.”

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

Proposed Changes
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 58 percent.”

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.”

Replacement Options
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,” he says.

And, because the regulations call for advanced energy-efficient glass, it actually may help glass shops increase their bottom lines, Rustagi notes.

“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

Repair Concerns
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 glass route.

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.”

Manufacturer Feedback
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 now.”

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 vehicle cooler.”

Penny Stacey is the editor of AGRR magazine.

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No reproduction of any type without expressed written permission.