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Volume 6   Issue 9               October  2005

New Energy Star Amendment Creates Controversy and
Sets Off Debate Among Manufacturers
by Alan B. Goldberg

The modifications to the Energy Star® program, which went into effect in September, 2005, (see June DWM, page 57) have generated concern from some and enthusiasm from others. It is based on a request by some DOE partners and stakeholders and stems from a meeting held in September 2003 to discuss a proposal. 

“When Energy Star began, there were exact U-factors and exact solar heat gain coefficients (SHGC’s),” says Dave Mills, president and CEO of Azon USA. Our initial argument with DOE was that ‘you are directing people what to use and what to manufacture.’ We said if you raise both values (U-factor and SHGC) in certain regions, you can save energy. We believe there is a misconception regarding lower values and energy efficiency. In our view, the focus should be on performance. Every product should be based on performance, not prescriptive criteria. We didn’t lobby against energy. We lobbied for greater energy savings.”

Why Amend?
After analyzing the results of a study completed in October 2004—Analysis Results for Performance Based Ratings for the Energy Star Windows Program—and reviewing comments from stockholders, DOE amended the qualifying criteria.

“This study was the culmination of 3-4 years of work and provided a convincing reason for the change. Energy performance is at the center of what we have been proposing for a number of years,” says Rand Baldwin, president of the Aluminum Extruders Council. 

“We want products to be energy efficient so these Energy Star guidelines should be performance-based just like most other Energy Star guidelines. I realize there has been a lot of discussion about U-factors, but it is one of many variables. The new amendment offers alternatives.”

Baldwin explained that in addition to being a performance-based initiative, the program has to be able to be implemented.

“Now, the consumer will be able to see any number of simple, performance measures for energy efficiency,” he says. 

Specifically there is a trade-off that involves higher U-factors and lower solar heat gain coefficients, but not in all four climate zones.

According to DOE, there is no latitude for trade-offs, either in the Northern or North Central zones. The criterion for the U-factor is equivalent to the same level as the International Energy Conservation Code (IECC) in the Northern zone. In the North Central zone, the current criteria are close to optimal. So the focus is on the South Central zone, excluding California, and the Southern zone. DOE is including the latter because it believes trade-offs are possible with the use of laminated low-E glass in many impact-resistant hurricane windows. They have higher U-factors but can save the same or more energy with lower SHGC’s.

The Justification
With this amendment, DOE states that it can meet its goals of defining alternative qualifications with criteria that offer the following: 

• Equal or greater average savings than the current prescriptive criteria; 
• Greater flexibility in U-factor performance ratings; 
• Equal to or exceeding prescriptive building energy codes in the two zones; and
• No adverse impact on the market; and enhancement of the value of the program.
DOE concluded that the amendment offers an overall benefit to industry and the consumer. 
It has established these three key expectations from implementing the amendment:
• Maintenance of the current competitive situation for all types of windows. Specifically, the change will make it possible for energy-efficient aluminum windows to qualify in the South Central zone, but excluding California; and
• An increase in the availability of aluminum windows that meet hurricane protection codes in the Southern zone. According to DOE, in 2003, 50 percent of all windows sold in Florida were hurricane-resistant. That proportion is expected to rise.
• The provision of a bigger choice of windows and more flexibility for consumers. 

Concern vs. Justification
Concerns range from confusion for the consumer to increased use of energy to various performance issues.

Some stakeholders believe the new qualification criteria will undermine what has been considered a simple program for communicating the higher level of energy performance.

According to DOE, the simplicity of the program will be maintained because of a product qualification label and a new display unit label system which will show visually whether and in what region a product qualifies, without requiring any additional technical detail.  

“As a vinyl extruder, we are not in favor of the new amendment,” says Joe Hums, regional sales manager for Mikron Industries. “We believe the original program was straightforward and simple to understand, for users and consumers. Allowing trade-offs based on a theoretical window that exactly meets both U-factor and SHGC will allow less efficient windows to qualify for the Energy Star program. This is a step backward for energy conservation.” 

Will products that qualify under the new amendment use more energy? To those who believe higher energy usage is a possibility, particularly in certain cities in the South Central zone, DOE references its goal of “establishing qualifying criteria expected to generate the greatest average energy savings across each climate zone.”

Another concern is the range of energy efficiency among qualified windows and DOE’s inability to distinguish between those levels. Does that mean all units will be treated equally even though they are not?

According to Jim Krahn, advanced research manager, Marvin Windows and Doors, the goal of the DOE Energy Star program was to raise the bar  and save energy. It was also to keep the program simple with consistent, maximum performance ratings.

“As these ratings are replaced with trade-offs in the South and South Central zones, the new qualifying windows are no longer equivalent to many existing real life products being delivered to those markets .The end result is that the trend (toward energy efficiency) is going the wrong way and that this type of change will in actuality increase energy consumption. It does not matter how much you save on paper. It’s how much you save at the pump or meter.” he says.

“I think we have to look for a realistic way to evaluate products for energy efficiency. There is more to the Energy Star program than the U-factor,” says Bill Deuschle, vice president of quality for TRACO. “Many factors need to be considered to determine if a product is going to perform. In our business [aluminum and vinyl windows], we also consider deflection as a critical issue. 

While we are always looking to improve the energy of a product, we will not substitute energy for safety. The bottom line is overall performance. So if a product has a lower U-factor, but is not the right structural product for the geographical area where it is to be used, we will not sell that product for that application. Performance comes in many packages, Energy is only one of those. Total performance, in my opinion, is where we [the industry] should be focused.” 

“Nobody wants to see a watered-down version of Energy Star,” says Jeff Lowinski, acting president of the WDMA. “The latest changes reduce the value of the current Energy Star requirements, making it easier for less efficient windows to qualify.”

He pointed out that Energy Star’s purpose is to promote performance beyond the minimum required by the code.  He said that trading off U-values for solar heat gain and relaxing requirements opens the door to less efficient products.

“It is our belief that DOE did not consider all the ramifications of their actions,” adds Lowinski. Some stakeholders believe that such a change puts DOE in a position where it will be committed to incorporate these trade-off features in future criteria permanently.

DOE’s response is that it will not lose sight of its energy-efficiency goals as it follows a general guideline to encourage performance-based specifications that are technology neutral and offer manufacturer flexibility. 

Can the amendment lead manufacturers and retailers to offer products with low visible transmittance? Some stakeholders say such products will not be in the best interest of consumers. Others maintain that consumers are able to evaluate significant differences in visible transmittance and that the market can determine the viability of products.

What about the current technology? Does it exist within the aluminum industry to achieve a U-factor of 0.43 or 0.42 in order to qualify in the South Central zone? Some stakeholders in the aluminum industry believe this is not possible with existing technology. Others view the new amendment as an opportunity to develop products to meet the standard.

“As key stakeholders in the effort to help conserve energy, WDMA member companies share the Department of Energy’s goals designed to encourage the use of energy-efficient products and practices to help conserve precious energy resources,” says Ken Bettger, senior principal engineer for Pella Corp. 

“As longtime supporters of products and practices which help reduce overall energy usage, WDMA members believe that it is essential that DOE maintains the integrity and consistency of the Energy Star-qualifying process. Stakeholders have made substantial investments to produce the innovations required to meet DOE’s aggressive goals aimed at conserving energy usage. To continue to invest heavily in energy-efficient products, stakeholder companies must have the assurance that DOE will continue to operate by a standardized process, based on scientific facts and technical merits,” he adds. 

Does the latest amendment for the South Central and Southern zones create more opportunities for the market as many stakeholders believe? Does it open the door to lower standards and higher energy usage as expressed by concerned parties? The discussions on its impact will continue. No doubt, the effects of the change will be documented and analyzed. But for now, as the old cliché goes, “time will tell” whether efficiency was sacrificed for opportunity or whether concerns about inefficiency were an overreaction to a controversial amendment.

Alan Goldberg is a contributing writer for DWM. He has more than 30 years of experience in the insulating glass industry. 

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