DOE Reviews Energy Star^® Criteria; 
Industry Groups Meet with Agency
by Penny Stacey and Tara Taffera

The Department of Energy (DOE) sent a letter to stakeholders on October 9 announcing officially that it is beginning a criteria review and revision process for Energy Star^®- qualified doors, windows and skylights (see related story in the October issue of DWM magazine, page 20). 

The DOE says there are three reasons it is pursuing a criteria change:

1. Improving energy efficiency is a national priority; 

2. IECC 2003 and 2006 have prescriptive requirements for windows that are the same as Energy Star for either solar heat gain coefficient (SHGC) or U-factor in all states; 28 states have already adopted these codes;

3. Energy Star is meant to provide product differentiation, but Energy Star windows now make up more than 50 percent of the market. Energy Star has a target market share of 25 percent for all products. 

DOE is considering a variety of changes including:

• A substantially lower U-Factor in northern zones (initial target range: 0.20-0.30); 

• Capturing winter solar gain using a minimum SHGC in the north; 

• Substantially lowering SHGC in southern zones (initial target range: 0.20-0.30);

• Requiring IGU certification;

• Adding minimum VT criteria to ensure adequate light; 

• Bringing the Energy Star climate zones into closer alignment with the IECC 2006 climate zones;

• Dividing the northern zone in two corresponding to IECC Zones 5 and Zones 6+7; 

• Allowing SHGC/U-Factor trade-offs in both the north and south to expand range of products; 

• Exploring emerging technologies, such as dynamic glazings; 

• Establishing installation procedures to ensure performance; and 

• Maintaining display unit and product labeling. 

The DOE will publish the results of its analysis in December 2007. In addition, it plans to hold a meeting with stakeholders in February 2008 and will announce finalized criteria in March 2008. According to DOE, the earliest effective date of the new criteria would be January 1, 2009.

“DOE believes it is important to have the clearest understanding of the current performance capabilities and cost implications the new window criteria might have,” said the DOE’s Richard Karney. 

Thus the DOE offered the major industry associations the opportunity to meet with them to provide the consensus views of their members on the criteria parameters outlined in its initial letter to stakeholders. 

“To better understand how specific manufacturers might be affected we made similar offers to a leading manufacturers and a number of smaller manufacturers,” added Karney.

Several industry representatives spoke before the DOE on Friday, October 26, about the upcoming changes to the criteria for Energy Star windows. Among these representatives were Margaret Webb, executive director of the Insulating Glass Manufacturers Alliance (IGMA), John Lewis, technical director for the American Architectural Manufacturers Association (AAMA) and Mike Fischer representing the Window and Door Manufacturers Association (WDMA).

WDMA View
Fischer, along with some WDMA members, presented before the DOE concerning the best way to move the program forward and presented some specific recommendations including:

• Short-term revisions that capitalize on today’s best available windows, with an incremental increase in efficiency that will shift the program to the best of the best. 

• Increases in energy efficiency that require a shift in product technology should be carefully planned, and with target performance requirements that will allow the industry to work on product development and necessary investment in capital. WDMA believes a five-year period between the next two Energy Star revisions is the most appropriate balance. 

• WDMA believes that adoption and enforcement of existing model codes, particularly the 2006 International Energy Conservation Code will also move new construction ahead and result in reduced energy use. WDMA urges DOE to continue working with states on adoption of the most up-to-date energy codes.

• The most significant opportunity for energy savings through windows is in the replacement market. The inventory of single-pane windows in today’s housing stock represents almost half of all windows. Conversion of these single-pane windows will have the biggest impact on energy savings. 

WDMA urged the DOE to consider the balance between energy efficiency and the price points that will occur as a result of new window designs and technologies. 

“If the math doesn’t work, consumers will not have the motivation to replace their existing single-pane windows with Energy Star products,” said Fischer. “It is important that the program include incentives like the current tax rebate program if we are to have the greatest possible effect on energy consumption in the United States.”

He also told DWM magazine, “We have significant alignment on key issues. Not all details are resolved but overall we are confident that the voice of our members will be heard.”

AAMA View 
AAMA also represents the views of door and window manufacturers and they spoke before the DOE as well. Lewis said the DOE’s main interest was how AAMA members responded to the group’s initial letter to industry stakeholders about the upcoming changes to the program.

“We took the letter from the DOE [to stakeholders] and distributed it to the membership; we discussed this at length at our Orlando conference,” said Lewis. “Members generally agreed that updating the Energy Star requirements was something that needed to happen, but AAMA’s message to the DOE was that we wanted to be sure that this is done in kind of a phased approach, and that any of the changes to be implemented would be done in a manner so that a total re-design of the fenestration systems was not required.”

Overall, Lewis says the meeting was successful as far as he was concerned.

“[The DOE representatives] were quite interested in AAMA’s position, and we got some feedback as far as the timelines, and some of their thoughts on a phased-in approach,” he added. “We suggested some options that piqued their interest, and we’ll have to see where this goes. We stressed that we looked forward to working with DOE on the revised Energy Star program; I think it was a positive meeting.”

IGMA Weighs In 
Webb provided an overview for DOE on IG certification and the various roles it plays, and also presented information regarding IGMA’s 25-year field correlation study.

Along with representing IGMA, Webb also presented on behalf of the Insulating Glass Industry Durability Advisory Group (IGIDAG), a group that IGMA administers.

“They wanted an exact number of windows that are manufactured without certified insulating glass units [IGUs],” says Webb.

She says this number is one that hasn’t been discovered as far as she is aware.

“The National Fenestration Rating Council (NFRC) conducted a survey of their members. They estimated that 40 percent of manufacturers don’t purchase or fabricate certified IGUs. But [the survey] doesn’t consider volume of the manufacturers.”

She notes that most large window manufacturers do utilize certified IGUs, and if they’re the ones that responded to the survey that they do—then the percentage of total windows that utilize certified IGUs (as opposed to manufacturers) could be much higher.

“Typically we find large window manufacturers do use certified IGUs and the survey didn’t differentiate between residential and commercial,” Webb says. “Most of the large residential manufacturers do use certified IGUs, [but] smaller companies may not.”

Webb says the DOE was also looking for information about the failure rate of non-certified IGUs, but that there are currently no field studies available about non-certified IGUs.

Karney said the information presented by all parties was extremely valuable.

“This will enable us to propose new criteria that satisfy industry's need for longer time horizons and DOE’s goals of creating a zero energy home by 2020,” said Karney. 

Penny Stacey is assistant editor and Tara Taffera is editor/publisher of DWM. 

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