Volume 9, Issue 8 - September 2008

The Countdown
Stakeholders Travel to Nation’s Capitol
to Give Feedback on New ENERGY STAR® Criteria

When door, window and skylight manufacturers traveled to Washington, D.C., on August 13 for the ENERGY STAR stakeholder meeting to provide feedback on the revised draft criteria for the program, one thing was clear. Many are concerned about how this new criteria could affect their products and their businesses.

John Lewis, the technical director for the American Architectural Manufacturers Association (AAMA), even suggested that the criteria could result in less energy savings than are now being achieved from energy-efficient windows, due to the price increases that will result from the revisions.

“It very well could be that, if we put in the ENERGY STAR criteria in Phase 2 with the marginal cost increases, it’s possible that the product will cost so much that consumers won’t buy it and we’ll save less energy and will lose ground,” he said.

Lewis and others in attendance had the opportunity not only to express such concerns, but also to hear a panel of speakers including ENERGY STAR program manager Rich Karney; Stephen Bickel, Alice Dasek, Jordan Kelso and Emily Zachery of D & R International Ltd.; and Stephen Selkowitz and Josh Apte of Lawrence Berkeley National Laboratory.

Much of the DOE’s presentation attempted to explain the reasoning behind the new draft criteria.

“The market share of ENERGY STAR windows was around 50 percent in 2007,” Karney explained. “The ENERGY STAR label must provide some differentiation.”

Likewise, ENERGY STAR criteria matches that of the codes in some locales.

“We wanted to create a climate zone map that would enable us to meet or beat codes in all parts of the country,” Bickel added.

In addition, the DOE is working to align the ENERGY STAR criteria more closely with that of the International Energy Conservation Code (IECC).

90 Days Needed? Timing—both of the public comment period for the draft, which began a day after the meeting— August 14—and was scheduled to run through September 14, 2008—and on the phase-in of the new criteria seemed to be the overarching concern of those in attendance.

Lewis was the first to speak— and the first of many to voice this concern.

“We’re asking for a 90-day review time,” he said.

JELD-WEN’s Ray Garries echoed this concern, as did nearly every other industry representative who spoke.

“The 30-day comment period is nowhere near enough,” added Garries.

Mike Fischer, director of codes and regulatory compliance for the Window and Door Manufacturers Association (WDMA), also noted that if the goal is to align ENERGY STAR more closely with the IECC, it would make sense to extend the public comment period further—since the 2008 IECC final action hearings are scheduled for September 14-23.

The phase-in of the criteria is also a concern for some. The first phase of the criteria could be implemented as early as August 3, 2009, according to Karney, and Phase 2 is scheduled to take effect on January 1, 2013.

Fischer suggested that Phase 1 be implemented in the winter, since summer typically is a busy season for manufacturers, and that Phase 2 be implemented on January 20, 2015—two years later than scheduled.

“For Phase 2, a tremendous amount of testing will need to be done,” Fischer cautioned.

A Simple Request
Trade-offs do assist in offering customers lots of options, but several industry representatives still insisted the simpler the criteria can be, the easier it is for manufacturers to help their customers (and their customers’ customers) understand the value of an ENERGY STAR label, and what it stands for.

“I think the overarching desire of the members is to have a simple program,” said Lewis. Specifically, he suggested DOE match its current map to that of the IECC, and he suggested that the new ES5a is more of a “local” zone, and a tough direction in which to head.

Nils Petermann of the Alliance to Save Energy/Efficient Windows Collaborative mentioned that one consideration might be finding a way to educate consumers about what SHGCs are and mean to them, or to even rank them as high, medium and low. Most consumers might not know what the number means, but “what they might know is whether they want a high or low solar heat gain,” Petermann said.

Fischer said WDMA members are hoping for a simpler division of climate zones.

“We think the zones are overly and unnecessarily complicated,” he said. “We’re trying to get simplicity.” Garries said he finds this is what his staff is looking for, too.

“My marketing people keep telling me this needs to be a simple process,” he said.

A New Approach
Culp suggested the DOE consider heading in an entirely new direction with the ENERGY STAR program.

“We’d like ENERGY STAR to think a little broader,” he said. “In ENERGY STAR Zones 1 and 5 the driving criteria (U-factors] pushes consumers away from green materials like aluminum and wood.”

On behalf of the AEC, Culp proposed that recycled content be recognized in ENERGY STAR criteria, and that credit be given toward meeting U-factor requirements based on the use of recycled materials.

“As you increase the recycled content you increase the embodied energy savings,” Culp added.

One in Favor
One manufacturer representative spoke entirely in favor of the new criteria. In fact, he actually scolded others in attendance for their fears.

“[This meeting] has been very cordial but the reaction has been very shameful,” said Brandon Tinianov of Serious Materials.

“Code is the bare minimum,” he said, “[and] there are people in the room who are saying ‘let’s be at code for another five or seven years.’” And, the cost concerns? Tinianov doesn’t seem to think this will be an issue.

“[When you’re looking at new construction,] the cost is wrapped up in a mortgage and [when] you balance that with energy savings on a month to month basis, and you see savings right away,” he said.

“They’ve got a direction they want to go in, the technology’s there, [and] the money’s there,” Tinianov added.

A Grateful Audience
While many varied opinions, along with other suggestions and criticisms were heard, most were grateful for the opportunity to speak.

“Thanks for the way you guys have put this system together here,” said Garries. It’s much better than someone in an office somewhere handing [the criteria] down and saying ‘this is the way it’s going to be.’”

“I had questions after my first reading [of the criteria], and a lot of my questions were answered [during the meeting],” said a representative of Southwall Industries.

“I think we all have a better understanding of the time and work that has gone into this,” added Lewis, after hearing DOE’s presentation.

At press time, DOE expected to release its final criteria at some point during the fall of 2008.


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