Finally Final! 
DOE Releases Final Revised Criteria for Energy Star®
by Tara Taffera and Penny Stacey

The Department of Energy released the long-awaited final, new Energy Star criteria on April 7—just a few weeks after the draft had been released on March 11. Though comments were reviewed during that time, some still feel the final decision was made too quickly.

“Overall, given the short time between March 11 and April 7 obviously the DOE wasn’t going to take a lot of time with analysis of the comments. We knew there wasn’t going to be a large-scale shift,” says Jeff Lowinski, vice president of advocacy and technical services for the Window and Door Manufacturers Association. Chuck Anderson, codes and industry affairs manager for the American Architectural Manufacturers Association (AAMA), says the final criteria was also what he expected. 

But Lowinski was pleased that the DOE did consider many of the WDMA’s comments. Following are some of his reactions to the final criteria:
• He notes that no changes were made to solar heat gain coefficient or U-values since the last draft. “We wanted them shifted a bit,” he says.
• “A number of issues still have to be considered and that will be done for phase 2.”
• DOE will continue to allow tubular daylighting devices to be rated. “All doors will be qualified according to the door table based on our recommendation,” says Lowinski. 
• “The shift to four zones is a positive move,” says Lowinski.
• “We wish they had considered the proposal we made in November 2008 which was to have a North American map which would have brought the U.S. and Canadian Energy Star programs more in line with one another,” says Lowinski.

Lowinski also notes that implementation issues still have to be addressed and those haven’t been announced yet.

As far as phase 2, Lowinski says, “We are ready to work with DOE on phase 2 starting today. Our members’ companies want to get those numbers solidified.” Lowinski says the DOE will start this process later in the 2009 calendar year but adds, “We have petitioned them to start ASAP.”

While Lowinski says Phase 1 is the transition phase, “Phase 2 is where product re-engineering will come in,” which is why he says starting this process early is crucial. While WDMA is already looking forward to Phase 2, the American Architectural Manufacturers Association (AAMA) supports a delayed implementation of Phase 1, according to its president, Richard Walker.

“AAMA members are still concerned about the timing of the new criteria and continue to ask to delay the implementation date,” says Walker. “Due to severe economic conditions and confusion with the stimulus tax credit, there is consensus that the implementation should be delayed until the tax credit is out of play.”

Anderson furthers this sentiment, speaking to the confusion created between Energy Star and the tax credits.

“As an industry, our members understand that DOE’s goal was to set the criteria to encourage utilization of the ‘cream of the crop’ of commercially available products. Historically, incentive rebates, tax credits and low-interest loan programs have been tied to these products, making Energy Star a phenomenal marketing tool to promote the most energy efficient windows, doors and skylights,” he says. “It was very unfortunate that our nation’s Congress decided to override the multi-billion dollar federal program, Energy Star, and create separate criteria as an incentive, especially given the timing of the stimulus package on virtually the eve of the criteria announcement.”  

Window manufacturers such as Gorell Windows and Doors are pleased with the final Energy Star criteria. “The solar heat gain coefficient (SHGC) numbers are more applicable with Energy Star than they are with the .30/.30 tax credit numbers,” says Tyson Schwartz, vice president of sales and marketing for Gorell. “With the SHGC numbers Energy Star has released, the numbers are much more applicable or customized for each particular region.”

“This update to the energy limits and climate zones delivers consumers a balance of value and performance,” says Ray Garries, JELD-WEN external affairs corporate manager. “The new 2010 program will increase energy efficiency 18 percent nationally, and 20 percent over current standards in the North Central and Southern climate zones.”

Although these manufacturers are pleased, Schwartz does have a suggestion for DOE to improve the program even further.

“Energy Star should push for better overall window performance (U-value) in the southern climates,” he says. “Gorell is one of the few companies that markets and sells products in the southern climates that also manufactures a window that is both hurricane-rated and boasts high energy efficiency. Our point is, you don’t have to be just an impact window or just an energy-efficient window, homeowners can have both benefits in one window.”

Other manufacturers such as Thermal Windows aren’t as pleased with the requirements. “Of course we are in favor of energy independence for our country, but I doubt if you could ever get an industry-wide consensus regarding standards or zone layout for the revised Energy Starr program,” says Dennis Lane, president. “Our country has such a vast difference in climates that it is unreasonable to draw a line indicating that on one side, you need a 0.60 U-factor and a few miles away, in some cases to the north, east or west, the criteria is a 0.35 U-factor. Therefore, we would have to express disappointment with the zones established.”

Lane adds that the Energy Star program continues to favor vinyl windows while disregarding air infiltration and long-term performance of the product. However, his company, which primarily manufactures aluminum, does manufacture vinyl products that will meet the 2010 residential criteria and continues to develop commercial thermally broken aluminum designs to address the change in residential and “no doubt future commercial specifications,” says Lane. 

“More evident than ever, as the fenestration market rapidly changes, it is essential that manufacturers change along with them,” he adds.

DOE’s Karney Gives a Few Insights Into Energy Star, Phase Two 

Richard Karney, program manager for the Department of Energy’s Energy Star program, spoke before members of the Northeast Window and Door Association (NWDA) on April 23 as part of its Educational Seminar and Fly-In held in Washington, D.C. He offered some insights regarding Energy Star including a few hints at what the program may look at for the yet-to-be-finalized Phase 2 section of the program. Karney first addressed the final criteria for Phase 1, and reiterated what the DOE has been saying throughout this process.

“Energy Star has to provide meaningful differentiation,” he says. “The label doesn’t mean anything anymore.”

According to Karney, approximately 60 percent of new construction windows qualify for Energy Star while 90 percent qualify on the remodeling side.

“The label no longer demonstrates superior efficiency.”

According to Karney, the new Energy Star criteria will add up to 9.21 trillion BTUs in annual energy savings.

“I’m quite pleased about the energy that will be saved through the new criteria,” says Karney.

Giving some insights into the final criteria, he says the DOE didn’t want to go higher than a .32 U factor in anticipation of possible code changes in 2012. According to Karney, Energy Star’s goal is to exceed code.

Although the new criteria goes into effect on January 4, 2010, and the transition period ends March 31, 2010, Karney says he’d like to see these windows produced right away.

“I’d like to see manufacturers start making these windows now,” he says.

Phase 2 of Energy Star has not yet been finalized and the DOE won’t look at that phase until the fall of this year.

He says Phase 2 objectives include addressing issues raised during phase one. This includes looking at exceptions for products installed in high-altitude areas.

“I felt uncomfortable making that exception [in Phase 1] but it is something we will look at,” he says.

Manufacturers are also asking that DOE consider life cycle analysis and embodied energy considerations in Phase 2, as well as credits for recycling. Karney says all of this will be considered in the second phase, though he admits, “I don’t know where it will lead us.”

Karney also says that some individuals have made comments requesting a separate program for new construction and remodeling. “Maybe we will look at this as well,” he says.

As far as other new initiatives, Karney says the DOE is looking at working with Ducker Research to collect door and window shipment data.

“That shipment data will help us [collect data] from an overall energy savings perspective,” he says.

And a commercial program for Energy Star could be on the horizon as well.

“We are looking seriously at a commercial windows program,” says Karney. “Am I waiting for the National Fenestration Rating Council to get its Component Modeling Approach in use? Yes.” He adds that DOE is waiting for funding as well.

“I’ve always said that a commercial program is a totally different beast than residential.”

He also added, “Marc [LaFrance from DOE] and I joke that on the commercial side we should just mandate low-E. The industry tap-dances around that.”

Energy Star—A Look at the Key Provisions

The Department of Energy (DOE) has released the final revised criteria for Energy Star-qualified doors, windows and skylights. Following is a look at key portions of the program. 

Approved Criteria 

The final document includes the following aspects:

1. Phased implementation. According to the DOE, stakeholders generally supported postponing finalization of Phase 2 criteria. “Since it is still three to four years until the likely effective date for these criteria, DOE is deferring finalization of these criteria to allow for additional data collection and analysis,” wrote Rich Karney, program manager. “The Department will begin research on a Phase 2 proposal in late [calendar year] 2009.” 

2. Revised four-zone climate zone map. The revised map includes four climate zones and geography-based zone names; the map included in the March 11 release of the criteria remains.

3. Category shift for sliding glass doors. Sliding glass doors will now be included in the door category for the criteria, rather than the windows category. “Stakeholders suggested it would be easier for consumers to understand the separate criteria for doors if they applied to all doors and left only windows in the windows category,” wrote Karney. “The Department’s analysis showed that no significant savings would be lost by transferring sliding glass doors to the door category. 

4. Revised criteria. DOE has retained the criteria levels and limited tradeoffs from the Revised Draft Report in the North. DOE had adjusted the U-factor for doors in the < ½-lite category; in addition, DOE has set the SHGC for doors to match the International Energy Conservation Code (IECC). The skylight criteria listed in the original draft will be retained, based on IECC levels.

5. Tubular Daylighting Devices. While DOE says some stakeholders had suggested that tubular daylighting devices be removed from the program, it decided to continue to include these under the criteria for doors, windows and skylights, “under the condition that manufacturers provide documentation showing the product U-factors are rated under NFRC’s computer simulation procedure.”

6. Insulating Glass (IG) certification. DOE will require IG certification for Energy Star-qualified doors, windows and skylights as soon as NFRC makes this certification mandatory, expected in July 2010. 

7. Shipment data requirement. While stakeholders supported DOE’s potential solution to the requirement for reporting product shipment data, the final draft noted that this will help DOE measure the impact of the program. DOE is still discussing whether this method is plausible or not. The DOE plans to make a final decision on this before Ducker Research conducts its next study of the door and window market.

Proposals that DOE Rejected
DOE rejected the following possibilities for the program:

1. Exemptions for specialized products. Several industry representatives suggested that DOE allow an exception to the U-factor values for high-altitude products, while others suggested separate criteria for high-impact products; DOE plans to compile data on these topics and analyze it to determine if it should be used in the Phase 2 proposal.

2. Reference products for building packages. According to the announcement, some industry representatives had suggested that a “package” of windows be allowed when equipped with a single glass package but various operator types. The DOE has rejected this suggestion, noting it could cause consumers to “mistakenly believe all windows they purchased qualified for applicable incentives offered in their region.”

3. Elimination of the map on the product label. Karney notes that removing the climate zone map from the product label “would compromise the effectiveness of the label for consumers.”

4. Air infiltration requirement. While some suggested that there be a mandatory air infiltration requirement, DOE has not included this in the new criteria, based on saying there’s not a consistent way to evaluate air infiltration performance and for the consumer to verify performance claims, according to the announcement.

5. CPD number and code readjustment requirements. DOE has eliminated these from the final criteria. 

6. Orientation, shading and glazing requirements. DOE said that setting this was not feasible because it deals with the installation of the windows and Energy Star typically is aimed at the replacement market “where orientation and shading are predetermined.” “The optimal way to capitalize on these factors is to educate consumers on their benefits,” says Karney. 

The revised Energy Star program requirements for doors, windows and skylights will go into effect January 4, 2010. A transitionary period will run through March 31, 2010. 

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

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