EPA, Industry Reach Compromise on Final Energy Star V6 Skylight Criteria
March 17, 2014
| Codes & Standards
After several rounds of revisions and stakeholder feedback, the Environmental Protection Agency issued the final criteria for Energy Star Version 6.0 for Windows, Doors and Skylights this January. It traces a two-year path of give-and-take between the EPA and the fenestration industry, culminating in a challenging, yet―compared to the initial draft―reasonable compromise.
While the window criteria usually get the most attention, it is instructive to look at what Energy Star Version 6.0 means for skylights as well. EPA’s rationale for tightening its criteria is to provide greater market differentiation and ensure that Energy Star stays ahead of residential energy codes. As of July 2012, EPA said the market share of Version 5.0-qualified skylights was 70 percent.
In its stakeholder commentary to the final draft last fall, AAMA said that “the proposed 0.48 U-factor in both the Northern and North-Central climate zones disqualified approximately 80 percent of double-pane curb-mount skylights available today. A slight increase to a 0.50 U-factor [would maintain] a 10 percent stringency improvement over the 2012 IECC values and allow the number of eligible products within the CPD to double from 6 percent to 12 percent while carrying only an equivalent or slightly higher incremental cost increase.”
EPA has agreed, stating that according to its Products Available for Sale database, “this change will triple the number of product models available in the Northern Zone,” based on improved product availability for both curb- and deck-mount skylights.
EPA also has upwardly revised the U-factor maximum for skylights in the North-Central and South-Central zones to 0.53, representing a trade-off between AAMA’s recommended factors of 0.55 maximum for both zones. This will allow more bestselling curb-mount products to qualify in the Northern zone and venting curb-mount products to qualify in the North-Central and South-Central zones, thereby improving product availability. According to the public comments received on the final draft, these products are bestsellers under the current specification, which means no incremental cost over Version 5.0.
EPA further asserts that the change “…will more than quadruple the number of available product models in the North-Central zone. In addition, aligning the South-Central U-factor maximum with the U-factor maximum in the North-Central zone simplifies the specification, allowing manufacturers to qualify a single product over a larger geographic area.”
EPA settled on a final Southern zone U-factor value of <0.60. This decision also was a victory for the industry, as the initial framework document suggested that EPA might go as low as 0.55 during this criteria revision.
These compromises are a huge victory for skylight manufacturers!
No Dice on Raising SHGC
Industry comments were not as persuasive for Solar Heat Gain Coefficient. AAMA pushed for a maximum SHGC of 0.30 in Southern and South-Central zones, but the EPA did not budge, setting SHGC maximums for the Southern and South Central zones at 0.28. The agency noted that the vast majority of skylights in the Products Available for Sale database have SHGCs of 0.35 or less, and a significant number have an SHGC of 0.25 or less.
TDD Classification Remains Unchanged
While AAMA continues to recommend that tubular daylighting devices be individually categorized within the Energy Star program to highlight their differing performance attributes and properly credit their design and function, the EPA did not establish separate criteria for these products within the final Version 6.0 requirements. The EPA has, however, stated that after results from the new test method [NFRC 203] are available for review, it will consider setting separate criteria for TDDs in future revisions.
In response to the most requested change from stakeholders―more time―EPA did extend the implementation date for skylights by one year to January 1, 2015. This is expected to help improve product availability and reduce transition costs while aligning with the Canadian Energy Star Window, Door and Skylight specification revision timeline.
The EPA announced that it will begin working with stakeholders in the second half of 2014 to evaluate the criteria-revision process. As with all code and regulatory matters, Energy Star and related programs are constantly evolving, and AAMA is committed to staying ahead of the curve on behalf of manufacturers of fenestration products of all types and materials.