Manufacturers Prepare for Energy Star Version 6.0
While window and door manufacturers move forward in their efforts to meet the Energy Star for Windows, Doors, and Skylights Version 6.0 criteria, significant concerns still surround the program’s proposed product requirements and an early 2014 implementation date.
Topping the list is the concern that the proposed U-factor for the Northern zone would drive the cost of Energy Star products beyond the affordability of the average consumer. Currently, the U-factor requirement for the Northern zone is 0.30. The Environmental Protection Agency’s Version 6.0 calls for a U-factor of 0.27, which some manufacturers think will require costly window and door redesigns.
“The challenge is going to be in the Northern zone,” says Bill Tindell, director of product development, Windsor Windows & Doors. “To achieve that may require triple-glazed windows, and the typical sash depth may not accommodate that. We are also looking at thermal breaks in the frame or the sash to potentially reduce the cold points in the design.”
“The proposed specifications will be especially problematic for windows and skylights produced for the Northern zone markets,” agrees Jeffrey Inks, vice president of codes and regulatory affairs for the Window & Door Manufacturers Association. “The proposed criteria, if approved, will force many manufacturers into triple-pane designs, requiring them to either redesign their windows to accommodate the larger triple-pane unit or find alternate [and expensive] ways to accommodate triple-pane units within the existing chassis designs.”
“The EPA’s cost estimates are based on double-pane windows, but we think that triple-pane windows will need to be used more frequently in order to meet the criteria than EPA believes,” Inks says. Frames used for double-pane windows often aren’t deep enough to accommodate triple-pane glass. (See sidebar below for more information on industry efforts to address the concerns regading the new criteria.)
“A redesign of the frame from scratch is very expensive and can take upwards of a year,” says Ric Jackson, director of external affairs at Quanex Building Products Corp. “There are tooling costs for fabrication, and the costs for process development, engineering, manufacturing changes and the challenge of dealing with legacy product.”
There are shortcuts a company can take to avoid a redesign, but most of them are costly, he says. “If you’ve exhausted the possibilities from using different spacers and glass coatings, the choices get more difficult and more expensive—using a foam filling for older, hollow frames or switching to an exotic gas like krypton or blends of argon and krypton,” Jackson explains.
Some manufacturers are concerned such upgrades and redesigns could put the price of those windows out of homeowners’ reach.
“If you move the criteria forward too fast, you damage affordability,” especially in the Northern zone, says Ray Garries, government affairs manager at Jeld-Wen Inc. “You want to make sure you have a mass market Energy Star product that is affordable. Niche products do not, generally, lend themselves to cost effectiveness. Real affordability must remain the primary driver of the Energy Star program.”
Kevin Vilhauer, manager of testing and certification for Milgard Windows and Doors, Tacoma, Wash., concurs. “The problem is the Northern zone requirements, because typically you need to change the glass thickness [to meet that criteria], and that involves redesigning the frame and the sash,” he says. Yet, “outside of the Northern zone, the criteria, for the most part, is fairly reachable.”
Indeed, some manufacturers consider even the proposed Northern zone numbers as reachable and support adoption of the proposed Energy Star Version 6.0. “Energy Star has developed a sound strategy in creating consumer awareness over the years. The Energy Star logo has become widely recognized and accepted within the industry and with consumers," says Tyson Schwartz, vice president of sales and marketing at Soft-Lite LLC. "Now, by my estimation, Energy Star is trying to make their brand more valuable by proposing new higher energy standards that are differentiated by zone. This is consistent with its strategy over the years.”
Meanwhile, the vinyl window manufacturer has developed a long-term strategy that aligns with Energy Star’s latest proposals, Schwartz says. "We have many different windows and glass packages (dual glass and triple glass) that will meet the Energy Star criteria, and these windows can reach the consumer at an affordable price.”
Soft-Lite is by no means alone in supporting the new criteria. “MI Windows & Doors is 100 percent in favor of the new Energy Star Version 6.0 criteria," says Patrick Schutte, director of sales and marketing. "We have made a sizable investment in new manufacturing technology and products to meet and exceed the new higher standards. MIWD believes that it’s not only in the best interests of our customers to have the most energy efficient windows and doors possible, but it’s also in the strategic interest of our country to reduce our dependence on foreign energy through conservation. Delaying the implementation of the new standards will be a disservice to homeowners who are seeking guidance when they look for energy efficient windows and doors.”
At press time, the EPA still had a target implementation date of January 1, 2014, for Energy Star for Windows, Doors, and Skylights Version 6.0. However, the release date for the final criteria was less clear. In March 2013, the agency reported it needed additional time to review and
respond to the comments received on the Draft 2 specification and revised skylight criteria. At press time, a revised timeline was not yet available, raising concerns among manufacturers as to whether or not they would have time to make product changes before Version
6.0 goes into effect.
“EPA plans to keep stakeholders informed of its process on the criteria revision,” says Doug Anderson, program manager, Energy Star for Windows, Doors, and Skylights, in the March letter. “We are committed to ensuring that our partners have adequate time to respond to the final Version 6.0 specification and will make adjustments to the implementation schedule if needed.”
“The biggest challenge for manufacturers that do not have a NFRC [National Fenestration Rating Council] certified listing will be getting product through the labs and testing in time,” says Quanex's Jackson. “We all know that putting a new window system together from scratch is a major project and takes more time than we have left before January 1, 2014.”
Tindell agrees: “The planned timeframe—eight to nine months—is probably not long enough to do product development because it’s difficult to make hard and fast specifications until you lock in the final numbers. That’s a very tight window.” There is also the task of pulling all the literature together for dealers and stores.
“You have to do the labeling, put together the informational brochures and develop all the point-of-purchase literature,” Garries says. “It’s a challenge for dealers, too, as they have a lot of people to train.”
Dealers need time to get ready for the next generation of Energy Star products, manufacturers say. “They will have to know about what glazing options to use, and manufacturers will have to simplify that task for them by grouping options the way automobile manufacturers do,” Milgard's Vilhauer points out. “Dealers will also have to learn what products fit each climate zone. Knowing the U-factor and SHGC options of each of those zones can be overwhelming.”
PRODUCT LINE CHANGES
Many companies have made changes or plan to make changes to their product lines in advance of the new Energy Star final criteria, so they are ready from both a manufacturing and marketing standpoint—and so dealers and the rest of the supply chain have time to prepare.
“We don’t get the sense that there will be many changes from the second draft version that was published in January,” says Windsor’s Tindell. “We are proceeding as if it’s going to be a January 1 implementation date. We are devoting a lot of resources to it—evaluating designs and being diligent from a design standpoint—because if your products don’t meet Energy Star criteria, you are on the outside looking in, in the marketplace. As soon as everything is set, we’ll pull the trigger.”
Simonton Windows, Columbus, Ohio, is taking a similar approach. “Our product development and design teams are evaluating what changes may need to be made to our vinyl new construction and replacement windows to meet the new guidelines,” says John Stark, channel manager for short line distribution, Simonton Windows. “Our company plans to meet the new Energy Star criteria.”
“Some of the changes [we need to make] for our product lines are already in motion,” says Jeld-Wen's Garries. “We have had to take some gambles based on our best guess of what the final criteria will be because our customers will want those products on day one. It’s a lot of work in engineering, testing, manufacturing, documentation and labeling,” he says. “We have 280 different product lines.”
The exact changes companies will have to make to meet the new Energy Star criteria will vary depending on their product offerings. It could require changes to the frame, sash, spacer, in-fill or glass package—or some combination of the above.
Some door manufacturers are facing much the same dilemma as window producers in terms of product redesign and the associated costs. “You have your glass, door slab, and frame to work with,” says Chris Nolt, testing and certification engineer for ProVia. “The easy solution is to go to a triple-glazed window. But the glass is thicker, and you have to adjust the doorlite trim/door slab, or design a new product with more efficient framing. That takes a considerable upgrade in equipment, and time to implement.”
Other door makers don't see the more stringent U-factor numbers as a problem. “We have a high thermal performance urethane core in all of our doors, so it will not be a problem to meet the new criteria,” says Steve Jasperson, code and regulatory compliance manager for Therma-Tru Corp., Maumee, Ohio. “Most door manufacturers that use high thermal performance cores will only need to use low-E insulating glass—which is readily available in the marketplace—to achieve implementation [and] will not need to change their products significantly to meet the 2014 Energy Star criteria.”
“In some cases, a single change could get you over the line,” agrees Jackson. For companies that already have a qualifying window under Energy Star Version 5.0, they could, for example, move from a more conductive insulating glass spacer to a better insulating spacer, or switch from a low-E glass with low solar heat gain to a glass with a higher SHGC, he says.
For others, “the potential impact on the supply chain is broad,” Inks reports. “Transitioning to new requirements touches every aspect of a manufacturer’s business: design, engineering, manufacturing, certification and marketing...and working with dealers, consumers and their supply chain.”
Some window and door manufacturers are taking this opportunity to look even farther beyond Energy Star Version 6.0, believing it behooves their companies to prepare now for the next version. “We have already begun some of the changes for 6.0, anticipating what the final changes will be,” says Milgard’s Vilhauer. “But we’re also planning right now for the next generation, 7.0, and what we need to do to be prepared for that in terms of redesign and major design changes.”
“Design for flexibility is where companies are going” as opposed to the previous model of designing to specific criteria, Vilhauer suggests. “Companies want a lot more flexibility built into the product so they can hit more stringent regulations at less cost,” he says. One example: designing extruded profiles that can be foam-filled, and designing profiles that can meet “structural and thermal requirements, and also accommodate different glass options.”
As standards continue to evolve, he says Milgard already has changed its approach to glass options. “We used to go with glass options you could use in multiple products,” Vilhauer explains. “Now, we’re using more regional glass options.”
Jackson also recommends companies look ahead to Version 7.0. “I think the real issue window manufacturers may want to consider is: Do they make the smallest possible change this time but potentially risk a complete system overhaul when Version 7 is announced? Or do they consider upgrading their frame design now and have the flexibility to adapt for future versions?”
Both the Window and Door Manufacturers Association and the American Architectural Manufacturers Association have been working with the EPA to address perceived problems with the Energy Star Version 6.0 proposed criteria and implementation date.
“Some concerns we had raised were not adequately addressed in Draft 2, so we decided we needed to be more assertive than the first time,” says Jeffrey Inks of WDMA. “So we did that with a 33-page letter and followed that up with a meeting with senior-level officials.” Among WDMA's concerns: the need to push the planned implementation date of Jan. 1, 2014, back one year, and the possibility the criteria for the Northern zone will make Energy Star products unaffordable for most consumers.
“Our really big concern is that EPA take the time to fully assess and respond to the concerns” of the industry, Inks says. “It is more important that they do that than implement something by an artificial date.” WDMA appreciates changes EPA made in Draft 2 related to air leakage, installation instructions, and door solar heat gain, he continues. "We believe these changes are significant improvements and will make the new criteria more rigorous and easier to implement.”
But, at the same time, he argues that “it would be inappropriate and misguided for EPA to finalize the Version 6.0 specifications as proposed” because the agency has yet to address industry concerns in several key areas. Specifically, he says WDMA is concerned with what
EPA claims to be a reasonable payback time for both manufacturers and consumers on Energy Star windows, what the industry believes are low estimates for the costs manufacturers will incur to meet the new criteria—particularly in the Northern zone—and EPA’s exclusion of
triple-pane windows from its cost-effectiveness analysis.
The American Architectural Manufacturers Association has also raised concerns regarding the proposed requirements, stating the EPA’s most recent draft proposal of Version 6.0 would lead to higher-cost products that offer only incremental benefits. Instead, the association suggests EPA should “move ahead with a focus solely on consumer education while maintaining the Energy Star label on high-performing Version 5.0 products.”
At a time when there are still “tumultuous economic market restraints, the EPA is following a timeline to modify Energy Star criteria that will cost manufacturers tens of millions to implement … and leave the homeowner with fewer and more expensive window choices,” the association states. “A move to increase the cost of compliant products at this time will serve only to broaden the wedge between homeowners and the
opportunity to retrofit their homes.”
“Fenestration manufacturers have asked the EPA to recognize the fragile state of both the industry and the U.S. homeowner,” AAMA continues. “Introducing Version 6.0 at this time of severe economic duress on industry and consumers may serve to reverse the intent of the Energy
Star program … .”
NEW COALITION FORMED
In addition to WDMA and AAMA, the Coalition for Home Energy Efficiency has been formed by industry manufacturers and others, and launched a consumer education campaign in mid-April focused on a Change.org petition to the President and Congress opposing “proposed changes to the Energy Star program that would price Energy Star-rated windows and skylights out of reach for average consumers and make affordable energy-efficient options harder to identify.”
The petition, which had received more than 15,000 signatures as of mid-April, says the proposed Version 6.0 of the Energy Star criteria for windows, doors, and skylights breaks with the mission of the program. “Rather than offering cost-effective, energy-efficient options for consumers, the proposed new Energy Star standards would increase the cost of efficient products too much,” the petition states. “As a result, in most parts of the U.S., it would take consumers many years to recoup their investment and begin seeing real cost savings.”