AAMA and WDMA Offer Recommendations for Energy Star Changes

November 21, 2008
Government

After extensive meetings with members and industry affiliates, the American Architectural Manufacturers Association and the Window & Door Manufacturers Association have issued a letter providing additional feedback on the most recent proposed Energy Star program criteria as they relate to fenestration products.

"It is our intention to collaborate with the Department of Energy to reduce energy consumption in existing and new homes; recommend increased enforcement of model energy codes; support the use of Energy Star as a means to communicate more energy-efficient choices for builders and homeowners and work with DOE to drive innovations and technologies that will further the development of affordable and efficient fenestration products," says John Lewis, AAMA's technical director.

The joint letter submitted by AAMA and WDMA notes that members and staff of both organizations have logged hundreds of hours examining DOE's analysis, and in putting together their recommendations, the two groups have sets forth a number of guiding principles:

  •  The Energy Star program should focus on that which will yield the greatest impact. Reducing the heat gain associated with the existing stock of single-pane products in the U.S. represents the single-greatest opportunity to decrease energy use.
  • Affordability is critically important. Program parameters should help achieve the desired consumer-driven outcome (i.e., the purchase of reasonably-performance fenestration products).
  • Return-on-investment matters. Energy Star product purchases must translate into immediate reductions of consumer utility bill savings.
  • Daylighting and ventilation are important. Continued reductions in SHGC requirements will result in unacceptably low visible light transmittance.
  • Simplicity trumps complexity. All other things being equal, a simpler program understood by the consumer is superior to an overly-complex program.

Closely related to affordability is the delivery of energy savings; such savings must translate into immediate reductions of consumer utility expenditures if the criteria are intended to drive consumer behavior. The ENERGY STAR requirements should provide a lower limit to SHGC coefficients in order to maintain the performance of glazing packages and provide an acceptable value for Visible Transmittance (VT). Different approaches that save equivalent energy should be closely scrutinized. In similar fashion, AAMA stressed the proposed standard must not exclude some products which would have equivalent or lower life-cycle energy and environmental impacts.

As for specific recommendations, the AAMA/WDMA letter asks that the first phase of changes be rolled out Jan. 1, 2010 and the second phase scheduled for Jan. 1, 2015. The groups also recommend the use of four climate zones for North America that are designed to correspond with zones set forth in the International Energy Conservation Code.

DOE's proposed criteria includes only one set of swing door requirements. AAMA and WDMA suggest that sliding doors be allowed to follow the same criteria. As for the window requirements, the groups ask that if a product meets the requirements without grids, it should be acceptable with grids, as they have a negligible effect on performance.

The letter concludes with a request that DOE conduct additional analysis of alternatives to the proposed Energy Star program before finalizing the criteria. "AAMA and WDMA would like the opportunity to provide input to the analysis and to the selection of window criteria used as the basis of the analysis," it is also noted.

AAMA also sent a separate letter to DOE with recommendations that focused on the importance of accepting equivalent products of varying U-factor and SHGC pairings, clarification regarding the current Energ Star program as a residential program and allowances for alternate SHGC and U-factor values for impact-rated products. “A preliminary analysis of alternate U-factor and solar heat gain coefficient (SHGC) criteria has shown promising results and is consistent with one of AAMA’s guiding principles: ‘Equivalent alternatives are just that—equivalent.’" says Lewis. "We see no justification for eliminating manufacturing options which provide fenestration manufacturers with viable alternatives to abandoning current production methods, at great cost, for little if any increase in the annual energy savings realized.”

The AAMA Skylight Council also submitted comments related to the skylight-specific criteria.

DOE information about criteria changes to the Energy Star program, as well as links to submitted comments can be found on the Energy Star Web site.