Industry Offers Feedback to Energy Star Changes
Meetings & Events
Washington, D.C.—The Energy Star label for windows, doors and skylights needs to serve as a real “differentiator” in the market, according to Richard Karney, program manager for the Department of Energy. “Not all products will be Energy Star,” he also emphasized as he welcomed about 100 industry representatives and others in a forum on the proposed changes to the Energy Star program on Wednesday, August 13.
Designed to gather feedback, the most common response to the new criteria is that more time is needed to study the changes and that the official public comment period should be extended-something that DOE has since done. Manufacturers also urged greater consideration be given to simplification and affordability.
The daylong meeting began with a review of the new Energy Star requirements and the rationale behind them. Karney noted that although DOE initially considered a three-phase approach to tightening the criteria, it opted for two based on industry input. “It made sense not to overburden manufacturers by making them change production processes twice,” he said.
With the first set of criteria, set to go in effect August 2009 at the earliest, the goal is to meet or beat the 2009 International Energy Conservation Code without requiring major product redesign, he continued. “It’s in the second phase that we really want to beef up the program and give manufacturers some lead time to do it,” Karney added.
Stephen Bickel of D&R International, which administers the Energy Star program for DOE, suggested that the phase one criteria “should be able to be met with products that are already available or with an upgraded glass package.” The one exception, he noted, was in ES1—the southernmost Energy Star climate zone—where new U-factor requirements in the Energy Star criteria will match the more stringent U-factor requirements expected to be in the 2009 International Energy Conservation Code. He predicted the first round of changes will produce a modest decline in Energy Star market share, except in the South.
The second round of Energy Star criteria changes are “much more stringent,” Bickel continued, noting it will be then that, “We reestablish Energy Star as a differentiator. There will be a price premium for Energy Star—and a decline in Energy Star market share. “The proposed criteria will require redesigned products in the two Northernmost zones and overall, he predicted, manufacturers will need to offer distinct product lines for the North and South. Pointing to some of the phase two U-factor criteria in the Northern zones, Bickel noted some windows—all triple-pane—already qualify. The use of triple-glazing adds about 15 percent to the marginal cost of these products, he added, which can be justified as far as the energy savings. He admitted that some manufacturers have already suggested the increased cost will be much more. “I’ve already heard it can’t be done,” but, he said D&R had also looked at real numbers coming from two manufacturers that produce triple pane units in volume that show the 15 percent marginal cost estimate to be about right.
Affordability, Simplicity and More Time
Ray Garries of Jeld-Wen Inc. questioned the wisdom of pushing Energy Star requirements to a level where triple glazing becomes a necessity. “We’ve made a tremendous investment in Energy Star product lines and want to continue,” he said. “Speaking for our customers, affordability is something we need to consider.” He questioned a number of the assumptions made in determining the new criteria, noting that his company estimates the payback for homeowners opting for products meeting the second round of Energy Star criteria to be a half to a quarter of what DOE expects. Pointing to DOE estimates that purchase of Energy Star products meeting the new criteria will produce $100 million in energy savings a year, Garries suggested that consumers will have to spend between $1 billion and $2 billion more to buy those products.
He also urged greater simplification of the program. Complications in maps and tradeoffs make it harder to upsell consumers on Energy Star, he suggested. He also urged DOE to reconsider establishing separate Energy Star criteria for new construction—where code generally sets minimum performance standards already—and for the replacement and remodeling market, where codes have less of an impact.
The most common piece of feedback that came back from industry representatives at the meeting was that more time is needed than the 30-day period initially scheduled to provide public comment. John Lewis, technical director of the American Architectural Manufacturers Association, was the first of several speakers asking that DOE consider accepting public comment for 90 days, especially since the DOE draft came out only a week before the stakeholder meeting. DOE is itself waiting to see what the window criteria will be in the 2009 IECC, which will be finalized in September.
Although AAMA had not had enough time to develop official positions on the criteria, Lewis noted, its members expressed some initial concerns that the new climate zone map was too complex and that Energy Star products will be “priced out of the market” in phase two. Mike Fisher, representing the Window & Door Manufacturers Association, also asked for more time to offer input. He asked DOE to consider January 1, 2010 and January 1, 2015 as implementation dates for phase one and phase two of the changes. “Changing a window to change the thickness of the IG or allow for triples means a lot of testing. We should have five years between phase one and phase two.” He also expressed concerns about the complexity of the new criteria, urging DOE to consider “simplicity” for the sake of the consumer.
Not all window manufacturers were unhappy with the proposed criteria. “I feel like a minority in this room,” said Brandon Tinianov of Serious Materials. Noting that he appreciated the rigor that went into the development of the new numbers, he said he was frustrated by lack of enthusiasm for further progression in the market.
Nils Petermann of the Alliance to Save Energy and Efficient Windows Collaborative noted that his organization’s goal is to educate consumers, and that it has been fairly easy for windows as they have simply pointed to Energy Star. With the new criteria including trade-offs for U-factors vs. SHGCs, he said, that will get more complicated. He suggested DOE consider simple descriptors—moderate solar heat gain, high solar heat gain, low solar heat gain—that could be understood more easily by consumers.
New door and skylight standards
The afternoon of the meeting was devoted primarily to new door and skylight standards. Describing the new swing door criteria, Alice Dasek of D&R noted that the goal of phase one is to establish the idea of the Energy Star label as a differentiator. It is phase two, however, where DOE seeks to drive that further.
Door manufacturers seemed pleased by the new ratings criteria. Steve Shrieber of Masonite started out by “applauding DOE” for the decision to eliminate different climate zone requirements for swing doors and for simply establishing different requirements depending on the amount of glazing. He even urged DOE to consider a lower U-factor number for opaque doors in the first phase.
Steve Jasperson of Therma-Tru also applauded the single climate zone, but suggested that DOE may need to go back and look at the half-lite criteria. Under the current requirements, he noted, he can construct a fully-glazed door that will qualify, but the half-lite version of the same door will not, even though it constructed with more insulating core material and is more energy efficient.
Skylight manufacturers were less enthusiastic about the new criteria for their products. “Skylights seem to be treated more harshly than windows,” said Roger LeBrun of Velux. New SHGC criteria, he noted, can impair the light benefits of skylights—one of the main reasons people buy skylights. LeBrun and ODL’s Dave De Block also urged DOE to establish Energy Star ratings for tubular skylights that take into account the daylighting benefits they deliver.
Nearly all the industry representatives at the meeting expressed appreciation to DOE for already gathering input from the industry in establishing the new criteria. Karney concluded the event by noting that DOE would consider extending the comment period further. Since the meeting, DOE made the decision to do just that and has now established October 17 as the deadline for submissions.
Written feedback on the draft criteria can be sent via e-mail to firstname.lastname@example.org with “Criteria Revision” in the subject line. DOE plans to post those public comments on the Energy Star windows Web site.
Based on the feedback, the final Energy Star criteria—and effective dates—are expected to be announced this fall. JGS