Is it time to make Energy Star requirements more stringent?

John G. Swanson
August 1, 2007
The Talk, Page 2...

Survey Results for 08/01/2007:

Is it time to make Energy Star requirements more stringent?

No—market acceptance is no reason for change.





Yes, it's time to raise the bar.





Maybe, but it depends upon new levels.





Last week, we reported on statements made by the Department of Energy’s Richard Karney that it was time to revise criteria for the Energy Star Windows program. Noting that more than half the products in the residential market tout the label, he told attendees at the National Fenestration Rating Council’s summer meeting that requirements need to be more stringent so the Energy Star label continues to mean something to consumers.

Karney followed up this week with a letter, emphasizing that the high level of market penetration enjoyed by Energy Star windows was only one of reason DOE is pursuing a change in criteria. “In addition to the market share issue, DOE must strengthen the Energy Star windows criteria so they meaningfully exceed the requirements of building codes across the country. As it stands, 28 states have adopted the IECC 2003, an equivalent or a more stringent code,” he writes. “In practice, this means the prescriptive code requirements in these states are at or near the Energy Star levels. Furthermore, improving energy efficiency is a national priority the President and DOE are committed to address. I highlighted both of these factors in my presentation at NFRC.

Discussions about raising the bar on Energy Star are not new, but with DOE outlining plans for a change, we decided it was time to hear what the industry had to say. And you had plenty to say. More than 270 readers voted in our poll, close to a WDweekly record.

As you can see from the results, people are split. Approximately half suggest that market acceptance alone is no reason for change, the other half indicate either it’s time, or it may be time, for an upgrade.

Most of the emails I got from readers indicated they would like to see Energy Star standards become more stringent, but some expressed reservations.

One manufacturer asks, “Does the fact that [there is] such a high percentage of windows with the Energy Star label mean that windows are getting more efficient, and isn’t that what we are trying to achieve?”

Another asks instead about how well the current program is policed. “What about businesses that are trying to beat the system? Is there a division that actually checks to see if the windows are NFRC tested or rated correctly?”

“I don’t think we should raise the bar just because a large percentage of the windows manufactured meet the Energy Star standards,” says yet another manufacturer. Still, he suggests, “Raising the bar for Energy Star can be a good thing as long as it doesn’t use more energy to make them than we can save by using them. The same principal applies to energy saving and increased cost.”

“While on the surface it sounds like a good idea,” one lab consultant notes, “I’m not sure that it’s truly a cost-effective means of improving energy performance of our homes.”

He questions the additional energy savings gained by going to extremely high-performance glazing. “My preference would be to install windows and doors with IG consisting of low-E glass with argon gas fill and a warm edge spacer, to minimize condensation during our cold Upper Midwest winters, and to spend the money saved on high-end glass on an upgraded insulation, HVAC or water heating system or even perhaps on well-planned site orientation and landscaping to help provide better shade in the summer and exposure in the winter. This equation works whether colder Northern climates are involved or hot Southern climates, where AC is the norm.”

As noted, there’s definitely support within the industry for a change. A number of people, in fact, mentioned that air infiltration should be added to the criteria.

“It’s about time,” said one dealer. “The typical Energy Star window reduces energy very little. Some of the windows are pitiful. They are weak and allow air leaks. Air infiltration tests should be mandatory on all windows.”

“They need to raise the bar if they truly want increased energy efficiency,” suggested one manufacturer. “It is meaningless, when you can pay $100 for a very inferior product that has low-E glass. Let’s do entire window, and test it in all temperature extremes. By the way, we think air infiltration should be a major factor. Great glass in a lousy frame equals a lousy window.”

“It is definitely time to revamp and strengthen the Energy Star program,” states Gerhardt Reichert, VP of business development for Edgetech IG. He points to England for a possible approach that could be taken here.

Positive things have happened in the UK since it adopted a new label and requirements for its voluntary Window Energy Rating and its version of Energy Star, called “Energy Efficiency Recommended” with a triangular logo.

“The European label adopted is extremely easy to read and understand. Every child, parent, or grandparent can understand it,” Reichert states. “It incorporates three visual cues in combination. The worldwide accepted grading of A, B, C… along with the color scale from red through yellow to greens, along with a progressively shorter bar for less energy usage.”

Within the program, he reports, many companies in the UK have moved their window product performance levels up from E, F, or G performance to the minimum C needed for the official “Energy Efficiency Recommended” status. Additionally they offer higher performing B and A rated products as an upsell to customers.

“A properly designed label can indeed work wonders in moving the window market towards improvements in energy savings without sacrificing price competitiveness or existing features, two things the DOE and industry remain cautious about,” Reichert notes.

Even if the majority of our respondents oppose a change, it still seems likely. “Energy Star fenestration qualification levels need modification,” explains Ray McGowan, technical services manager for NFRC. In the Northern half of the U.S., he notes, current Energy Star requirements match the 2006 IECC. In the Southern U.S., the 2006-2007 supplement has more stringent SHGC requirements than Energy Star.

Given the fact that codes are designed to set forth minimum performance levels and the purpose of Energy Star is to highlight top performers in the market, Energy Star has to change. “Energy Star is doing the right thing,” McGowan says, “and the entire industry is invited to attend the coming stakeholder meetings and provide comments on the developing qualification levels. Please use your marketplace voice to encourage all to attend or comment.”

In his letter, by the way, Karney questions the “no” response option we offered readers in last week’s poll. Pointing to the reasons besides market acceptance driving DOE to upgrade Energy Star requirements, he states, “DOE would have been very interested in the results of a survey of the industry’s initial receptivity to the proposed criteria change. Unfortunately, the wording of the third choice in your poll makes the results nearly meaningless.”

While we would never claim our WDweekly polls have statistical validity, we apologize if our choice of words skewed the results somehow. It is good news, however, to hear that DOE wants to hear what the industry thinks as it begins to evaluate possible changes to Energy Star. I would like to join McGowan in urging manufacturers, dealers and others to participate in the process. Reichert’s idea of looking at Europe for a more scaled approach—perhaps Energy Star and Energy Star Plus—is certainly worth consideration. We hope we’ll hear even more ideas, and in the meantime, we’ll work to keep everyone up-to-date on DOE’s plans.

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