Energy Star Criteria Revision Process Officially Underway

June 15, 2010

The U.S. Environmental Protection Agency sent a letter to stakeholders Monday announcing that is beginning a criteria revision for windows, doors, and skylights. During this process, EPA is inviting industry input, as well as updating research from the last criteria revision, which took place between June 2007 and April 2009, leading to the establishment of the current Energy Star criteria, which took effect in January this year.

EPA, in consultation with the U.S. Department of Energy, is considering a variety of adjustments to the criteria, writes Douglas W. Anderson, Energy Star program manager. The letter says initial topics for consideration, based on six guiding principles established for Energy Star program as a whole, include:

► Significant energy savings can be realized on a national basis
   •  Lower U-Factors in most or all climate zones
   •  Adjust SHGC in some climate zones
   •  Expand education on shading and orientation
► Product performance can be maintained or enhanced with increased energy efficiency
   •  Establish installation procedures to ensure product performance
   •  Add minimum air leakage requirement
   •  Require some form of structural testing
►Purchasers will recover their investment in increased energy efficiency within a
           reasonable period of time
   •  Develop equivalent performance criteria for impact-resistant products
   •  Consider industry proposals for a daylighting credit for skylights and tubular
          daylighting devices (TDDs)
►Energy-efficiency can be achieved with several technology options, at least one
          of which is non-proprietary
   •  Allow leeway in thermal performance for products being installed at high altitudes
►Product energy consumption and performance can be measured and verified
with testing
   •  Create/add a blind purchasing program through the National Fenestration
           Rating Council
   •  Resolve the outstanding conflict between the physical and simulation test results
           for TDD U-factor ratings
►Labeling would effectively differentiate products and be visible for purchasers
   •  Maintain or enhance product and display unit labeling
   •  Bring market share more closely in line with the 25 percent program target.

EPA has established a tentative timeline for the criteria revision, according to the letter. Its initial analysis and research is expected to take place between now and June 2011, with preliminary criteria to be published in July 2011. That will be followed by a stakeholder meeting in August 2011, followed two month comment period.

According to the timeline, comments will be reviewed and criteria finalized between October 2011 and February 2012, with the new Energy Star criteria for windows, doors and skylights set to be released in March 2012, with a final two week comment period before publication of the new program requirements in April 2012.  EPA has set March 2013 as a tentative date for the new criteria to take effect. 

"For its initial analysis, EPA will gather data on marginal cost, product performance, and production considerations," EPA's Adams notes.  Anyone interested in discussing these or other issues with an Energy Star staff support person is invited to contact Joe Hart of D&R International at or 301/588-9387.

The letter confirms much of what Adams outlined earlier this year, speaking at the Window & Door Manufacturers Association legislative conference in March.