Industry Provides Feedback on New Energy Star Criteria

August 28, 2012

Washington, D.C.—Industry representatives questioned some of the details, but overall criticism of Version 6.0 Energy Star criteria for windows, doors and skylights, released earlier this year, was fairly muted at a stakeholder meeting hosted by the Environmental Protection Agency here on Monday, August 27. Many attendees suggested that provisions in the 2014 criteria are too stringent, but much of the feedback submitted to EPA previously by manufacturers argued more assertively for less aggressive thermal performance requirements.

Perhaps the most notable development at the meeting was the announcement that EPA would launch a Most Efficient program for windows beginning in January 2013. Douglas Anderson, EPA's manager of the Energy Star windows program, reported that draft criteria—expected to be in line with the current Department of Energy Volume Purchase Program—will be announced in the next few weeks. A stakeholder webinar will be held in mid-September to gather feedback on the Most Efficient requirements, with final numbers expected to be set in the beginning of October.

The Most Efficient program, in place for several product categories, is different than Energy Star in many ways, Anderson suggested. Products meeting the criteria aren’t labeled, but are listed on the Energy Star website. Criteria for product categories can change every year, with little industry input, he noted also. “We feel we have a lot more flexibility,” he said. “We really see it as an opportunity to reward the companies investing in new technology.”

 EPA's Doug Anderson moderating a question-and-answer session that was part of the stakeholder meeting.

In addition to more stringent U-factor requirements than the current Energy Star criteria, the initial Most Efficient windows program will require structural product certification. Anderson suggested it will provide a way to encourage development of triple-glazed products, as well as dynamic glazing products looking into the future.  

The focus of the meeting, however, was on the 2014 Energy Star criteria, with Emily Zachary of D&R International, which administers the Energy Star windows program for EPA, providing a detailed explanation of new window requirements. One reason the industry may be offering fewer objections to the new criteria, she suggested is “that there’s been a huge improvement in performance,” due primarily to the .30/.30 requirements for federal energy efficient tax credits put in place in 2009 and 2010.

Based on the EPA’s analysis of products available in the market, she said, those credits “significantly changed the landscape of window performance, and pushed most manufacturers to offer performance that met or exceeded those performance levels.” In studying double-hungs, a big percentage of the market today consists of windows with a 0.29 U-value, developed by manufacturers looking to meet tax credit requirements with a bit of a cushion; .30 U-factor, developed to meet the tax credit criteria; and 0.32 U-factor, the current Energy Star requirement for the Northern climate zone, she reported. “The goal is to shift that all down.”

The 0.27 U-factor proposed for the Northern zone in Version 6.0 was chosen because EPA is confident more manufacturers can get there with a double-pane window and not have to go triple pane, which EPA recognizes is not necessarily cost effective, Zachary said. Looking at currently available products on the market with a 0.27 U-factor, the majority are double-pane, she noted. In addition, the market data shows that fourth surface low-E products have seen little penetration, indicating potential for more manufacturers to meet the new criteria.

Industry Feedback
The meeting, which drew about 40 people and was also available online as a webinar, was designed to provide a forum for stakeholder feedback on the new criteria. Topping the list of concerns expressed at the meeting were the new requirements for installation instructions. Manufacturers on hand, as well as Jeff Inks of the Window & Door Manufacturers Association and Rich Walker of the American Architectural Manufacturers Association, suggested EPA’s proposed a list of provisions that should be included with installation instructions is too detailed and would create numerous challenges for manufacturers attempting compliance.

Asking EPA to consider a simple requirement that installation instructions be provided, industry representatives raised questions about how the installation instruction requirements would be assessed and how they would be enforced. Manufacturers also expressed concern about EPA’s requirement to include information about the potential hazards of lead paint with installation instructions.

Also raising a number of questions was a new proposed requirement for an air leakage rating of ≤0.3. No one opposed the criteria itself, but there were questions about how such performance numbers would be determined and how they would be presented on a label.  AAMA's Rich Walker specifically recommended that EPA simply adopt pass/fail criteria for air leakage.

Among those offering formal feedback at the meeting was Thomas Zaremba of Roetzel & Associates, representing the primary glass manufacturers. He suggested that EPA should consider more equivalent energy performance criteria options in the Northern climate zone to recognize products in the market that enable homes to take advantage of solar heat gain. Questioning EPA's assumption that high-gain/low U-factor products were not available in the market, he noted that many of the float glass manufacturers have such lines and that they are a popular alternative in Canada.

Zaremba also suggested that the new criteria could be more stringent on U-factors in general, pointing to the availability of four-surface low-E products as a way to meet higher performance standards cost effectively.

Others expressed reservations about the new criteria, and as well as future changes. WDMA's Jeff Inks said his organization supports Energy Star , but that EPA needs to move forward carefully, as the additional energy efficiency enhancements to windows, doors and skylight products are likely to produce diminishing returns on the energy savings front. He commended EPA on the current process that allows stakeholder input, and urged that it continue using such a process to avoid criteria changes that create additional compliance costs.

Ray Garries of Jeld-Wen Inc. expressed similar concerns about the potential costs of performance upgrades to comply with Energy Star. He pointed out that while the market share of Energy Star windows and doors has increased, the market overall is down significantly from several years ago and that means sales of Energy Star windows and doors are less than they used to be.

"A larger Energy Star market is not a bad thing for consumers," Garries asserted. "Real affordability has to be a key." 

Other speakers included Ray Dill of ODL, who questioned a number of new door criteria, including U-factor criteria that require a higher performance half-lite glazing panel than full-lite panel in the same door.  He also said more research has been done on tubular daylighting devices, suggesting EPA should consider separate criteria for them rather than including them with regular skylights.

AAMA's Rich Walker noted that many of its skylight manufacturer members had concerns about the new skylight criteria.  Commending EPA on the job it had done analyzing the window market to determine its latest set of criteria for those products, he urged EPA to re-examine the current skylight market with the same rigor.

While many in attendance expressed concerns about specific installation requirements, John Jervis of the American Window & Door Institute praised EPA for recognizing the importance of installation with the new criteria. Highlighting his organization's focus on installation procedures, he pointed to a new service his firm was offering to provide instructions for different types of applications online.

Energy Savings
The meeting featured much discussion of the energy savings likely to be delivered on a national scale by potential changes to the Energy Star criteria, with analysis provided by Gregory Holman and Christian Kohler of Lawrence Berkeley National Laboratory.  One of the biggest changes for the Version 6.0 criteria comes in the Southern climate zone, where the U-factor has been ratcheted down from 0.6 to 0.4 U-factor. That was driven by more stringent requirements in the 2012 International Energy Conservation Code, EPA's Anderson stated, which the Energy Star program looks to exceed, or at least meet.

Much of the additional energy savings promised by the new criteria comes in the more stringent U-factor requirement in the Northern zone, with the changes seen having less impact in the North Central and South Central zones, Kohler stated. In much of the country, the savings in heating costs achieved by more stringent U-factor requirements will be offset by increased cooling costs, he also reported.

For this reason, looking to the future, dynamic glazing products, as well as products with dynamic shading devices, could provide much more savings, Kohler suggested.  The analysis suggests there are further savings that can be achieved through the use of triples in the Northern zone, he reported as well, although there are likely to be diminishing returns from many changes moving forward.

In addition to sharing their thoughts at the meeting, window and door manufacturers and others still have an opportunity to submit feedback to EPA before it finalizes the 2014 criteria, Zachary emphasized.  The deadline for comments is September 28 and she urged attendees and webinar listeners to submit comments to