Stakeholders Travel to Nation's Capitol to Give Feedback on New ENERGY STAR® Criteria

The Department of Energy's (DOE) auditorium was filled yesterday with door, window and skylight manufacturer representatives who came out for the stakeholder meeting to discuss the draft of the revised ENERGY STAR® criteria released last week (CLICK HERE for related story). Those in attendance had the opportunity to hear a panel of speakers including ENERGY STAR program manager Rich Karney; Stephen Bickel, Alice Dasek, Jordan Kelso and Emily Zachery of D & R International Ltd.; and Stephen Selkowitz and Josh Apte of Lawrence Berkeley National Laboratory. In addition, manufacturers and association representatives had the opportunity to offer feedback on the criteria.

Much of the DOE's presentation was spent explaining the reasoning behind the new draft criteria.

"The market share of ENERGY STAR windows was around 50 percent in 2007," Karney explained. "The ES label must provide some differentiation."

Likewise, ENERGY STAR criteria matches that of the codes in some locales.

"We wanted to create a climate zone map that would enable us to meet or beat codes in all parts of the country," Bickel added.

In addition, the DOE is working to align the ENERGY STAR criteria more closely with that of the International Energy Conservation Code (IECC).

After these explanations and an overview of the criteria draft (CLICK HERE to view), the panel encouraged stakeholders to provide feedback on what they'd heard so far.

Timing seemed to be the overarching concern of those in attendance-both of the public comment period for the draft, which begins today and runs through September 14, 2008-and on the phase-in of the new criteria.

American Architectural Manufacturer Association (AAMA) technical director John Lewis was the first to speak-and the first of many to voice this concern.

"We're asking for a 90-day review time," he said.

Mike Fischer, director of codes and regulatory compliance for the Window and Door Manufacturers Association (WDMA), also noted that if the goal is to align ENERGY STAR more closely with the IECC, it would make sense to extend the public comment period further-since the 2008 IECC final action hearings are scheduled for September 14-23.

The phase-in of the criteria is also a concern for some. The first phase of the criteria could be implemented as early as August 3, 2009, according to Karney, and Phase 2 is scheduled to take effect on January 1, 2013.

Fischer suggested that Phase 1 be implemented in the winter, since summer typically is a busy season for manufacturers, and that Phase 2 be implemented on January 20, 2015-2 years later than scheduled.

One of the main reasons most hope to push back the phase-in of the program is that Phase 2, particularly, will require some product upgrades and re-designs for many window manufacturers.

"What proportion of products which qualify today will qualify under the new criteria?" asked Bickel. "With the exception of [Climate Zone] ES5a, the majority will."

For this zone, Bickel expects new products to be designed using argon gas and higher performance glass packages. However, he expects products will still be readily available, but did note that for this zone, there currently are no qualifying continuous aluminum frame windows.

"These products exist, but not many people are making them," he added.

Of course, with new products come additional costs. While DOE has accepted this and shared with manufacturers its projections for cost increases, many in attendance noted that in the end, it's the consumer who's going to pay for this. DOE estimates an approximate increase of 15 percent under the new criteria, particularly for windows designed to meet ES5 and ES5a's criteria.

"There's going to be a price for premium ES5 windows," says Bickel.

Lewis fears what may happen when these costs are passed on to consumers, though.

"It very well could be that if we put the ES criteria in Phase 2, with the marginal cost increases, it's possible that the product will cost so much that consumers won't buy it and we'll save less energy and will lose ground," he said.

Several manufacturer representatives also questioned the new criteria-and the emphasis the criteria in general places on U-factors.

"U-factor is important, but it's not the only thing," said Thomas Culp of Birchpoint Consulting, who spoke on behalf of the Aluminum Extruders Council.

Gary Curtis of the Northwestern Energy Efficiency Alliance also noted the variables that can affect a U-factor.

"We believe U-factor is a pretty solid measure, but occupant actions may affect the gains," he said.

Though many argued too much emphasis still is placed on U-factors, the DOE has incorporated several tradeoffs into the new criteria, in which a combination of a particular U-factor with a particular SHGC will meet the criteria.

"The idea is we have the overall goal of decreasing energy consumption in a home, and this can be achieved with different U-factor and SHGC combos," Apte explained. "Then we calculate the change per unit."

Lewis, however, pointed out that tradeoffs are not offered in the Southern zones in the current draft of the window criteria, and AAMA members would like to see this return.

Bill Yanek, executive director of the Glazing Industry Code Committee, pointed out that he sees the tradeoffs as a benefit to manufacturers and their customers.

"In pursuing greater energy conservation, maximizing the use of trade-offs will result in greater cost-effectiveness," he said.

Culp went so far as to suggest the DOE consider heading in an entirely new direction with the ENERGY STAR program.

"We'd like ENERGY STAR to think a little broader," he said. "In ES Zones 1 and 5 the driving criteria (U-factors) pushes consumers away from green materials like aluminum and wood."

Culp proposed, on behalf of the AEC, that recycled content be recognized in ENERGY STAR criteria, and that credit be given toward meeting U-factor requirements based on the use of recycled materials.

Comments regarding the draft of the new criteria should be directed via e-mail to Karney at Richard.karney@ee.doe.gov, or to Zachery at D&R at Emily@drintl.com.

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