Travel to Nation's Capitol to Give Feedback on New ENERGY STAR®
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
Likewise, ENERGY STAR criteria matches that of the codes in some
"We wanted to create a climate zone map that would enable
us to meet or beat codes in all parts of the country," Bickel
In addition, the DOE is working to align the ENERGY STAR criteria
more closely with that of the International Energy Conservation
After these explanations and an overview of the criteria draft
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
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
"These products exist, but not many people are making them,"
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,"
Lewis fears what may happen when these costs are passed on to consumers,
"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
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.email@example.com,
or to Zachery at D&R at Emily@drintl.com.
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