Releases Energy Star Draft Criteria and Report
March 12, 2009
The U.S. Department of Energy (DOE) released its Energy Star
for Windows, Doors and Skylights Revised Draft Criteria and Report.
DOE says this latest draft takes the comments it received into consideration
as well as the criteria approved for the 2009 International Energy
Conservation Code (IECC) and the criteria set forth for the 2009-2010
tax credit in the American Recovery and Reinvestment Act (ARRA)
of 2009, according to the DOE. Taking these and other factors into
consideration the DOE has made several changes to the draft ENERGY
STAR criteria, specifically:
- A reduction in the number of climate zones to four and returned
to geographic zone names;
- An adjustment to the windows criteria to limit tradeoffs in
- An adjustment to the U-factor for the =½-lite category
of swinging entry doors and a change in the SHGC to match IECC
- Changed skylight criteria based on IECC levels;
- Suspended Tubular Daylighting Devices from the program until
industry collects a
sufficient body of test results; and
- Delayed beginning work on criteria for Phase 2 until late fiscal
There are some additional items of interest in the draft criteria.
In September of 2008, the International Code Council (ICC) finalized
the 2009 IECC, whose levels exceed those of ENERGY STAR in several
regions. DOE says ENERGY STAR must consider the stringency of IECC
levels when evaluating which criteria will yield savings above prevailing
building codes. This is true in the wake of the passage of the American
Recovery and Reinvestment Act of 2009; because the law requires
states to adopt the most recent code and enforce it to receive additional
state energy grants, states are likely to adopt the 2009 IECC more
quickly than they might have otherwise.
On February 17, 2009, President Obama signed into law ARRA, which
extends and revises the tax credit for windows, doors, and skylights.
HERE for related article.) While the previous tax credit for
fenestration products applied to ENERGY STAR qualified products,
the new tax credit specifies energy performance criteria, a maximum
0.30 U-factor and maximum 0.30 SHGC, for the entire country, regardless
of climate zone. DOE considered this fact when reviewing ENERGY
STAR criteria levels across the country.
Although the tax credit applies across the United States, DOE considered
it most closely when reviewing the proposed criteria for the North,
the zone that would most benefit from the application of this low
U-factor. Meeting or exceeding code is a minimum requirement for
ENERGY STAR criteria, and ICC set the final 2009 IECC prescriptive
criteria for the regions corresponding to ES5, ES5a, and ES4 at
a maximum U-factor of 0.35 and no rating for SHGC.
In revising the draft criteria for the northern climates, DOE says
it considered its original analysis, stakeholder comments, the newly
enacted federal tax credit and final 2009 IECC prescriptive criteria.
The revised criteria consolidate the three northern zones (ES5,
ES5a, and ES4) into a single zone and greatly simplify trade-offs,
as requested by stakeholders. DOE tightened the U-factor criterion
to the 0.30 level of the tax credit to ensure ENERGY STAR intersects
with it. To maximize the number of products qualifying in this zone
at the 0.30 maximum U-factor, DOE set no SHGC criterion rather than
carry over the tax credit's SHGC maximum. The majority of windows
in the market meeting the 0.30 U-factor, however, will also meet
the tax credit's 0.30 SHGC level, because the 7 median SHGC for
products with U-factors = 0.30 is 0.27. The revised tax credit of
30 percent, up to $1,500 total, will help cover the cost of producing
windows that qualify for the credit.
The Industry Reacts
Jeff Lowinski, vice president advocacy and technical services, for
the Window and Door Manufacturers Association (WDMA), says the DOE
did take into account many of the comments WDMA made on behalf of
"They addressed the issue of too many zones, differing requirements,
etc.," says Lowinski who adds that the WDMA is currently looking
at the new draft in more depth. The association will have more information
as to what additional comments they may make on this draft in the
He does point out, however, that ENERGY STAR is not in line with
"The technical debate regarding energy requirements should
go on in a technical forum not a legislative forum," says Lowinski.
While some may believe that the draft requirements are too stringent,
Wayne Gorell, president of Gorell Windows and Doors, has a different
"I don't think they have gone nearly far enough," he
says, adding that this applies to the tax credit requirements as
"As far as ENERGY STAR goes (and the same goes for the tax
credit), the tougher the achievable standards, the better,"
he says. "We have the ability to make windows with a U value
well under 0.2 today, so why are they setting the standard more
than 50 percent worse, at 0.3U?"
He adds that the U value standards should be set at or close to
0.2U, at most 0.25U to get the most benefit for our country.
"This is probably not what a lot of manufacturer's want to
hear, but we need to focus on the reason for ENERGY STAR and the
reason for the tax credit. The requirements should not be based
on what is easy to achieve, we need to do what is best for our country
and its citizens, and that is saving more energy to work towards
Gorell says that the industry should also be taking into consideration
the fact that technology will continue to improve.
"We are short changing consumers who buy windows today from
saving the most energy they possibly could save for many years to
come," he says. "Most consumers do not change their windows
more than once, so missing the opportunity to save the maximum amount
of energy now, will have a long-term impact."
Impact on Skylight Industry
Another change to the revised criteria includes a revised criteria
for skylights that, according to the DOE, would encourage superior
product performance and maximize potential savings. (Click on the
full draft criteria at the end of this story to see the chart regarding
skylights, which appears on page 9 of the draft.)
Roger LeBrun, product certification engineer for Velux America
Inc., says his company will support the skylight criteria, as it
fairly accounts for the technology that is available and currently
However, there is one item in the criteria regarding tubular daylighting
devices (TDD) with which LeBrun disagrees. The DOE had deferred
setting ENERGY STAR criteria for these products until there was
a sufficient body of physical test results on which to determine
"As of the date of this report, no additional test results
are available, and DOE has no choice but to suspend TDDs from the
ENERGY STAR program pending the availability of a sufficient body
of test results," according to the criteria.
LeBrun says he is very disappointed that tubular daylighting devices
were proposed for elimination.
"There is no reason for ENERGY STAR to dismiss the category
on the basis of a sub-optimal test method they accepted for many
years, since the thermal energy penalty from TDDs is far outweighed
by their lighting energy savings. If nothing else, these are the
most efficient 'lighting devices' one can buy. They just need to
be as tight as any good door or window. Why else would the National
Green Building Standard award extra points when they are used in
rooms where windows can't be used?"
The DOE is taking comments on the revised criteria from now until
March 25. (CLICK
HERE for information on where to send comments.) The final criteria
will be published on March 31, 2009. The effective date for phase
1 criteria is January 1, 2010.
HERE to view the full draft criteria.
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