AAMA Proposes Further Revisions to ENERGY STAR® Program
After extensive meetings with members and industry affiliates, the American
Architectural Manufacturers Association (AAMA) in Schaumburg, Ill., provided
additional feedback on the most recent proposed ENERGY STAR® Program
criteria as they relate to fenestration products.
"It is our intention to collaborate with the Department of Energy
(DOE) to reduce energy consumption in existing and new homes; recommend
increased enforcement of model energy codes; support the use of ENERGY
STAR as a means to communicate more energy-efficient choices for builders
and homeowners and work with DOE to drive innovations and technologies
that will further the development of affordable and efficient fenestration
products," says John Lewis, AAMA's technical director.
Holding true to this commitment, AAMA submitted a joint letter with the
Window and Door Manufacturers Association (WDMA) to DOE. Participation
in the ENERGY STAR Program criteria development is based upon the guiding
principle that a simpler program more readily understood by the consumer
is superior to an overly-complex one. This basic approach should include
reduction of heat loss and unwanted solar heat gain associated with the
existing stock of single-pane windows, skylights and glass doors in the
U.S. In addition, affordability should be regarded as one of the foundational
elements of the process used to determine program parameters and is necessary
to achieve the desired consumer-driven outcome, according to AAMA.
Closely related to affordability is the delivery of energy savings; such
savings must translate into immediate reductions of consumer utility expenditures
if the criteria are intended to drive consumer behavior. The ENERGY STAR
requirements should provide a lower limit to SHGC coefficients in order
to maintain the performance of glazing packages and provide an acceptable
value for Visible Transmittance (VT). Different approaches that save equivalent
energy should be closely scrutinized. In similar fashion, AAMA stressed
the proposed standard must not exclude some products which would have
equivalent or lower life-cycle energy and environmental impacts.
Other important topics of interest include the timing and implementation
of the plan and aligning the current ENERGY STAR zone maps with those
of the International Energy Conservation Code (IECC). (View
the full joint letter sent to DOE.)
In a separate letter, AAMA proposed supplemental recommendations that
focused on the importance of accepting equivalent products of varying
U-factor and SHGC pairings, clarification regarding the current ENERGY
STAR Program as a residential program and allowances for alternate SHGC
and U-factor values for impact-rated products. (View
the full AAMA letter sent to DOE.)
"A preliminary analysis of alternate U-factor and solar heat gain
coefficient (SHGC) criteria has shown promising results and is consistent
with one of AAMA's guiding principles: 'Equivalent alternatives are just
that-equivalent.' We see no justification for eliminating manufacturing
options which provide fenestration manufacturers with viable alternatives
to abandoning current production methods, at great cost, for little if
any increase in the annual energy savings realized."
The AAMA Skylight Council also submitted comments related to the skylight-specific
criteria. The Council also agreed that an industry recognized climate
zone map, such as those already established by the American Society of
Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and IECC,
will help to minimize confusion in the marketplace. Much concern was expressed
regarding the relationship between SHGC and visible daylight, as well
as the increasing cost of argon.
In addition, the Council stated that reducing SHGCs will reduce general
lighting power density to the point that skylights will be ineffective
at providing an adequate level of lighting without the use of electric
illumination. It was recommended that ENERGY STAR only consider skylights
that allow electric illumination to be turned off to maximize energy savings.
The group also felt that tubular daylighting devices (TDDs) should not
be excluded from qualification, especially in Phase 1. All TDDs should
be considered qualified if a dual diffuser at ceiling level is used and
the air leakage and durability requirements contained in the skylight
labeling provisions of the 2003 and 2006 IRC and IBC are met. (View
the full letter sent to DOE from the AAMA Skylight Council.)
"We will continue to work with DOE, AAMA members and the industry
to ensure that the ENERGY STAR program benefits the marketplace while
taking manufacturer concerns into consideration," Lewis stated.
All AAMA recommendations and comments were submitted to the Department
of Energy on November 14, and the association will continue discussions
as the Department plans to announce its ENERGY STAR Program targets for
2009 and 2013.
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