With Stiffer Requirements on the Way, the Industry Claps Back at EPA

By Drew Vass

In July, and after a years-long planning and development process, the U.S. Environmental Protection Agency (EPA) unveiled Draft 1 for Energy Star Windows, Doors and Skylights Version 7.0—including what many describe as “significant” changes. Performance requirements for entry doors go relatively unscathed with no changes for opaque doors and changes for those with glass equating to 0.02 improvements to U-factor. The story is significantly different for windows and sliding glass doors however—especially those for the Northern climate zone, where the industry is now fixated.

If Version 7.0 proceeds as drafted, windows in the Northern zone will be forced to make the leap from U-factors of 0.27 to 0.22, under prescriptive requirements; solar heat gain coefficients (SHGC) will now be limited to 0.17, to maintain visible transmittance (VT). Additional pathways are provided, with combinations of U-factor and SHGC ratings that are less stringent, but, by most accounts, experts and representatives of door and window manufacturers all tell [DWM] that every avenue has its challenges. In the Northern zone, they say, a shift from double- to triple-pane glass will likely ensue. And perhaps nowhere would those changes be felt more than in sliding glass doors, which are now slated to fall under the same requirements as windows.

“The modeling seems to indicate that, under the currently proposed Energy Star Version 7.0 criteria, many manufacturers will need to go through a significant redesign to continue using the Energy Star label,” says Doug Hauck, a technical services engineer for Quanex Building Products.

But not according to EPA officials.

Part of the impetus for Version 7.0 includes an estimated total energy savings of around 9.7 trillion British thermal units (BTUs) per year (nationally, over what would be expended using what EPA labels as “baseline” products). That’s if shipments of Energy Star-rated windows remain equal to 2019 levels once the new requirements are put into place. But EPA officials also point to what they feel is an unacceptably high market share for windows carrying the Energy Star logo, suggesting that the criteria for Version 6.0 have grown lax. Version 6.0 went into effect in January 2015; by 2017, officials say adoption rates were already at 84%.

Weighing the Consequences

EPA officials say they used the National Fenestration Rating Council’s (NFRC) Certified Products Directory (CPD) in Draft 1 of version 7.0 to determine “whether a new specification would result in products that are broadly available, with non-proprietary technologies offered by more than one manufacturer.” According to EPA’s analysis, the proposed requirements for the Northern zone can already be met by more than 50% of existing Energy Star-rated products. But manufacturers say they believe EPA’s research could be flawed.

“Products included in the NFRC database aren’t necessarily those that are being produced,” says Jeff Inks, vice president, advocacy, for the Window and Door Manufacturers Association. “It also isn’t like there are simple switches to start manufacturing any window in the database. It’s not like that at all,” Inks says. “What is in NFRC’s database isn’t a one-to-one representation of what’s available in the market.”

Can those hypothetical products be made? Door and window manufacturers say yes, with a caveat: deployment will likely take longer than the 12-month period that EPA officials are suggesting for rollout. Currently, EPA plans to finalize Version 7.0 around the start of 2022 (ideally in January, officials say), with new requirements set to take effect 12 months later.

But, “It will take longer than 12 months to develop new product lines, especially if you’re switching a product over to triple-pane glazing, which is what most manufacturers will have to do in order to meet the requirements,” says Dan Parish, engineering manager for Pella. Instead, Pella would prefer a start date of January 2024—a year beyond EPA’s current proposal, he says. “Realistically I’d like to see 16 to 18 months,” says Dean Martin, a certification and testing engineer for ProVia.

Others suggest that 12 months might be enough— under normal circumstances—but not amid the current business climate.

“Generally, product enhancements can be completed in that timeframe,” says Nick Pesl, Kolbe’s displays and product information manager. “In today’s world, 12 months is not a lot of time to develop a new product or product line.”

With issues such as labor and material shortages looming, some door and window manufacturers say they fear that the demand for additional glass and other technologies might affect an already fragile supply chain. But glass manufacturers assure they will be ready.

When it comes to producing more glass, some industry members also suggest that EPA could be overlooking details that affect its plans for energy savings. By pressing the industry to produce more triple pane units, “We’re asking glass manufacturers to increase their volumes,” Martin says. “To make glass, it takes a lot of energy. So you’re saving energy at the consumer level, but you’re adding it on the manufacturing side for more glass.” There will also be increased costs and emissions for transporting additional glass and heavier products, he says.

The Bottom Line

So far as how products would go about meeting the proposed Version 7.0 requirements for the Northern climate zone, most agree that triple-pane insulating glass units (IGU) are the quickest way to get there, but other options are on the table. According to Hauck’s analysis (see more details in his column on p10), to meet the proposed requirements, windows with double-pane IGUs would require premium low-E coatings on surfaces two and four. The same products would at least require features such as warm-edge spacers, Argon gas fill and foam-filled vinyl frames. Experts say finding the right combinations of those improvements for each product make triple-pane glass a less complicated solution—even if triple pane required retooling frames to accommodate added thickness and weight.

That’s not to say there aren’t snags associated with triple-pane glass, or that it’s a shoo-in for meeting the proposed criteria. While most high-performance, triple-pane windows inherently pair low U-factors with low SHGC ratings, EPA officials believe homeowners in the Northern climate zone shouldn’t have to live with overly dark windows, nor should they miss out on free energy, via blocked solar heat gain with its new proposal. For this reason, the administration has added requirements for maintaining visible transmittance (VT) of light.

“Some very low SHGC products also have very low visible transmittance (VT),” EPA officials write. “These dark or tinted products reduce glare in southern, cooling-dominated climates, but are considered unacceptable to many consumers in the Northern climate zone. Establishing a minimum SHGC for the Northern climate zone could improve the veracity of the Energy Star label by disqualifying excessively dark products and possibly improving energy performance through passive solar heat gain.”

EPA is proposing requirements in the Northern climate zone that would exclude products with SHGC ratings of less than or equal to 0.17. According to their analysis, those products would save less energy and would also lower VT beyond what they see as acceptable. But manufacturers suggest those requirements also clash with the typical ratings found on triple-pane windows with low-E coatings. At the same time, some suggest that the idea for saving energy by relying on passive solar heat gain is a bit of a misnomer.

“I understand the philosophy behind that—gaining solar heat in the Northern climates—but also it’s kind of misleading, because I don’t think they took into account all of the various aspects, like how a house is positioned and which way it’s facing,” Martin says. “So, consumers are getting kind of misled on their energy bills.” While homeowners could be led to think they’re getting windows that save energy through passive heat gain, that “feature” will be limited to homes with windows facing certain directions, along with other factors that can prevent heat gain from occurring, Martin says.

Viewing the Menu

As manufacturers mull over how to create windows that meet U-factor requirements, while providing acceptable levels of VT, other options come into play, such as vacuum insulating glass (VIG) and thin-triples (IG with an added layer of thin glass). Both VIG and thin-triples eliminate the bulk and weight issues associated with triple-pane glass, but manufacturers say they have concerns over the costs for those options. As part of its analysis, EPA gathered info from door and window manufacturers about the costs for those and other technologies, such as room-side low-E coatings, triple-pane glass and foam-filled frames. In the process, researchers calculated what they call baseline expenses in order to determine the expected cost increases for manufacturers and consumers. Researchers also gathered price points on finished products, including 138 windows from 60 product lines and 39 manufacturers. As part of that research, they contacted window installers and wholesalers, asking for price quotes on replacement projects involving 12 windows, minus installation. Products used in cost analysis range from windows with triple silver low-E coatings and double-pane glass, at $155 per window, to $1,275 for triple-pane windows with surface four coatings. Based on their analysis, officials say a baseline product with a U-factor rating of around 0.35 was established, with the aim of reaching new performance requirements that generate paybacks for consumers within 13 years.

But the science behind those estimates is fuzzy, manufacturers suggest, and paybacks, they say, are over-estimated.

“Depending on the window type, the payback  could take upward of 20 years,” Pesl says.

“We believe that the actual payback the typical consumer is going to encounter will be far greater than what EPA states,” Inks adds. “That’s because we believe the baseline they’re using in their analysis is inappropriate and the incremental cost increases they are using are not representative of the true cost increases consumers will encounter. Looking at the Northern Zone, for example, EPA is asserting that the incremental costs of going to a Version 7.0 window from a Version 6.0 is $36. But if you look at the average cost difference between the two based on the market
today, it’s much more than that,” he says. “The bottom line is—we don’t believe what EPA is asserting as incremental cost increases is representative of true cost increases most consumers will pay.”

Even if manufacturers were able to produce windows that meet the criteria at the costs estimated by EPA’s research, there’s no guaranty, experts say, that consumers will go for those higher price tags—with or without the Energy Star label. As a consumer-facing brand that’s meant to delineate the performance of doors and windows, Energy Star is a voluntary program for manufacturers and an optional guide for consumers. At the same time, the idea that some manufacturers might opt out of the program seems unlikely, experts say, on the basis that if even one opts in, others must follow.

“Energy Star isn’t required by any code or statute, but it’s effectively mandated by our customers, who expect it and rightfully so,” Hayden says. But that doesn’t mean consumers will remain willing to pay if, “What can be made [to meet the proposed criteria] differs from what can be made affordably,” he suggests, adding, “And what can be made isn’t necessarily going to be [at] what consumers will be willing to pay, cost wise.” At the same time, “Manufacturers aren’t going to produce products that consumers won’t buy,” Inks says, because they can’t afford to.

In the end, which requirements make it through the final phases of development stands to be seen, as there’s still plenty of push and pull expected to occur between EPA and the industry. In the meantime, “In terms of having a consumer-oriented program that helps consumers differentiate better performing products … we share that same objective,” Inks says.

Ultimately, it isn’t either that will determine the success of the program, but consumers, as they look for the familiar Energy Star label and decide how much they’re willing to pay for it.

Drew Vass is the editor of [DWM] magazine.

To view the laid-in version of this article in our digital edition, CLICK HERE.

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