August 22nd, 2022
Energy Star Innovation Part Two
During the last week, many of us crafted a final response to the EPA concerning the Energy Star Version 7 for windows, doors and skylights. Our last letter to EPA in March ’22 asked for nine changes to be made to the proposal, and EPA accepted one.
While it is unlikely that EPA will make significant changes to the proposal, we are still asking for modifications. The changes are all based on cost reductions for manufacturers to meet the version 7 massive reductions in U value and keep Energy Star windows an affordable choice. Our core requests are:
1. A realistic start date;
2. Adjustments to solar gain criteria;
3. Commitment to voluntary status;
4. Realign U values between zones;
5. Realization that safety is required;
6. Use of sustainable carbon principles;
7. Criteria that reflect climate change;
8. Recalculation with recent new data; and
9. Fairness principles in testing.
The latest information from the industry and the EPA can be viewed at Residential Windows, Doors and Skylights for Partners | ENERGY STAR. Another new consideration is the recently legislated Inflation Act which will resurrect tax credits for Energy Star windows. It seems that it will be retroactive and increase the maximum dramatically to the point that it may be a real incentive to consumers! While many don’t agree with this type of incentive using tax money, it has been effective for our industry. This will offset some resistance to higher prices and must be in our strategies.
With this in mind, we must prepare now if your company decides to continue its Energy Star partnership. There are vital steps you can take now:
1. Complete your simulations on all the upcoming glazing options and decide which models will be capable.
2. Gain an understanding of the market share of Energy Star and how your products fit. EPA estimates 82% of windows are now Energy star labeled. This percentage will likely fall dramatically, with some estimating a 20% drop or more!
3. Marketing and sales must decide your strategy using this data and cost/price estimates.
4. Determine how you will use the new tax credits to your advantage.
5. Supply chains must create contractual supply and delivery plans to have new materials ready to go.
6. Engineering and operations should finalize their machinery and teammate plan for 2023 with these new specifications in mind.
7. Innovation groups must be prioritized to find ways to lower costs and increase quality with these new products.
While we know consumers value the Energy Star program, we must make some critical decisions soon to adapt well. Our ability to Innovate well will determine our success.