EPA Begins Phase 2 of ENERGY STAR® RevisionsJune 14th, 2010 by Editor
The U.S. Environmental Protection Agency (EPA) announced the beginning of the second phase of its criteria revisions for doors, windows and skylights today. During this process, EPA will invite industry input and update research from the last criteria revision (June 2007 – April 2009). Based on this feedback and analysis, EPA will select criteria that meet the principles outlined in The ENERGY STAR Label: A Summary of Product Labeling Objectives and Guiding Principles.
Phase one went into effect on April 1, 2010, and EPA operations manager Doug Anderson had provided some information about Phase 2 during a March meeting in Washington, D.C. (CLICK HERE for related story.)
EPA, in consultation with the U.S. Department of Energy (DOE), says it is considering a variety of adjustments to the criteria in order to meet the requirements of the guiding principles and to address comments raised during the last criteria revision. Initial topics for consideration include realizing significant energy savings on a national basis. According to the EPA announcement, this can be accomplished by establishing lower U-factors in most or all climate zones, adjusting SHGC in some climate zones and expanding education on shading and orientation.
Secondly, the EPA says product performance can be maintained or enhanced with increased energy efficiency. This can be accomplished through establishing installation procedures to ensure product performance, adding a minimum air leakage requirement and requiring some form of structural testing.
Additionally, purchasers will recover their investments in increased energy efficiency within a reasonable period of time through the following: Development of equivalent performance criteria for impact-resistant products, and considering industry proposals for a daylighting credit for skylights and Tubular Daylighting Devices (TDDs).
The EPA also proposes that energy efficiency can be achieved with several technology options, at least one of which is non-proprietary. This can be accomplished by allowing leeway in thermal performance for products being installed at high altitudes.
Regarding product energy consumption and performance, the announcement says this can be measured and verified with testing. Topics for consideration include creating/adding a blind purchasing program through the National Fenestration Rating Council; and resolving the outstanding conflict between the physical and simulation test results for TDD U-factor ratings.
Lastly, EPA says, under the new criteria, labeling would effectively differentiate products and be visible for purchasers. This would be accomplished through maintaining or enhancing product and display unit labeling; and bringing market share more closely in line with the 25 percent program target, according to EPA.
Rich Walker, president and chief executive officer of the American Architectural Manufacturers Association (AAMA) says he is encouraged by EPA’s addition of several non-thermal performance parameters to the next ENERGY STAR revision.
“Although resistance to wind load and windborne debris impact are not directly tied to thermal performance, both properties are critical in maintaining the structural integrity of fenestration,” says Walker. “Superior thermal characteristics of windows, doors and skylights can be meaningless if the units cannot stand up to wind loads and flying debris from high wind events. The members of AAMA look forward to working closely on integrating these importance fenestration attributes that have been key components of the AAMA Gold Label Certification Program for many years.”
Jeff Inks, vice president of codes and regulatory affairs for the Window and Door Manufacturers Association (WDMA) says that while the DOE and EPA have been talking about phase 2 for some time it is helpful that the industry now has a formal timeline in place.
Inks pointed out that in phase 2, the EPA will be considering the addition of new qualification criteria beyond existing U-factor and solar heat gain coefficient energy provisions, for example, air leakage and installation procedures.
“We’ll certainly be working closely with EPA to help ensure that any revisions to the existing criteria or addition of new criteria are practical and within the scope of the intent of the Energy Star products program.” he says.
“EPA has indicated they will work closely with industry. We trust that they will and we look forward to working with them on development of phase two criteria,” he adds.
EPA has established the following tentative timeline for the criteria revision.
Initial Analysis and Research, June 2010 – June 2011
Preliminary Criteria Published, July 2011
Stakeholder Meeting, August 2011
Comment Period, August – September 2011
Review Comments, Finalize Criteria, October 2011-February 2012
Release Final Criteria, March 2012
Two-Week Comment Period, April 2012
Publish New Program Requirements, May 2012
Criteria Take Effect, March 2013
EPA says that for its initial analysis it will gather data on marginal cost, product performance and production considerations. Anyone interested in discussing these or other issues with an ENERGY STAR staff support person should contact Joe Hart of D&R International at firstname.lastname@example.org or 301/588-9387. Written comments may also be sent to Hart via e-mail or fax (301/588-0854). Non-disclosure agreements are available upon request.