AAMA Looks at Energy Star Changes

Changes in the Energy Star program and their impact on window and door makers are topping the agenda at the summer meeting of the American Architectural Manufacturers Association taking place here this week. Attendees also heard a cautious, but optimistic forecast for improving industry sales this year and next.

One change coming to Energy Star is the introduction of blind testing of products bought in the field as part of the National Fenestration Rating Council’s new independent verification program. The NFRC IVP, now is pilot phase, was developed in response to problems the Energy Star program encountered in other product areas, explained Paul Gary of the Gary Law Group, an industry attorney speaking at the event. Representing a "paradigm shift" for the industry, the program could create some unique challenges to window manufacturers, he said.

Susan MacKay, also with the Gary Law Group, explained a number of the details, including the two types of testing to be used.  Non-destructive testing will be a thermal test to see if the product performance matches the U-factor listed on the NFRC label.  In destructive testing, the window or door will be taken a part to see if it matches the product drawings. The IG unit will also be tested for gas fill levels. If testing is unsuccessful, the manufacturer will have an option to pay for a retest up to five times before a the product line is disqualified. 

Gary asserted that the industry should argue for a number of changes before the IVP is finalized.  First, he stated, the program should allow the manufacturer to be present for testing.  "Mistakes are made. It may not be the correct product," he suggested. "Giving the manufacturer the opportunity to be present would simply be a good way to prevent mistakes in the procedures that could be costly."

He also recommended that AAMA urge EPA to issue some sort of "statement of intent" for the IVP procedures. The danger, he suggested, is that the program of blind product tests provides "a roadmap for plaintiffs' attorneys."  They may use the procedures, but not test two or three of a manufacturer's products bought in the field, but 30, until they find one that doesn't meet the level.  He also warned that looking further down the road, the creation of the IVP program sets the stage for someone to demand a similar plan be developed for air, water and structural tests. 

NFRC's IVP procedures are officially expected to begin in January 2013.  Other changes are coming with Energy Star version 6, new window, door and skylight rating criteria, which are now expected to take effect in January 2014, reported Ray Garries of Jeld-Wen at a meeting of AAMA’s regulatory affairs committee. EPA issued a framework document with potential changes to the program last year. That included performance requirements and other new rules it is considering, but an official draft of the new criteria will be issued by EPA soon, he said.

The most critical number many in the industry are looking at is the new Northern zone U-factor requirement. EPA officials are saying a U-factor of .27 is about "95 percent sure,” as are new requirements for air infiltration requirements, Garries said.

Also likely will be a new “Most Efficient” designation within the Energy Star windows, doors and skylight program, he said. Currently used with other Energy Star product categories, the new tier is likely to have a U-factor requirement of .20. The addition of the “Most Efficient” designation to the windows program is welcomed by many in the industry, Garries stated, explaining that it provides an additional level of recognition for those manufacturers offering ultra-efficient products, while reducing the pressure to tighten the regular Energy Star criteria further.