ENERGY STAR Tightens RequirementsDecember 21, 2011
Given the energy-saving benefits of high-performance fenestration and the positive influence it has on our industry, AAMA has joined others in urging a resumption of the tax credits that expired at the end of last year. These tax credits were, and future credits are likely to be, tied to performance levels dictated by the ENERGY STAR® program, which continues to tighten its requirements.
In October, the EPA released for stakeholder input the ENERGY STAR for Windows, Doors and Skylights Version 6.0 (originally referred to as "Phase 2") Product Specification Framework Document – essentially a roadmap and schedule for the next iteration of ENERGY STAR requirements, slated to take effect in Fall of 2013.
Door Criteria for Comparison
Proposed Version 6.0 ENERGY STAR Criteria for Doors
Current ENERGY STAR Criteria for Doors
Zone-by-Zone Summary of the Proposed Changes
Northern Climate Zone
Due partly to the “30/30” tax credit, windows with a U-factor of 0.30 are more readily available than in years past. The proposed ENERGY STAR 6.0 would tighten U-factor down to within the 0.25-0.27 range, specifics yet to be determined. Because solar heat gain in colder climates can reduce heating expenses, EPA proposes to continue to allow products with any SHGC to qualify in the North.
The 2009 (Version 5.0) criteria offered Equivalent Energy Performance criteria in the Northern Zone, but extremely few windows have been engineered to take advantage of this type of trade-off. Given the continued allowance for any SHGC in the North, the minimal number of products using these criteria, and the complexity that these criteria added to the program, EPA proposes to drop Equivalent Energy Performance criteria in Version 6.0.
North-Central Climate Zone
Proposed revisions for the North-Central Zone are based on EPA’s goal of moving U-Value and SHGC maxima to be equal to or more stringent than code. Because a higher solar heat gain can offset heating costs in the winter, a significant decrease in SHGC is not always ideal in this region, and EPA intends to set the SHGC criteria equal to or just below code.
South-Central Climate Zone
IECC 2012 now meets the current ENERGY STAR requirement for U-factor in the South-Central Zone. The proposed U-factor ranges for the South-Central allow ENERGY STAR to stay ahead of code and product is available that can easily meet these U-factors. IECC 2012 ratcheted down the SHGC in the South-Central Zone to 0.25, so EPA intends to propose that such a low SHGC may detract slightly from heating savings.
Southern Climate Zone
ENERGY STAR currently requires a U-factor of less than or equal to 0.60 in the Southern Zone. IECC 2012, however, requires windows to meet a U-factor of 0.40. EPA recognizes this as a significant tightening of the criteria and does not intend to propose a more stringent level. IECC 2012 has set SHGC to 0.25 and EPA is considering a requirement that exceeds that.
In addition to these not unexpected tighter U-factors and SHGCs, some of the new program elements being considered for ENERGY STAR 6.0 are:
- Certification to NAFS structural requirements. EPA expresses “concerns that requiring NAFS certification may result in a backlog at labs and inundation of AAMA and WDMA resources.” In response, AAMA has stated that it “advocates testing and certifying to the code-required NAFS Standard and believes that our current network of accredited laboratories will be able to meet the needs of additional product testing.”
- Air leakage testing, rating, certification and labeling, keyed to the 2010 IECC, with requirements of an air leakage rating of ≤ 0.3 cfm/ft2 for windows, sliding doors and skylights or ≤ 0.5 cfm/ft2 for swinging doors.
- Mandatory online posting of detailed installation instructions.
- Products Installed at High-Altitude. Products installed at high altitudes have typically required the use of breather tubes in sealed insulating glass units to equalize air pressure, which precludes the use of argon gas and potentially reduces the efficiency that these products can achieve. While some manufacturers have requested allowances for products installed at high altitudes to account for these efficiency reductions, others identified ways around this problem. Because of that, and the small number of products ultimately installed at high altitudes, EPA does not expect to propose special allowances for these products.
- Testing of Tubular Daylighting Devices (TDDs). Beginning in March 2012, NFRC is requiring physical testing for the certification of all TDDs. Simulations will no longer be accepted. Additionally, because there are too few TDDs to warrant a separate set of criteria, EPA proposes continuation of the requirement that TDDs follow skylight criteria.
EPA has published the following projected development schedule:
AAMA will continue to advocate for ENERGY STAR products that are high performance in all aspects and are certified to validate that performance.