Regulatory Affairs Committee Discusses Legislative and Industry Updates at 75th Annual ConferenceMarch 29, 2012
At AAMA's 75th Annual Conference, Regulatory Affairs Committee members met to address Environmental Protection Agency (EPA) issues, including recommendations for the ENERGY STAR® 6.0 framework document and Lead Renovation, Repair and Painting (LRRP) rule; as well as important federal legislation and industry updates.
ENERGY STAR Windows, Doors and Skylights Framework Document
During the Committee meeting, AAMA President and CEO Rich Walker noted AAMA’s comments for the ENERGY STAR Windows, Doors and Skylights Version 6.0 Product Specification Framework Document.
AAMA used the comment period opportunity to call on EPA to revisit the timeline set for implementing revised ENERGY STAR guidelines and remind EPA of current economic conditions that would inhibit the ability of manufacturers to make necessary retrofitting changes, as well as raise product costs for homeowners.
AAMA recommendations included the following:
- The need for EPA to mandate full NAFS certification for windows and unit skylights, as the current network of laboratories are fully equipped and capable of any additional testing
- U-factor allowances should be provided for high-altitude fenestration products
- Further research is needed in advance of using life cycle analysis (LCA) within the ENERGY STAR program
- Support for the ENERGY STAR recommendation of providing installation instructions
On March 9, 2012, following the AAMA conference, the EPA released responses to comments for the ENERGY STAR 6.0 framework document. (Click here to view EPA’s comment response summary.)
EPA plans to contact stakeholders once the Draft 1 Criteria and Analysis Report is available for review in July 2012.
LRRP Rule for Public and Commercial Buildings Rule Development
Originally scheduled for a December 2011 release, the EPA has received an extension for promulgating its LRRP for Public and Commercial Buildings final rule. The extension allows for a final decision to be made through June of 2012.
Walker noted during the meeting that the Science Advisory Panel, which is composed of experts who provide independent scientific advice to the EPA, recognized that there is little to no empirical data related on lead dust exposures in public and commercial buildings and that applying empirical data from residential settings may produce uncertain results.Recently, AAMA announced its support for The Lead Exposure Reduction Amendments Act of 2012 (S2148), which seeks to restore the “Opt-Out” provision removed from the LRRP rule in April 2010.
Specifically, S2148 would restore the “Opt-Out” provision, suspend the LRRP rule if the EPA cannot approve commercially available test kits that meet the regulation’s requirements and restrict the EPA from expanding LRRP activities to commercial and public buildings until a study is conducted to prove necessity.
Formaldehyde Standards for Composite Wood Products Act
Walker also discussed the Formaldehyde Standards for Composite Wood Products Act, a law which establishes limits for formaldehyde emissions from composite wood products (e.g., hardwood plywood, medium-density fiberboard, and particleboard). When enacted, the federal law (based on the California Air Resources Board (CARB) rule) requires that the EPA develop and provide implementing regulations by January 1, 2013. A Notice of Proposed Rulemaking was scheduled for public comment in February 2012.
Cut Energy Bills at Home Act
Also during the Committee meeting, Walker discussed The Cut Energy Bills at Home Act (S1914). Introduced in November 2011, S1914 seeks to create a new tax credit for energy-efficient home improvements based on predicted annual energy cost savings from hot water, lighting, heating and cooling in a taxpayer’s primary residence.
According to the act, taxpayers will receive a minimum credit of $2,000 for products and installation if their homes’ energy costs are reduced by 20 percent. Taxpayers will receive $500 for each additional 5 percent reduction in energy costs, not exceeding $5,000 or 30 percent of taxpayers’ expenditures.
However, the bill requires the use of a contractor who is either certified through the Building Performance Institute (BPI) or RESNET. At this time, neither BPI nor RESNET have certified enough contractors to make this bill plausible across the country.
The Smart Energy Act of 2012
The Smart Energy Act of 2012 is pending legislation that seeks to establish a federal loan program for energy efficiency upgrades in both federal and private sectors. Walker noted that this program allows for upgrades to commercial, multifamily residential, industrial, municipal, government, school, institutes of higher learning and hospital buildings.
Contacting Local and Federal Legislators and Regulatory Agencies
Also regarding legislation, AAMA recently surveyed its members to determine the number of employees represented by the association. This information will be used, as applicable, to support our established positions on legislative and regulatory issues. The data has also been made available on the Members Only portion of the AAMA website, under the Legislation and Codes heading, for any members currently pursuing their own outreach initiatives to local or federal legislators or regulatory agencies.
The Regulatory Affairs Commit meeting concluded with a discussion of ASHRAE, ASTM and IGMA activity updates.
For a copy of the Annual Conference presentation given during the Regulatory Affairs Committee meeting and other activities of interest, please visit the Members Only section of the AAMA website.