Industry Weighs in on New ENERGY STAR Document

March 12th, 2012 by Editor

The U.S. Environmental Protection Agency (EPA) announced the release of the comment response summary for the ENERGY STAR Windows, Doors, and Skylights Version 6.0 Product Specification Framework Document. Many companies and associations within the door and window industry participated in the comment period, providing their views, comments and concerns on the development of the new document.

The feedback from the American Architectural Manufacturers Association, for example, was based on both individual member comments as well as the position taken by AAMA as an association representative of the fenestration industry as a whole.

Speaking of structural requirements, AAMA commented, “AAMA supports the requirement of full NAFS certification for windows and unit skylights and strongly believes that the current network of laboratories are fully-equipped and capable of any additional testing.” The association added that it supports NAFS / NFRC 400 requirements for doors, but “we question the validity of EPA’s statement that “less than a quarter of ENERGY STAR’s partnership base currently participates in NAFS certification.”

The comment goes on to say, “According to the 2010/2011 U.S. National Statistical Review and Forecast report prepared by Ducker Research Company and published by AAMA and WDMA, the entire residential window market size in 2010 was 41.6 million units. Within the AAMA Certification Program alone, 26.2 million NAFS labels were sold in 2010. Even after estimated reductions are made for labels sold for non-residential products, and especially after adding NAFS certification data from WDMA, NAMI and Keystone; it seems to be statistically impossible for less than a majority of the residential window units available in the marketplace to be certified to NAFS. With 81 percent ENERGY STAR penetration in the residential window market, it seemingly also would be mathematically improbable that less than a quarter of ENERGY STAR’s partnership base currently participates in NAFS certification.”

The Window and Door Manufacturers Association also submitted comments on the new document, noting that it support the inclusion of new provisions in the Version 6.0 criteria that would require window, skylight and sliding door products to be tested and certified to the applicable structural requirements in the NAFS in order to be ENERGY STAR qualified.

“Testing and certification to the NAFS is already required for compliance with the applicable structural requirements for these products in the International Building Code and International Residential Code, meaning ENERGY STAR qualified window, skylight and sliding door assemblies used in new construction must already be NAFS certified,” the WDMA commented. “We believe that ENERGY STAR criteria needs to ensure that these ENERGY STAR qualified products used in existing construction meet the same structural performance requirements as for new construction.”

According to the WDMA’s comments, the association suggested the ENERGY STAR program should, therefore, also require water penetration resistance, in addition to air infiltration resistance requirements for these products in accordance with or consistent with NAFS.

“The incorporation of water penetration resistance as well as structural requirements in the ENERGY STAR criteria is consistent with and compliments the incorporation of new air leakage requirements, all of which we believe would add greatly to the strength and credibility of the overall residential windows, doors and skylights program.”

And like AAMA, the WDMA also questioned the accuracy of the program’s reference to how many ENERGY STAR products are also NAFS certification.

The WDMA writes, “Regarding the Agency’s concern that new requirements for NAFS certification could lead to a backlog at testing facilities and inundate WDMA resources, we believe such concerns, while appreciated, may be greater than warranted … We believe the Agency’s concern is based on a significant underestimation of the number of ENERGY STAR products that are already NAFS certified.

“While WDMA and the AAMA are the leading NAFS certifiers there are other accredited entities that also certify products to NAFS. Although we do not know the actual numbers, we believe the 25 percent the Agency has cited as being certified through WDMA’s and AAMA’s programs is not an accurate representation of actual ENERGY STAR fenestration products that are NAFS certified. Regardless of the actual numbers, we believe NAFS certification should be required for the reasons stated above.”

The EPA responded that it appreciates the additional information stakeholders provided to clarify the matter and plans to reach out to the named organizations to request additional information.

All stakeholder comments are available on the ENERGY STAR website. The comment response summary is available here  as well as an addendum to the matrix here .

EPA says it plans to contact stakeholders once the Draft 1 Criteria and Analysis Report is ready for review in July 2012.

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