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Horse First, Then Cart: New Energy Star Guidelines for Windows & Doors

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In the South we have the expression: “Don’t put the cart before the horse.” It reminds us to keep things in the right order, to avoid confusion, because when things get mixed up they don’t work well.

When it comes to windows and doors, the latest Energy Star regulations may be putting the cart before the horse. I got a press release from the Window & Door Manufacturers Association (www.wdma.com) explaining that the program is being re-vamped with stricter requirements, and some of their members aren’t very happy about the upcoming changes.

The Energy Star program has a two-fold purpose: to encourage manufacturers to make energy-efficient products, and to encourage consumers to purchase energy-efficient products. In the past, the Environmental Protection Agency (EPA) would collaborate with manufacturers and consumer groups to collect input on the energy-saving guidelines. The window manufacturers engineered their products to meet those guidelines and reaped the benefits of marketing their product with the highly visible, government-sanctioned Energy Star logo. The manufacturers’ cross-promotion of the Energy Star seal helped to establish and legitimize the program.

However, now that the window manufacturers have helped to build the program into a recognizable and respected brand, the EPA is changing the rules without consultation of the manufacturers and consumers. Essentially, some windows that currently qualify as Energy Star-approved will in the future not qualify for the program. This doesn’t mean that those particular windows will be any less energy-efficient than they are today. It simply means that those windows won’t be able to carry the Energy Star stamp of approval.

By moving the goal posts, this leaves the window manufacturers in a tight spot. Ironically, the window makers were so successful in helping to establish the Energy Star program as an identifiable and sought-after designation that windows which don’t carry the logo are now more difficult to market. Of course, manufacturers can always re-engineer their products to increase their efficiency and meet the new Energy Star qualifications, but doing so will come at a cost, and that cost will be passed to the consumer—you and me.

In a nutshell, the new regulations will ultimately result in Energy Star windows that cost considerably more to manufacture, and in turn, to purchase. Qualifying windows may be too expensive for the average consumer to buy and likely discourage participation in the very program the government is supposedly trying to promote. And for those that can afford the new units, it will take a much longer time for them to recoup their investment in the expensive windows through the savings on their energy bills—making the qualifying units a tougher sell.

This seems backwards to me. I understand the Energy Star program has the noble goal of conserving energy, but it seems that whoever is in charge of making these regulations should learn that the cart works better when the horse is in front. Homeowners appreciate energy-efficiency, and people want to improve their homes. I think this taxpayer-funded program should make those goals as easy as possible to achieve.

— M. Weber

The original press release follows:

EPA Ignores Consumer Concerns and Industry Objections in Final ENERGY STAR Draft Proposal

[Washington DC] – The ENERGY STAR Program marked a sharp departure from its past practice of collaborating with industry partners to balance consumer accessibility against the need to raise efficiency standards over time with the final draft of Version 6.0 program requirements for residential windows, doors, and skylights, released today.

The program has taken an unjustified and unprecedented step to target a deep cut in the share of ENERGY STAR windows and skylights sold to average consumers. Past revisions have focused on incremental gains in efficiency that still would promise a reasonable payback period for fenestration products carrying the ENERGY STAR label. In an earlier Version 6.0 draft, the program admitted it set the proposed standards for windows with a goal of reaching “a market share of less than 50% after the Version 6.0 specification takes effect” from just over 80%. (Version 6.0 Draft 1 Criteria and Analysis Report, p8.)

“Because of the program’s past success, consumers expect to recoup the cost of ENERGY STAR labeled products through energy savings in a reasonable period and they doubt the efficiency of products without the label,” said Michael O’Brien, CEO of the Window & Door Manufacturers Association. “Version 6.0 takes away reasonable payback periods for much of the country and will strip the ENERGY STAR label from affordable energy efficient products that do offer a fair payback period.”

Fenestration industry leaders are not alone in their concerns about Version 6.0. The Coalition for Home Energy Efficiency, a coalition of environmental and consumer advocates, manufacturers, and retailers – launched a petition to save the ENERGY STAR program. The petition has gathered more than 20,000 signatures in a matter or several weeks over concerns that ENERGY STAR products will be priced out of reach of average consumers. A bipartisan group of 23 Congressmen signed a letter asking the Obama Administration to “re-examine the proposed ENERGY STAR specifications for windows, doors, and skylights to ensure that they are consistent with the guiding principles of the program.”

Stakeholders repeatedly have raised concerns throughout the Version 6.0 revision process. The program has not responded directly to many of those concerns and has pointed to confidential data and a questionable methodology to justify its analysis. To meet their procedural requirements, the effective date has been shifted to Jan. 1, 2015 from Jan. 1, 2014. The U-factor for windows in the North-central zone has shifted to .30 from .29. But the area of greatest concern to consumers and the industry – the Northern zone criteria – remains unchanged. The Northern zone covers almost half of the country.

“To the program’s credit, the final draft offered some concessions, but they did not address our primary concerns about transparency and fairness,” said O’Brien. “This is a major set-back for average consumers and for the industry, which has been committed to improving energy efficiency standards over the last decades.

WDMA hopes to work closely with EPA to address the concerns of its members about the agency’s recent lack of transparency and departure from the program’s guiding principles during the Version 6.0 process.  Looking forward to the Version 7.0 revision, WDMA members strongly encourage EPA to implement an open process that includes all stakeholders and remains true to ENERGY STAR’s guiding principles.

“Industry partners, consumers and taxpayers have developed reasonable expectations about the goals of the ENERGY STAR program over two decades,” said O’Brien. “Any changes to the program’s mission should be discussed openly and stakeholders should play a role in that discussion.”

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