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CLEVELAND TOLEDO AKRON COLUMBUS CINCINNATI FORT MYERS NAPLES

www.ralaw.com

September 28, 2001

Mr. Gary Curtis

D & R International

147 Commercial Street NE

Salem, OR 97301

E-mail: garyc@drintl.com

Fax: 503.364.4146

**Re: Comments to DOE's Proposed Revisions to Energy Star Window
Criteria**

Dear Mr. Curtis:

I have been authorized to express the following comments on behalf of
Pilkington North

America, Inc., PPG Industries, Inc. and AFG Industries, (referred to in
this letter for simplicity as

the " Three Glass Manufacturers" or "TGM") to the two-step changes that
have been proposed to

the criteria for the Energy Star Window and Door Program as outlined in
William Noel's letter of

August 31, 2001 ("DOE Proposal"). Consistent with our e-mail exchange, I
appreciate your

willingness to receive and consider these comments through September 28,
2001.

As you know Gary, all Three Glass Manufacturers have been directly
involved in various

discussions on revisions to Energy Star Windows. As background for this
level of interest, the

TGM represent over 60% of the glass sold into the residential market,
including a wide range of

energy efficient products.

The TGM have reviewed the Step 1 and Step 2 proposed revisions to Energy
Star

Windows and have achieved a technical consensus that DOE's proposed
revisions are not

beneficial and, therefore, the TGM urges DOE to consider the alternative
proposals which are

outlined in the attached Appendix. The consensus reached by the TGM
regarding the proposed

revisions is as follows.

Step 1 of DOE's Proposal is unacceptable. It will increase energy
consumption and

contrasts significantly from the International Energy Conservation Code
("IECC) relative to the

2000 HDD line for the "Central" geographical region of the United
States. September 28, 2001

Page 2

As an alternative, the TGM proposes a Step 1 revision that will result
in energy savings

and be consistent with the IECC relative to energy conservation
requirements and geographical

divisions.

Regarding Step 2 of the DOE's proposal, the TGM is opposed to the single
U-factor /

SHGC limit for the entire USA. Whereas, such an approach can easily be
applied to household

appliances, it is simply unrealistic and, quite frankly, detrimental as
a vehicle to promote energy

conservation and the use of renewable energy sources in the diverse
weather environments found

across the United States.

We would particularly encourage DOE to reconsider its proposal to apply
the IECC's

most severe, southern region SHGC of 0.40 throughout all climatic
regions of the United States.

The application of such a SHGC limit value in the central U.S. and all
of the northern U.S. is

completely unjustified by any technical or engineering analysis. In that
regard, the IECC imposes

no such SHGC limitation on any region above 3,500 HDDs. Moreover, our
calculations show

that adherence to step 2 of DOE's Proposal will actually result in an
**increase** in energy

consumption in the north and central regions of the United States. Our
calculations show that a

typical new home in the northern region (above 6000 HDDs) will
experience an annual reduction

in energy consumption of 2.3 million Btu's if windows having a U-factor
of 0.35 and a SHGC of

0.50 are used, rather than windows having a 0.35 U-factor and a 0.40
SHGC as outlined in step 2

of the DOE Proposal. Similarly, a new home in the central region
(between 3500 and 6000

HDDs) would experience an annual reduction of energy usage of 1.1
million Btu's.

DOE's Step 2 Proposal is also completely inconsistent with the
Congressional mandate

resulting in the creation of the Energy Star Program. The Congressional
objective is to increase

energy efficiency and reduce the Country's dependence on non-renewable
sources of energy.

The adoption of a national SHGC of 0.40 will not advance either
objective. While the 0.40

SHGC limit may reduce peak load demands during a few extreme days of
heat in the summer, it

will only do so at the expense of a significant increase in overall
energy consumption throughout

the remainder of the year.

As a result of the overall energy consumption increase, the TGM are
completely and

uniformly opposed to the second step of DOE's Proposal. It is not
supported in any manner by

the requirements of the IECC. Indeed, it has no technical justification
at all. It will result in an

increase in energy usage in the north and central regions of the United
States. At the same time,

it will reduce the benefits that can be derived from passive solar heat
gain through the widows by

homeowners in the central and northern regions of the United States. The
TGM urges DOE to

adopt our Step 2 proposal as set out in the attached Appendix. September
28, 2001

Page 3

The TGM's proposals also meet or exceed all changes resulting from the
adoption of

Title 24 in California and the requirements of the IECC. They are
technically sound and

accomplish the twin objectives of the Energy Star Program, namely,
energy conservation and

encouraging the use of renewable energy sources.

We urge you to adopt the changes to the program articulated in the
attached Appendix. If

there remains major opposition from window manufacturer's regarding the
proposed changes

within the program over the next 15 months, then DOE should re-open the
comment period

relative to the second step of its proposal. If DOE is unwilling to
extend the time necessary to

hear additional industry concerns respecting the second step of its
proposal, the TGM urges DOE

to consider the TGM second step as articulated in the attached

Very truly yours,

Thomas S. Zaremba, on behalf of:

Pilkington North America, Inc., by Paul M. Gore

PPG Industries, Inc., by Al Lutz, and

AFG Industries, Inc. by Thomas J. Mewbourne

cc: William Noel,

Department of Energy

Office of Building Technologies

1000 Independence Ave., SW

Room 5E-098 EE042

Washington D.C. 20585

e-mail: william.noel@hq.doe.gov

fax: 202.586.1233

September 28, 2001

Page 4

**APPENDIX**

**Step 1 - Change in Energy Star Criteria**

**U-factor SHGC**

**Northern Region** 0.35 Any \> 6000 HDD

**Central Region** 0.40 0.55 3500 - 6000 HDD

**Southern Region** 0.50 0.40 \< 3500 HDD

U-factor and SHGC values represent maximum values

**Step 2 - Change in Energy Star Criteria**

**U-factor SHGC**

**\> = 3500 HDD** 0.35 Any

**\< 3500 HDD** 0.50 0.40

U-factor and SHGC values represent maximum values

41827_1

From: Noznesky, Douglas \[DNoznesky@stanleyworks.com\]

Sent: Thursday, September 27, 2001 3:54 PM

To: Maureen Kuhlman

Subject: RE: Proposed criteria changes for ENERGY STAR

To Whom It May Concern:

We feel that the current proposal for windows and doors is acceptable.

However, there are some issues which have not been completely addressed
for

doors:

-The Energy Star two phase proposal is too confusing. We would like to
see

the intermediate step removed and the final step moved from Jan. 1, 2003
to

Jan. 1, 2002.

-There are no details given on the Energy Star requirements for
sidelites.

-There currently exists no NFRC label for doors. We would like to see
the

labeling requirements simplified or eliminated. Requiring an NFRC
listing

only without an NFRC label for Energy Star would be ideal. With the
current

arrangement, we would need dozens of different label combinations for
every

glass size, configuration, thickness, product line, etc.

In whole, the proposal is fair and equitable as it currently exists.

Regards,

Doug Noznesky

Stanley Doors

![](media/image20.png){width="0.9479166666666666in"
height="1.1770833333333333in"}

Date: September 17, 2001

To: Gary Curtis, D&R International

D&R International

147 Commercial Street NE

Salem, OR 97301

Re: DOE proposed change to Energy Star criteria

We have reviewed the August 31, 2001 memo issued on the change to the
qualification criteria. As participants in the Energy Star program, we
at Sierra Pacific Windows have some comments and concerns, specifically
with the changes scheduled for 2003:

1\. Simplifying the program for consumers by establishing a single
nationwide specification, in our opinion, somewhat defeats the purpose
of the program. Specifically, setting the SHGC upper limit at .40
ignores the needs of consumers in the colder climates of the northern
region. We regularly receive requests for product that will allow for
passive solar heat gain in order to reduce heating (energy) costs. This
proposed change goes against the benefits higher SHGC in these
instances.

In addition, we question the argument that this "simplification" is
helpful to the consumer. It appears to be misdirected. The difficulty in
understanding the Energy Star requirements is not that there are three
regions, but rather the meaning of the U-factors and SHGC numbers. It
has been our experience that, to date, consumers have been satisfied
knowing that our company is participating in the Energy Star program.
Those who wish to understand the U-factors and SHGCs have no trouble
understanding the establishment of three regions.

2\. Tightening the U-factor upper limit at .35 for the current central
and southern regions may have consumers paying more for windows.
Reducing the U-factor from .40 to .35 will result in many window
manufacturers having to provide, at least in the short term, a more
expensive product.

3\. Upon review of the summary of stakeholder comments dated 9-7-01, it
appears as if there is concern by others regarding the reduction of
U-factors. We are in agreement with those expressing caution against
having Energy Star lead by so great a margin that values would be
difficult to attain. In addition, we are also in agreement with a
proposal put forth by a major glass manufacturer recommending northern
region requirements of U-factor ≤ .40 and SHGC ≥ .50. Their comparison
made using Resfen, shows these requirements would yield the same energy
usage as a window with a .35 U-factor and .37 SHGC.

As a manufacturer, we truly question whether this change is being made
in the best interest of the consumer or the best interests of some
participating members. We strongly request that these proposed changes
be re-evaluated. If you would like to discuss this further, please give
me a call at your convenience.

Thank you for your attention.

Sincerely,

Rick Audsley

Sierra Pacific Windows

cc: Kendall Pierson

Rod Preston

From: Steve Berberian \[Steve.Berberian@harveyind.com\]

Sent: Friday, September 07, 2001 6:42 AM

To: \'mkuhlman@drintl.com\'

Cc: Jim Barreira; Tom Russell; Dan LaPlante; Dave Lambert

Subject: RE: Proposed criteria changes for ENERGY STAR

Maureen,

The planned changes to the Energy Star Program would have a profound
adverse

effect to our current marketing programs.

Effective 1/1/02 these proposed changes would reduce our Energy Star

compliance in the central region (south of Boston and Worcester, MA,
north

of Charleston, SC) approximately 80% because of the 0.40 SHGC
requirement.

Most of our SHGC are 0.42-0.46.

We would remain Energy Star compliant for the Northern region only until

1/1/03. At that time we will only have approximately 10 products Energy
Star

compliant, and they would all need a double low-E IG unit to qualify
because

of the 0.40 SHGC requirement.

Currently we can glaze all of our windows with low-E and Argon filling
and

achieve the energy star requirements for the Northern and Central
regions.

The proposed changes would not be good for Harvey Industries.

Please advise as to what our options are, if these proposed changes will
in

fact go through, and what the motivation is behind the proposal. It
appears

like the rules are changing now that we have all signed on. Please
advise

ASAP.

Thanks, - Steve

Stephen K. Berberian

Product Development Manager

Harvey Industries, Inc.

725 Huse Road

Manchester, New Hampshire 03103-2339

Business Phone: 603-622-4232

Business Fax: 603-669-8945

e-mail: steve.berberian@harveyind.com

website: www.harveyind.com

1025 Thomas Jefferson Street, N.W. Eighth Floor West Tower Washington,
D.C. 20007 Tel: 202-342-0800 Fax: 202-342-0807

August 3, 2001

**VIA E-MAIL & FEDERAL EXPRESS**

Mr. Gary Curtis

D&R International

147 Commercial Street, NE

Salem, OR 97301

Re: Comments on Modification of Energy Star Window & Door Criteria to
Satisfy

Current Building Energy Efficiency Codes

Dear Gary:

Enclosed are our comments in response to the Department of Energy's
request for

participation and comment by interested parties in identifying options
to address potential

changes to the ENERGY STAR Windows program criteria in response to
current model energy

codes and recent state adoption of energy codes.

Our firm has reviewed and offered comments regarding the ENERGY STAR
Windows

program since its inception. We have also actively participated in the
development of the 2000

International Energy Conservation Code (IECC), the current, nationally
accepted model energy

code, and many state-developed codes. Finally, we are a member of NFRC,
where I serve on the

Board, representing the building industry.

In light of this experience, we have prepared the enclosed comments and
a

recommendation to the Department for potential changes to ENERGY STAR
criteria. Our

recommendation is based upon criteria for windows (including doors and
skylights) that would

meet or exceed the IECC and other state developed codes, while working
within the existing

ENERGY STAR windows Northern, Central and Southern zones framework.

We appreciate the opportunity to provide these comments, and we look
forward to

working with you and the Department during this review process.

Please contact us if you have any questions.

Sincerely,

Garrett A. Stone

GAS:pgg

**COMMENTS ON**

**MODIFICATION OF ENERGY**

**STAR WINDOW & DOOR**

**CRITERIA TO SATISFY**

**CURRENT BUILDING ENERGY**

**EFFICIENCY CODES**

**August 3, 2001**

**Garrett A. Stone**

**Eric M. DeVito**

**Brickfield, Burchette, Ritts & Stone, PC**

**1025 Thomas Jefferson Street, NW**

**Washington, DC 20007**

**ph. 202-342-0800**

**fax 202-342-0807**

**e-mail: gas@bbrslaw.com**

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 1**

**COMMENTS ON MODIFICATION OF ENERGY STAR**

**WINDOW & DOOR CRITERIA TO SATISFY CURRENT**

**BUILDING ENERGY EFFICIENCY CODES**

**INTRODUCTION AND EXECUTIVE SUMMARY**

In the notice to ENERGY STAR™ Windows stakeholders last month, the
United

States Department of Energy has identified the fact that recent code
changes have

resulted in fenestration code requirements that equal or exceed the
ENERGY STAR

Windows criteria and has requested interested parties to submit comments
on how the

ENERGY STAR Windows program criteria might be modified in order to meet
or exceed

these requirements.

In response to this request, we offer the following comments regarding
potential

changes to the ENERGY STAR windows criteria (including glazed doors and
skylights)

and the possible adoption of new criteria for opaque and mostly-opaque
doors. Given

our experience with building energy efficiency codes and voluntary
energy efficiency

programs, we have evaluated the existing specifications in light of the
evolution of

building energy efficiency codes over the past few years and identify
below what we

believe is the optimal solution to modifying the program to satisfy
current code

requirements. The approach outlined in these comments is limited to
satisfying current

code requirements based on the express limitations set forth in the
Department's

notice.

We have concluded that certain fundamental principles have historically
been

incorporated into the ENERGY STAR platform and should remain the
guideposts for this

round of modifications to the criteria. Specifically, the ENERGY STAR
Windows program

should strive to:

Be as simple for the consumer as possible and avoid any

complication that could cause marketplace confusion and undercut

the overall message;

Meet code requirements at a minimum, but ideally exceed code

requirements so as to move the marketplace above the minimum

standard -- the code standard should be based on the national

model code recently endorsed by the Department (the 2000

International Energy Conservation Code -- the widespread state

adoption of this code now occurring underscores the use of this

standard), although some consideration should also be given to the

requirements of state-specific codes like California;

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 2**

Make sufficient changes in each round of improvements to the

criteria, such as to avoid constant new modifications, but limit

unnecessary modifications where possible to maintain continuity;

Do not exceed realistic products available in the marketplace (e.g.,

do not require triple glazing or darkly-tinted products); and

Incorporate and promote relevant NFRC ratings.

We have concluded that the best approach to meet all of these objectives
would

include: (1) a change to the criteria of the Central Zone to incorporate
a code-compliant

SHGC; (2) reasonable revisions to the ENERGY STAR map to align with
code-based

climate zones; and (3) adoption of an air leakage requirement.

At a minimum, the criteria must be improved to meet code everywhere. We

believe that this can best be accomplished by utilizing the replacement
fenestration

criteria of the IECC, which provide a somewhat simplified, convenient
set of minimum

criteria by climate zone (these criteria are also the most stringent
prescriptive code

criteria for fenestration due to the simplified climate zones). The IECC
specifications

that are more stringent than ENERGY STAR in certain climate zones are a
0.50 U-factor

above 2,000 Heating Degree Days (HDD), a 0.40 SHGC up to 3,500 HDD, and
a 0.35

U-factor down to 6,000 HDD (these criteria effectively create 5 zones
under the IECC).1

The code also requires a 0.3 cfm/ft 2 maximum air leakage everywhere.2

In order to avoid increasing the number of zones (which would increase

confusion and complexity), reasonable revisions to the ENERGY STAR map,
along with a

change to the criteria of the Central Zone and adoption of the air
leakage requirement

could effectively achieve code compliance. Specifically, we would
recommend under

this option that:

\(1\) The Southern zone be limited to areas less than 2,000 HDD, the
Central

zone extend from 2,000 HDD to less than 6,000 HDD and the Northern

zone apply to 6,000 HDD and above (with this change, the ENERGY STAR

U-factor will equal the IECC U-factor for the Southern and Northern
zones

and equal or exceed the IECC U-factor for the Central zone);

\(2\) Maximum SHGC be set at 0.4 for the Central zone (consistent with
the

IECC requirement); and

\(3\) Maximum air leakage for all zones be set at 0.3.

1 *See* 2000 IECC Section 502.2.5: Prescriptive Path for Additions and
Window Replacements, and

Table 502.2.5: Prescriptive Envelope Criteria Additions to and
Replacement Windows for Existing

Type A-1 Residential Buildings. *See also* 2000 IECC Sections 502.1.5 &
502.2.4.15:

Fenestration Solar Heat Gain Coefficient.

2 *See* 2000 IECC Section 502.1.4: Air Leakage and Table 502.1.4.1:
Allowable Air Infiltration Rates.

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 3**

We recommend that the windows criteria also consistently be applied to
all doors

(including opaque doors) and skylights to the degree possible. Limiting
differences in

the criteria for each of these products will reduce confusion and
enhance simplicity.

While we understand the argument that some opaque doors can achieve
better U-factors

and SHGCs than glazed doors under certain circumstances, we think any

benefits from a higher standard for such doors are far outweighed by the
increased

complexity and potential confusion (after all, opaque doors are a very
small percentage

of the building envelope). At a minimum, all doors with some glazed area
should be

required to meet the windows criteria.

The only difference in criteria among fenestration products that we
believe can

be justified at this time is a more lenient skylight U-factor criteria.
The IECC specifically

requires that skylights have a U-factor of 0.50 or better for climates
with HDD greater

than or equal to 2,000. 3 This standard, or the existing ENERGY STAR
U-factor standards

for skylights, would seem most appropriate. Using a 0.35 or 0.40
U-factor standard for

such products would be unreasonable.

Finally, we believe that is important to recognize that there are other
potential

criteria, although not code-required and therefore outside the scope of
this round of

revisions, that the Department should consider for future revisions of
the ENERGY STAR

criteria. Specifically, NFRC is in the process of rolling out new
energy-related ratings,

such as condensation and fading resistance, that should ultimately be
considered for

incorporation into ENERGY STAR. NFRC's existing VT rating is another
possible

consideration. Durability (e.g., the permanence of the energy efficiency
features)

should also be incorporated. Since there is no such durability rating
presently available,

a strong warranty requirement could be utilized as a proxy.

In sum, with limited modifications -- e.g., the map, Central climate
zone SHGC,

and air leakage -- the ENERGY STAR Windows program can be brought into
consistency

with current building energy efficiency codes. We recommend that the
Department

make these essential modifications.

**INDUSTRY AND CODE IMPROVEMENTS SINCE THE ENERGY STAR WINDOWS PROGRAM
WAS**

**INITIATED**

Since the ENERGY STAR Windows program was implemented in early 1998,

considerable strides have been made in the entire fenestration arena.
For example,

over the past several years, the NFRC program has become widely
implemented by

window manufacturers and has achieved general acceptance by industry
stakeholders

throughout the country. When NFRC first published its Certified Product
Directory in

3 *See* 2000 IECC Section 502.2.5: Prescriptive Path for Additions and
Window Replacements.

**"Exception:** Replacement skylights shall have a maximum U-factor of

0.50 when installed in any location above 1,999 HDD."

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 4**

1993, less than 4,000 products were rated for U-factor and none were
rated for SHGC.

The NFRC CPD now reports that over 82,000 products are rated for
U-factor and over

60,000 are rated for SHGC. ENERGY STAR and improved codes have both
contributed

hugely to this progress by essentially requiring NFRC ratings.

Moreover, the NFRC-rated product statistics show substantial numbers of

products at the most stringent levels of performance. The following
graphic diagrams

the breakdown of NFRC ratings in relation to existing ENERGY STAR window

requirements.

**NFRC Product Distribution**

**Energy**

**Star**

**Zone**

**U-factor \# of**

**Products**

**% of**

**Total SHGC \# of Products**

**% of Total**

All U-factors 82,678 \-- All SHGCs 60,050 \--

**Northern** 0.35 and below 28,578 35%

**Central** 0.40 and below 44,918 54% 0.55 and below 53,878 90%

**Southern** 0.75 and below 80,078 97% 0.40 and below 29,580 49%

Source: NFRC Certified Products Directory, 9 th Ed. (available online at
www.nfrc.org).

Again this level of availability of very efficient products is a
function of both the

success of the ENERGY STAR window program and improved codes. Over the
past

several years the national model code, the IECC, as well as
state-specific codes in

states like California and Florida, has significantly improved the code
requirements for

fenestration products. Indeed, as the Department has noted, the
stringency of the

performance and prescriptive requirements for fenestration in the IECC
has brought

codes to the level of, or even exceeding, ENERGY STAR. The IECC has also
made it

easier for builders to determine which windows will comply with the code
in various

parts of the country.

A brief summary of fenestration code improvements helps to place the
IECC's

present requirements into perspective. The progression started in the
1995 edition of

the Model Energy Code, the immediate predecessor to the IECC. For the
first time in

the 1995 version, the MEC required all fenestration products to be
rated, certified and

labeled with NFRC U-factors, or by a limited default table. In 1998,
with the first edition

of the IECC, the national model code took another bold step by adding
requirements to

reduce solar heat gain. Specifically, the IECC requires all fenestration
(new,

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 5**

replacement, and additions) installed in locations with heating
degree-days less than

3,500 to have SHGCs of 0.40 and below.4 The 1998 version also added
prescriptive

tables to allow users to readily determine which windows will meet the
code in various

climatic regions, and it added prescriptive U-factor and SHGC
requirements for

fenestration in additions and replacements. The 2000 IECC retains all of
these

fenestration requirements and added a new simplified prescriptive option
to ease

compliance. (This same simplified prescriptive option (as well as other
fenestration

requirements) is found in the 2000 International Residential Code --
Chapter 11.)

Finally, the IECC and IRC contain a prescriptive requirement for air
leakage -- a

maximum 0.3. 5

With these new fenestration provisions, the IECC now contains
prescriptive

window requirements that are in some areas of the country more stringent
than those

under the ENERGY STAR Windows program. This creates an obvious anomaly
in that a

federally sponsored market transformation program with a goal to promote
energy

efficient windows actually promotes some windows that would not meet
minimum

requirements under the national model energy code. This is truly an
anomaly because,

as it is often described, the IECC, when adopted in a state, specifies
the absolute worst

window allowed by law. For ENERGY STAR to be less stringent than the
code would

certainly send the wrong message.

The 2000 IECC is the current, nationally accepted model energy code
standard

and, as a result, is the appropriate source of code requirements on
which to base a

national energy efficiency program such as ENERGY STAR. This is
evidenced by the

Department of Energy's own certification of the 2000 IECC in early 2001
under the

Energy Policy Act.6 As a result, States are now legally required to
consider updating to

the 2000 IECC, as many have already done. It would be inconceivable that
the

Department would rely on any source in lieu of the 2000 IECC. In fact,
in its

determination, the Department specifically called out two
fenestration-related

improvements to the IECC, the SHGC requirement and the replacement
windows

requirement, as the only major improvements over the MEC.7

4 *See* n.1 above.

5 *See* n.2 above.

6 BUILDING ENERGY STANDARDS PROGRAM: DETERMINATIONS REGARDING ENERGY
EFFICIENCY

IMPROVEMENTS IN THE 1998 AND THE 2000 INTERNATIONAL ENERGY CONSERVATION
CODES FOR

RESIDENTIAL BUILDINGS, 66 Fed. Reg. 1964 (Jan. 10, 2001). With this
Determination, the Energy

Policy Act of 1992 now requires each State, not later than January 10,
2003, to certify to the

Secretary of Energy that it has reviewed the provisions of the 2000
International Energy

Conservation Code ("IECC") and make a determination as to whether it is
appropriate to adopt the

IECC or revise its current building code provisions to meet or exceed
the IECC.

7 *See* DOE DETERMINATION, n.6 above, at pp. 1965, 1968.

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 6**

Texas has received considerable attention lately because it took a
monumental

step by adopting the International Residential Code for new
construction, additions and

replacements. Until this year, Texas had no energy code, or any building
code for that

matter. As mentioned above, the IRC's energy chapter (Ch. 11) contains
the same

fenestration requirements as the IECC for homes with up to 15% glazing
and for

replacement fenestration. For homes with greater than 15% glazing, the
IRC

incorporates the IECC by reference, including its various prescriptive,
component

performance and systems analysis approaches.8

Adoption of the IRC by the state of Texas breaks down any barriers that
may

have existed in the southern United States to IECC adoption. Prior to
the recent surge

of IECC adoption in southern states, many had predicted that the IECC
would face an

uphill battle in southern states. Suffice it to say, this "uphill
battle" in warm-weather

states has been far less than expected: California has created their own
code that

contains fenestration requirements similar in stringency to the IECC
U-factor and SHGC

requirements; South Carolina has adopted the IECC without substantive
amendment;

as just mentioned, Texas has adopted the IRC with direct reference to
the IECC for

homes above 15% glazing; Arizona has adopted the IECC voluntarily;
Florida has

adopted requirements similar to the IECC; and Georgia is currently
reviewing the IECC

for potential adoption.9

States farther north are also moving forward with IECC adoption:
Maryland has

adopted the IECC without substantive amendment, and New York and
Pennsylvania

have adopted and are in the final stages of implementing the IECC. Other
states and

localities can be expected to adopt the 2000 IECC over the next few
years. As

evidenced by the rapid adoption of the IECC throughout the U.S., it is
safe to say that

the IECC is the proper baseline from which to compare existing ENERGY
STAR.

Furthermore, through our review of other state-developed codes, none
appear to have

fenestration requirements more stringent than the IECC standards for
replacement

windows. For these reasons, the IECC provides an excellent baseline from
which to

measure the existing ENERGY STAR program.

8 *See* 2000 IRC Section N1102.1 Residential buildings, Type A-1.
"Compliance shall be

demonstrated by either:

1\. Meeting the requirements of this chapter for buildings with a

glazing area that does not exceed 15 percent of the gross area of

exterior walls; or

2\. Meeting the requirements of the *International Energy*

*Conservation Code* for residential buildings, Type A-1."

9 North Carolina has adopted the IECC. However, we have not included
North Carolina in this list

because the state, during its statewide code development process,
deleted the IECC's 0.40

maximum SHGC requirement, which would have applied in roughly 2/3 of the
state. However, we

expect North Carolina to adopt the provision in the future.

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 7**

**EXISTING ENERGY STAR IS LESS STRINGENT THAN THE IECC**

For simplicity, the easiest comparison to the IECC can be made by
looking at the

IECC additions and replacement window prescriptive requirements (in
Chapter 5),

which are diagrammed in the color-coded map in **Attachment** 1. The
existing IECC

maximum 0.4 SHGC requirement (for new homes, in additions, and as
replacements) is

mapped out in **Attachment** 2.

A prime case in point of areas where ENERGY STAR falls behind the IECC
is in

many southern parts of the country. As an example, in the Dallas
metropolitan area, a

window carrying the ENERGY STAR label may not meet the IECC/IRC recently
adopted in

the state. Dallas falls into the Southern ENERGY STAR zone (0.75
U-factor and 0.4

SHGC). As indicated in **Attachment** 1, under the IECC/IRC, windows
used in additions

and replacements must have a U-factor 0.50 or below and a maximum 0.4
SHGC (the

same 0.4 SHGC requirement as ENERGY STAR). For new homes in Dallas with
a

maximum glazing area of 15%, the IECC/IRC U-factor requirement is
slightly higher at

0.65. Regardless, it is quite evident that an ENERGY STAR labeled window
in Dallas

would not necessarily meet the Texas energy code. In addition, the
current ENERGY

STAR criteria would be inconsistent with existing utility programs in
Texas. Under a

Texas Public Utility Commission approved market transformation program,
the Texas

Window Initiative currently educates and encourages consumers to
purchase windows

that have below a 0.40 U-factor and 0.40 SHGC to realize all potential
cooling savings

and heating savings and to provide added insulation benefits of low
U-factor windows.

While the ENERGY STAR U-factor fails in Texas, as another example, the
ENERGY STAR

SHGC fails in South Carolina, where the IECC (which has been adopted in
South

Carolina) requires a 0.4 SHGC in parts of the state where ENERGY STAR
(Central climate

zone) would only require a 0.55 SHGC.

ENERGY STAR also falls short in much of California. Current ENERGY STAR

requires a maximum 0.4 SHGC in southern California only. Under
California's new Title

24 energy efficiency standards, all windows (in all orientations)
installed in areas with

notable air conditioning loads must meet a maximum 0.4 SHGC requirement,
which

covers 11 of the state's 16 climate zones; only northern California,
some coastal areas,

and the mountain regions are exempt.10 The IECC's 0.4 SHGC requirement
would

apply in generally the same areas.

Air leakage is another area where ENERGY STAR falls short of the IECC.
The

IECC, and many state-developed codes, including California, contain
maximum air

leakage requirements for fenestration (windows, skylights, swinging and
sliding doors).

ENERGY STAR has no requirement for air leakage. The IECC requires all
windows and

10 *See* California AB 970 Energy Efficiency Standards for Residential
and Nonresidential Buildings,

Tables 1-Z1 through 1-Z16, "Alternative Component Packages" for Climate
Zones 1 -- 16.

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 8**

sliding doors to have air leakage rates below 0.3 cfm/ft 2 and swinging
doors to be below

0.5 cfm/ft 2 when tested in accordance with ASTM E 283. 11

**NECESSARY MODIFICATIONS FOR ENERGY STAR CRITERIA TO EQUAL CODE**

Within the existing ENERGY STAR framework, various adjustments can be
made

to bring ENERGY STAR up to the code. In a nutshell, ENERGY STAR's
existing maximum

0.75 U-factor requirement extends too far north, and its existing
maximum 0.4 SHGC

requirement does not extend far enough north. Likewise, the 0.35
northern U-factor

does not extend far enough south. In some zones, or some parts of
existing zones,

current ENERGY STAR need not change significantly to keep pace with the
IECC.

**Attachment 3** sets out a revised map and U-factor and SHGC criteria
consistent with

the IECC. We recommend adoption of these criteria as discussed below.

**A. ENERGY STAR Northern**

The existing 0.35 maximum U-factor requirement continues to represent
the best

available technology to provide maximum cost-effective insulating
benefit. Moreover,

the code requires a maximum 0.35 U-factor. 35% of the current products
rated under

NFRC have U-factors of 0.35 and below. This indicates that the
technology is readily

available. Maintaining the 0.35 maximum U-factor would continue to push
the market

to this level of efficiency. Lowering this requirement further would
push manufacturers

into triple glazing, which never has been shown to be cost-effective,
nor would it be

required by code -- a 0.35 U-factor is the lowest level required by the
IECC.

If the goal is to meet the code, we recommend leaving the existing
Northern

zone requirements as they are now. However, to keep pace with the IECC,
the area

falling under the Northern zone must be adjusted to some extent. To
equal the IECC's

U-factor requirements, the Northern line should be readjusted to require
the 0.35 U-factor in all of Nebraska and Iowa, in the northern parts of
Illinois, Indiana and Ohio, in

a much larger portion of Pennsylvania, and in parts of West Virginia.
(See

**Attachment** 3). This approach would apply the 0.35 U-factor to areas
with HDD equal

to or greater than 6,000 HDD, consistent with the IECC requirements.

**B. ENERGY STAR Central**

The most significant change to existing ENERGY STAR are the changes
needed in

the Central zone. The required Central zone changes have the potential
to generate

significant heating energy and cooling peak and energy savings
previously untouched

by ENERGY STAR. Specifically, the Central zone's southern boundary
should be

11 *See* n.2 above.

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 9**

extended down to 2,000 HDD and its SHGC requirement should be reduced to
0.4

SHGC.

If these limited changes are not made, ENERGY STAR would be required to

establish a fourth, South Central zone to be consistent with code
requirements, with at

least a 0.50 U-factor and 0.40 SHGC maximum, extending from 2,000 HDD to
3,500

HDD. Such a change would unnecessarily complicate ENERGY STAR and
confuse

customers who have grown accustomed to the existing three zone approach.

Adoption of the 0.4 SHGC for the Central zone is warranted because in
many of

these areas, there are significant cooling requirements during
warm-weather months,

which necessitate high summer peak load capacity for utilities in this
region. Many

areas of California are prime examples of where a maximum 0.4 SHGC is
warranted

and already required by Title 24 (and would also be required under the
IECC). Peak

demand reduction is also critical, particularly given the recent crises
in California and

other states involving available summer peak electric capacity.
Shortages in summer

peak electric capacity in California were the key drivers behind AB 970,
which is the

legislation that forced a review of California's energy efficiency
standards. Expanding

the 0.4 SHGC requirement across much of the state provided an easy
solution because

of the cost-effective summer peak electric demand savings associated
with it.

Furthermore, such a change would not involve significant cost or
technology

advancement. Windows sold in the Central zone already require a low-e
coating to

meet the 0.40 U-factor requirement. Revising the requirements to require
a low solar

gain low-e coating in the Central zone would be easily achievable
through available

technology -- almost half the windows rated through NFRC have SHGCs of
0.4 and

below. This technology shift would impose the same or very similar cost
when

compared to any low-e coating currently being used to meet the 0.40
U-factor

requirement. A maximum 0.4 SHGC would provide significant cooling peak
demand

and energy savings in these regions, while at the same time deliver the
heating savings

already required under ENERGY STAR U-factor requirements for the Central
zone.

When comparing IECC to ENERGY STAR, the IECC requires the 0.4 maximum

SHGC in many more climate zones. Areas that are, for the most part,
currently missed

by ENERGY STAR and captured by the IECC 0.4 SHGC requirement include,
Oklahoma,

Arkansas, South Carolina, and most of North Carolina. The IECC's 0.4
SHGC also

extends to much larger portions of California, Mississippi, Alabama and
Georgia. (See

**Attachment** 2.)

In the southern parts of the existing ENERGY STAR Central zone, there is
also a

big difference in U-factor requirements when compared to the IECC. Under
the IECC,

as indicated in **Attachment** 1, U-factors up to 0.75 are permitted
only in Florida, in the

southernmost parts of California, in southwest Arizona, and in the
southern ¼ of Texas,

Louisiana, Mississippi, Alabama and Georgia. Current ENERGY STAR
requirements

allow the 0.75 U-factor requirement to extend further to almost all of
Texas (except the

panhandle), the southern edge of New Mexico, all of Louisiana, and half
of Mississippi,

Alabama and Georgia. As a result, we recommend lowering the Southern
line to

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 10**

require a 0.40 maximum U-factor in all but the southernmost portions of
the U.S. Thus,

cities like Charlotte, Dallas, Las Vegas, Memphis, and Washington, DC,
which all could

greatly benefit from both heating and cooling savings attributable to
low U-factors and

SHGCs, would be appropriately positioned under such new ENERGY STAR
criteria. (See

**Attachment** 3).

**C. ENERGY STAR Southern**

Similar to the Northern zone, there are some areas of the country where
existing

ENERGY STAR criteria are still compatible with the IECC. In the Southern
zone, ENERGY

STAR's existing 0.75 U-factor requirement is equivalent to the IECC in
some areas, but

not all.

Unfortunately, promoting 0.75 U-factor fenestration does nothing to
further

energy efficient windows -- 97% of the product lines currently rated
through NFRC have

U-factors of 0.75 or better. However, it is understandable that the
program has focused

solely on solar heat gain in the south. To remain only equivalent to the
IECC (if that is

to be the goal), we do not oppose leaving the existing Southern zone
0.75 U-factor and

0.4 SHGC requirements as is. However, the current shape of the Southern
zone must

be minimized to match the stringency of the IECC's U-factor
requirements. As noted

above, to match IECC, the Southern zone must be limited to a much
smaller area of the

country, specifically areas below 2,000 HDD. The current ENERGY STAR
boundary for

the Southern zone extends to locations with HDD well above 2,000.

Under the IECC, as indicated in **Attachment** 1, U-factors up to 0.75
are

permitted only in Florida, in the southernmost parts of California, in
southwest Arizona,

and in the southern ¼ of Texas, Louisiana, Mississippi, Alabama and
Georgia. To

match the IECC, we propose that the Southern line be lowered as
indicated in

**Attachment** 3, which is also consistent with our recommendations
above for the

Central zone and with the IECC.

**D. Fenestration Air Leakage Requirements in the IECC**

As discussed above, ENERGY STAR has no maximum air leakage requirements

for fenestration. Ironically, even predecessors to the IECC, which for
the most part

ignored energy efficiency requirements for fenestration, contained
maximum air leakage

rates. ENERGY STAR's failure to prescribe air leakage rates leaves out
an integral

component of the complete energy efficiency package, and theoretically,
allows

efficiency gains achieved through high performance window components to
be offset by

losses through fenestration product air leakage. Presumably, ENERGY STAR
has not

included air leakage because of a lack of an NFRC certified-rating.
Fortunately, NFRC

recently approved its air leakage rating for certification and is ready
to move forward to

provide this rating. We recommend that DOE phase in a requirement for
this rating, set

no higher than the current IECC standard -- 0.3 cfm/ft 2 . The
requirement could be

***Comments on Modification of Energy Star***

***Window & Door Criteria***

**Page 11**

phased in either by accepting alternative air leakage certifications for
a phase-in period

or simply postponing the effective date for this new criteria.

**E. Summary of Proposals for ENERGY STAR to Equal the IECC**

To catch up to the IECC, ENERGY STAR could revise its standards to have
the

following breakdown (A map of these proposed ENERGY STAR requirements to
match

the IECC is in **Attachment** 3):

**ENERGY STAR**

**Zone HDD U-factor SHGC Air Leakage**

**Northern** 6,000 and above 0.35 Any 0.3 cfm/ft 2

**Central** 2,000 -- 5,999 0.40 0.40 0.3 cfm/ft 2

**Southern** 1,999 and below 0.75 0.40 0.3 cfm/ft 2

**ENERGY STAR DOORS AND SKYLIGHTS**

There has been considerable discussion regarding new ENERGY STAR

requirements for doors. We believe that the criteria we have set forth
above are

entirely appropriate and should be applied to windows **and** doors (and
skylights, with

the exception of U-factor). This approach would be consistent with the
IECC. The

IECC sets fenestration U-factor, SHGC and Air Leakage requirements for
all doors in

new homes, additions and replacements.12 Under the IECC, "fenestration"
is defined

as:

**FENESTRATION. Skylight**s, roof windows, vertical windows (whether

fixed or moveable), **opaque door**s, **glazed door**s, glass block, and

**combination opaque/glazed door**s.

Likewise, the IECC requirements for additions and replacement
fenestration also

include all doors: "The U-factor of each individual **fenestration**
product (windows, doors

and skylights) shall be used to calculate an area-weighted average
fenestration product

U-factor . . . which shall not exceed the applicable listed values in
Table 502.2.5 . . . ."

12 The IECC contains limited U-factor exceptions for skylights in
northern climate zones -- the

maximum U-factor for skylights is 0.5. *See also* n.3 above.

and **"Fenestration** products used in additions and as replacement
windows in

accordance with this section shall also meet the \[SHGC\] requirements
of Section

502.1.5 in locations with HDD less than 3,500." (See **Attachment 1**
for the IECC's

replacement fenestration U-factor and SHGC requirements.)

Thus, the best, most consistent, and most appropriate, criteria for
ENERGY STAR

doors would be to apply the same requirements as ENERGY STAR windows.
This would

be in line with the IECC requirements for doors, and it would provide a
simple consumer

recommendation across energy efficient fenestration product lines. In
any event, we

recommend that all doors with any glazing comply with the same window
criteria.

\##

NOTE: Attachments would not print in this format.

October 1, 2001

Mr. Gary Curtis

D & R International

147 Commercial Street NE

Salem, OR 97301

Dear Gary:

This letter is to officially express the concern and reservations of the
Window & Door Manufacturers Association (WDMA) regarding proposed
changes in the Energy Star program. The Energy Star program has proven
to be valuable in the marketplace and is just now gaining greater
recognition.

The nature and scope of the proposed changes obviously have a
significant bearing on the future direction of Energy Star. We recognize
the desire to make the program as "simple" as possible for the
end-consumer, but at the same time, we strongly feel that the program
must be based upon good, credible science. The proposal to actually
initiate two significant changes in the program in a relatively short
timeframe appears to be rather hasty and unnecessary. We strongly feel
that DOE should consider just "Step 1" at this time and that a longer
period of review and input by the industry be created.

We have received technical information from reliable sources that
several of the proposed changes will result in true high-performance
products losing their Energy Star rating due to calculations of their
SHGC's. We strongly feel that it is ultimately in the best interest of
America's consumers if the Energy Star program actually encouraged
innovation and unique solutions to energy conservation rather than
attempting to "standardize" or homogenize all products together.
Likewise, we are also concerned over proposals to establish separate
criteria for glazed and unglazed exterior doors.

We are not aware of any mandated deadlines which are requiring immediate
action by DOE on this issue. Sweeping changes such as the ones proposed
must have the involvement and support of everyone within the industry.
As stated earlier, WDMA can recognize some merit or value to the
proposed changes in Step 1, but the additional changes contained in Step
2 appear to be unnecessary and, in fact, counter-productive. With that
in mind, WDMA is urging an extended period of review and discussion
prior to implementation for those changes outlined in Step 1 to insure
adequate input from the industry. I can pledge to you that WDMA and its
membership would be willing to participate in any meetings or conference
calls on the issue.

Sincerely yours,

Alan J. Campbell, CAE

President

> \-\-\-\--Original Message\-\-\-\--\
> **From:** Nancy\
> **Sent:** Tue 9/18/2001 3:53 PM\
> **To:** Windows\
> \
> **Subject:** Proposed Changes to EnergyStar
>
> September 18, 2001\
> Mr. Gary Curtis                                                
>         Fax:  503.364.4146\
> D&R International\
> 147 Commercial Street NE\
> Salem, OR 97301\
> \
> RE:     Proposed changes to EnergyStar®\
> \
> Dear Mr. Curtis:\
> \
> This is in response to the e-mail dated September 15, 2001, from
> William\
> Noel, Manager, Energy Star Program.    Mr. Noel indicates that the
> U-Factor\
> will change for the Southern Region from the present 0.75 to 0.35
> effective\
> January 1, 2003.  It will be impossible to attain a level of 0.35 in
> Florida\
> and this requirement will virtually put aluminum window manufacturers
> in\
> Florida out of business (or at the very minimum, unable to participate
> in\
> the EnergyStar program).\
> \
> As you know, in the Northern climate, EnergyStar windows reduce heat
> loss;\
> in the Central climate, windows reduce both heat loss and solar heat
> gain;\
> and in the Southern climate, windows reduce solar heat gain,
> necessitating\
> different criteria for each climate.   While a single criteria may be
> easier\
> for the consumer to understand, it is unrealistic and unreasonable to
> make\
> all of these climates adhere to the same criteria.\
> \
> I strongly urge EnergyStar to reconsider its position on this
> criteria\
> change.\
> \
> Sincerely,\
> \
> Custom Window Systems, Inc.\
> \
> \
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\
> John Cwik\
> President\
> /n\
> N:\\EnergyStar\\Curtis.91701L.doc

November 13, 2023

#### Mr. Gary Curtis

D & R International

147 Commercial Street NE

Salem, OR 97301

E-mail: <garyc@drintl.com>

Fax: 503.364.4146

Re: Comments to DOE's Proposed Revisions to Energy Star Window Criteria

Dear Mr. Curtis:

I have been authorized to express the following comments on behalf of
Pilkington North America, Inc., PPG Industries, Inc. and AFG Industries,
(referred to in this letter for simplicity as the " Three Glass
Manufacturers" or "TGM") to the two-step changes that have been proposed
to the criteria for the Energy Star Window and Door Program as outlined
in William Noel's letter of August 31, 2001 ("DOE Proposal"). Consistent
with our e-mail exchange, I appreciate your willingness to receive and
consider these comments through September 28, 2001.

As you know Gary, all Three Glass Manufacturers have been directly
involved in various discussions on revisions to Energy Star Windows. As
background for this level of interest, the TGM represent over 60% of the
glass sold into the residential market, including a wide range of energy
efficient products.

The TGM have reviewed the Step 1 and Step 2 proposed revisions to Energy
Star Windows and have achieved a technical consensus that DOE's proposed
revisions are not beneficial and, therefore, the TGM urges DOE to
consider the alternative proposals which are outlined in the attached
Appendix. The consensus reached by the TGM regarding the proposed
revisions is as follows.

Step 1 of DOE's Proposal is unacceptable. It will increase energy
consumption and contrasts significantly from the International Energy
Conservation Code ("IECC) relative to the 2000 HDD line for the
"Central" geographical region of the United States.

As an alternative, the TGM proposes a Step 1 revision that will result
in energy savings and be consistent with the IECC relative to energy
conservation requirements and geographical divisions.

Regarding Step 2 of the DOE's proposal, the TGM is opposed to the single
U-factor / SHGC limit for the entire USA. Whereas, such an approach can
easily be applied to household appliances, it is simply unrealistic and,
quite frankly, detrimental as a vehicle to promote energy conservation
and the use of renewable energy sources in the diverse weather
environments found across the United States.

We would particularly encourage DOE to reconsider its proposal to apply
the IECC's most severe, southern region SHGC of 0.40 throughout all
climatic regions of the United States. The application of such a SHGC
limit value in the central U.S. and all of the northern U.S. is
completely unjustified by any technical or engineering analysis. In that
regard, the IECC imposes no such SHGC limitation on any region above
3,500 HDDs. Moreover, our calculations show that adherence to step 2 of
DOE's Proposal will actually result in an **[increase]{.underline}** in
energy consumption in the north and central regions of the United
States. Our calculations show that a typical new home in the northern
region (above 6000 HDDs) will experience an annual reduction in energy
consumption of 2.3 million Btu's if windows having a U-factor of 0.35
and a SHGC of 0.50 are used, rather than windows having a 0.35 U-factor
and a 0.40 SHGC as outlined in step 2 of the DOE Proposal. Similarly, a
new home in the central region (between 3500 and 6000 HDDs) would
experience an annual reduction of energy usage of 1.1 million Btu's.

DOE's Step 2 Proposal is also completely inconsistent with the
Congressional mandate resulting in the creation of the Energy Star
Program. The Congressional objective is to increase energy efficiency
and reduce the Country's dependence on non-renewable sources of energy.
The adoption of a national SHGC of 0.40 will not advance either
objective. While the 0.40 SHGC limit may reduce peak load demands during
a few extreme days of heat in the summer, it will only do so at the
expense of a significant increase in overall energy consumption
throughout the remainder of the year.

As a result of the overall energy consumption increase, the TGM are
completely and uniformly opposed to the second step of DOE's Proposal.
It is not supported in any manner by the requirements of the IECC.
Indeed, it has no technical justification at all. It will result in an
increase in energy usage in the north and central regions of the United
States. At the same time, it will reduce the benefits that can be
derived from passive solar heat gain through the widows by homeowners in
the central and northern regions of the United States. The TGM urges DOE
to adopt our Step 2 proposal as set out in the attached Appendix.

The TGM's proposals also meet or exceed all changes resulting from the
adoption of Title 24 in California and the requirements of the IECC.
They are technically sound and accomplish the twin objectives of the
Energy Star Program, namely, energy conservation and encouraging the use
of renewable energy sources.

We urge you to adopt the changes to the program articulated in the
attached Appendix. If there remains major opposition from window
manufacturer's regarding the proposed changes within the program over
the next 15 months, then DOE should re-open the comment period relative
to the second step of its proposal. If DOE is unwilling to extend the
time necessary to hear additional industry concerns respecting the
second step of its proposal, the TGM urges DOE to consider the TGM
second step as articulated in the attached

> Very truly yours,

Thomas S. Zaremba, on behalf of:

Pilkington North America, Inc., by Paul M. Gore

PPG Industries, Inc., by Al Lutz, and

AFG Industries, Inc. by Thomas J. Mewbourne

# 

cc: William Noel,

Department of Energy

Office of Building Technologies

1000 Independence Ave., SW

Room 5E-098 EE042

Washington D.C. 20585

e-mail: <william.noel@hq.doe.gov>

fax: 202.586.1233

# 

# [Appendix]{.underline}

## Step 1 - Change in Energy Star Criteria

**U-factor SHGC**

**Northern Region** 0.35 Any

\> 6000 HDD

### Central Region 0.40 0.55

> 3500 - 6000 HDD
>
> **Southern Region** 0.50 0.40
>
> \< 3500 HDD
>
> U-factor and SHGC values represent maximum values

##### 

###### Step 2 - Change in Energy Star Criteria

**U-factor SHGC**

**\> = 3500 HDD** 0.35 Any

**\< 3500 HDD** 0.50 0.40

####### U-factor and SHGC values represent maximum values

41827_1

William Noel October 5, 2001

Program Manager, Energy Star

U.S. Department of Energy

c/o Gary Curtis

D&R International

147 Commercial Street NE

Salem, OR 97301

E-mail: <windows@drintl.com>

Fax: (503) 364-4146

Re: Proposed Revisions: Energy Star Windows

Dear Mr. Curtis;

As a partner in the Energy Star Window program, we have a vested
interest in promoting and selling energy efficient products. Thank you
for the opportunity to comment on the proposed revisions to the Energy
Star Windows program.

We also have a vested interest in ensuring that the program recognizes
the benefit of a wide range of energy efficient products that are
available and used throughout the market today.

Through our involvement and success in promoting and marketing Energy
Star Windows, we believe that the current DOE proposal for Phase I and
Phase II is unacceptable. While we acknowledge the need to bring the
Energy Star Windows program in line with existing energy codes, the
current program goes too far. Specifically, we believe that the current
program will exclude the use of window products that are technically
proven to be energy efficient products.

On that basis, we are writing to support and endorse the attached
proposal, sent to you previously from Pilkington North America, AFG and
PPG. As stated, these three glass manufacturers represent over 60% of
the glass sold into the residential market including a wide range of
energy efficient products.

Based on the merits of the attached proposal in addition to our market
knowledge and promotion of Energy Star windows, we recommend that DOE
adopt the proposal as outline in the attached. To exclude the
recognition of energy efficient products within the Energy Star Window
program is not appropriate to the overall desire to reduce energy demand
and reduce energy costs.

Thanks for the opportunity to comment on this. Again, we recommend
serious consideration and adoption of the attached proposal.

Sincerely,

Timothy E. Slattery

President, Denver Division & Champion Western factory

> \-\-\-\--Original Message\-\-\-\--\
> **From:** Larsen, Jim - CORP\
> **Sent:** Fri 8/3/2001 6:40 PM\
> **To:** Windows\
> **Cc:**\
> **Subject:** Comments on Energy Star Windows
>
> Cardinal Glass Industries has reviewed and agrees with the
> recommendations of BBRS (the attached pdf file is the same as you\'ve
> received directly from Garrett Stone).
>
> The proposed alignment of the Energy Star Windows program to equal or
> exceed current energy codes is critical not only to the Energy Star
> Windows program, but in maintaining the momentum on IECC adoption
> across the country.  In it\'s efficiency determination on the 2000
> IECC, the Department of Energy specifically referenced the Solar Heat
> Gain limits as a substantive improvement in stringency.  The
> California Energy Commission in the AB970 proceedings endorsed the
> importance of SHGC in electrical capacity planning for the state. 
> These new Energy Star zones and requirements will have significant
> impacts on peak electrical demands throughout a large section of the
> county.  Any program that reduces peak loads and electrical
> consumption will have positive impacts on air quality and pollution
> abatement
>
> My experiences as chairman of the NFRC Technical Committee, an
> ex-offico member of the NFRC board of directors, and through my job
> responsibilities as an energy code consultant, I am qualified to
> comment on the Energy Star Window program.  As a national manufacturer
> that makes energy efficient glass products Cardinal supports these
> recommendations, not only for the positive impact it will have in
> helping to solve our national energy crisis, but for the quality of
> life improvements it will bring to our 4,000 employees in 10 states
> across the county.
>
> Regards,\
> Jim Larsen
>
> \<\<E-StarComments2001(BBRS-Final).pdf\>\>

775 Prairie Center Drive

Eden Prairie MN 55344

952.935.1722

Mr. Gary Curtis

D&R International

147 Commercial Street, NE

Salem, OR 97301

Re: Department of Energy's Energy Star Windows Draft Proposal dated

August 31, 2001

Dear Gary:

I am writing to offer the comments of Cardinal Glass Industries on the

Department of Energy's ENERGY STAR Windows Draft Proposal dated August

31, 2001. As the nation's largest manufacturer of insulating glass units
and

energy efficient glazing for the window industry, we are very interested
in

the ENERGY STAR Windows program. As you know, for a number of years, we

have been active on the local, state and national level in supporting
efforts

to encourage or require energy efficient fenestration through building
and

energy codes and voluntary programs and, specifically, have been an
active

supporter of ENERGY STAR.

First, let me summarize our thinking and recommendations:

• First, we strongly support the Department of Energy's efforts to

promptly bring the ENERGY STAR program into compliance with

national energy code standards (e.g., the IECC) and recent

state-specific code changes and adoptions (e.g., California,

Texas, South Carolina, New York, etc.). In this regard, we

believe that phase 1 (2002) of the Department's proposal is the

**absolute minimum** that must be done.

• Second, we fully appreciate the Department's effort in phase 2

\(2003\) of its proposal to aggressively and boldly put ENERGY STAR

ahead of the energy codes while simplifying the marketing

message consistent with other ENERGY STAR programs. At the

same time, we are concerned that some window

manufacturers presently in the program may have real

difficulty transitioning so rapidly to the new requirements,

Mr. Gary Curtis September 21, 2001

Page 2 of 6

particularly those located in Florida and south Texas. While

the Department will have to make the ultimate call on

balancing these considerations, we think, at a minimum, the

Department should consider providing a longer transition

period between phase 1 and 2, or perhaps delaying the

implementation of phase 2 indefinitely.

In phase 1, the Department proposes to modify the existing ENERGY STAR

Northern, Central, and Southern climate zone framework to meet and, in

some cases, exceed current national and state building energy efficiency

code standards. This phase of the Draft Proposal is consistent with the

recommendations by Garrett Stone of Brickfield, Burchette, Ritts &
Stone,

PC (submitted on August 3, 2001). We previously offered comments

endorsing these BBRS recommendations, and we continue to support them.

Modifying the ENERGY STAR criteria in this manner would be a
considerable

improvement over the existing program. The revised map properly reflects

the climate zones incorporated into the IECC, with modifications
primarily

to reflect unique California energy code requirements. Reducing the SHGC

maximum for the Central region to 0.40 is necessary for compliance with

the SHGC requirement of the IECC and to meet the new California

standard. Moreover, extending the low SHGC requirement throughout the

Central region (above 3500 HDD) would make the requirements more

stringent than the energy code, and, as a result, can be expected to
improve

comfort, lower electrical peak demands, reduce pollution, and reduce

consumer cost (through reduced air conditioner sizes and reduced

electrical use during high-price time periods.) Finally, aluminum window

manufacturers would continue to be able participate in the Southern

region.

**In short, we believe that the overall phase 1 proposal will
significantly**

**improve nationwide residential building energy efficiency and should
be**

**adopted as soon as reasonably feasible.**

We also support the **concept** of a single set of national criteria as
contained

in phase 2 of the Department's Draft Proposal, although we have some

reservations about certain aspects of the proposal at this time. A
single

standard for all climates is an excellent approach to stay well ahead of

building energy codes, while at the same time promoting available,
cost-effective

high performance window technology. A single standard would

also be a simple consumer message, eliminating any confusion over Mr.
Gary Curtis September 21, 2001

Page 3 of 6

climate regions, and much more closely resembling the
"one-size-fits-all"

nature of programs in place for other ENERGY STAR products, like
appliances,

electronics, etc.

It is safe to say that the single national standard (phase 2) contained
in the

Draft Proposal will give the Department significant breathing room
without

having to worry about repeatedly changing the criteria to stay one step

ahead of constantly improving building energy codes. Even considering
the

pace of improvements to building energy codes over the past few years,
it

will take some time for building energy codes to reach the proposed

standard. Such a move would also position ENERGY STAR to significantly

transform the window market above the baseline set by existing building

energy efficiency codes.

The use of a single criterion is particularly appealing regarding
control of

summer solar heat gain. Control of summer solar gain is an issue

throughout virtually all of the country. Even when a home is located in
the

far north, like Bismarck, North Dakota or Minneapolis, Minnesota, such

homes have significant solar gain concerns in the summer, requiring

substantial cooling and creating significant comfort issues for
non-solar-control

fenestration. Although both of these locations are considered to be

"heating-dominated" climates with close to or above 8000 HDD, the
cooling

(1%) design temperatures are still rather substantial -- 90 and 88
degrees,

respectively, requiring considerable cooling in the summer -- in fact,
most

of the electrical utilities that serve the northern part of the country
are

summer-peaking as a result of air conditioning load. I have attached a

graph showing summer and winter design temperatures relative to HDD for

RESFEN's 48 sample cities.

Unlike winter design temperatures, this graph demonstrates that summer

design temperatures do not sharply decline relative to increasing HDD.

Given the pervasiveness of solar gain control issues nationwide, we
think it

would be reasonable to establish a maximum 0.4 SHGC criteria for ENERGY

STAR windows across the nation.

A universal 0.35 U-factor is more problematic, however, because of the

substantial market presence of the aluminum window industry in certain

cooling-driven climates, such as south Texas and Florida. It is
important

that this market sector continue transformation toward more energy

efficient products. The progress being made in this sector could be
lost,

however, if the Department moves too fast and closes this sector out of
the Mr. Gary Curtis September 21, 2001

Page 4 of 6

program during the transition. In other words, the policy decision by
the

Department must recognize that establishing a maximum 0.35 U-factor in

these cooling-driven climates will almost certainly act as a
disincentive for

this segment of the industry to adopt solar control glazing (since this

technology will no longer qualify these products as Energy Star),
risking the

loss of potential energy efficiency gains from this measure. As a
result, we

ask the Department to carefully consider whether the rewards outweigh

the risks from this approach in the short run.

If the Department chooses to move forward with the single nationwide

standard, the aggressive 1-year phase-in period between steps 1 and 2 of

the proposal will likely exacerbate any problems. An objective of
launching

step 1 of the proposal in 2002 is reasonable, although window

manufacturers should be given sufficient notice to change their
labeling.

Manufacturers are currently used to the three-zone approach, and, with

the exception of the modification of the boundaries of the climate
regions,

the program will still be available to the same window manufacturers as

before, although some may have smaller areas in which their product will

qualify. However, with the single nationwide criterion proposed for
phase

2, the program charts a new, significantly different course. While we
can

see the potential for national benefits from that change of course and
we

are currently capable of supplying glazing products that will help to
meet

the proposed single national standard, a much longer implementation

period will allow window manufacturers to get up to speed, and get on

board, with the new program. Also, manufacturers who wish to participate

in the ENERGY STAR program, but are used to supplying high U-factor

products in the south, may require a longer lead time to evaluate and

prepare for the new requirements if they wish to continue to participate
in

the program.

Finally, it is important to note that we think that the Department's
two-phase

proposal illustrates the stark policy choice -- simplicity (one

nationwide standard) versus reflecting regional climate differences
(three

climate zones). We simply do not see any other reasonable alternatives.

Changing from the three-zone approach to anything other than the single

"one-size-fits-all" approach should be a non-starter.

There is one issue that the Department did not address that we think is

necessary for consistency with energy codes. That issue is air
infiltration.

The codes establish a maximum air infiltration level for fenestration

products. That requirement should be incorporated into Energy Star. Mr.
Gary Curtis September 21, 2001

In summary, we thank the Department for the opportunity to comment on

its proposed revisions to the ENERGY STAR Windows program. Please
contact

me if you have any questions or concerns with regard to these comments.

Sincerely,

James E. Larsen

Director, Technical Marketing

Cardinal Glass Industries

September 27, 2001

William Noel

Program Manager, Energy Star

U.S. Department of Energy

c/o Gary Curtis

D&R International

147 Commercial Street NE

Salem, OR 97301

E-mail: <windows@drintl.com>

Fax: (503) 364-4146

Re: Proposed Revisions: Energy Star Windows

Dear Mr. Curtis;

As a partner in the Energy Star Window program, we have a vested
interest in promoting and selling energy efficient products. Thank you
for the opportunity to comment on the proposed revisions to the Energy
Star Windows program.

We also have a vested interest in ensuring that the program recognizes
the benefit of a wide range of energy efficient products that are
available and used throughout the market today.

Through our involvement and success in promoting and marketing Energy
Star Windows, we believe that the current DOE proposal for Phase I and
Phase II is unacceptable. While we acknowledge the need to bring the
Energy Star Windows program in line with existing energy codes, the
current program goes too far. Specifically, we believe that the current
program will exclude the use of window products that are technically
proven to be energy efficient products.

On that basis, we are writing to support and endorse the attached
proposal from Pilkington North America, AFG and PPG. As stated, these
three glass manufacturers represent over 60% of the glass sold into the
residential market including a wide range of energy efficient products.

Based on the merits of the attached proposal in addition to our market
knowledge and promotion of Energy Star windows, we recommend that DOE
adopt the proposal as outline in the attached. To exclude the
recognition of energy efficient products within the Energy Star Window
program is not appropriate to the overall desire to reduce energy demand
and reduce energy costs

Thanks for the opportunity to comment on this. Again, we recommend
serious consideration and adoption of the attached proposal.

Sincerely,

Terry Rex

Director of Marketing

BFRich Co. Inc.

www.bfrich.com

> \-\-\-\--Original Message\-\-\-\--\
> **From:** Dwight_Alexander@rbpi.com\
> **Sent:** Fri 9/14/2001 5:16 PM\
> **To:** Windows\
> **Cc:**\
> **Subject:** Proposed U Value Changes
>
> The proposed decrease in Energy Star U values in the Southern U.S.
> will\
> cripple the homebuyer, homebuilder and the aluminum window
> manufacturers.\
> While we agree with the .40 SHGC, your .35 suggested U value will
> decrease\
> energy consumption in San Antonio, Texas by only .07% (using RESFEN)
> while\
> increasing the cost of the window by 34%!\
> \
> What\'s the pay-back?\
> \
> Dwight Alexander\
> Alenco Windows

![](media/image21.png)

**[\_\_\_\_\_\_]{.underline}**

November 13, 2023

Gary Curtis

D&R International

147 Commercial Street NE

Salem, OR 97301

> Re: Proposed changes in U-Factor Requirements for Energy Star

Dear Mr. Curtis

Once again, The Department of Energy (DOE), has been working on the
development of U-Factor and SHGC requirements for Windows, Doors, and
Skylights for Energy Star Compliance, without the input of the all
segments of Fenestration Industry. It is unconscionable that a U.S.
Agency, which is charged with improving energy efficiency in this
country, would leave the Southern Aluminum Window and Door manufacturers
out of the process. Surely, the DOE is aware that Texas and many other
Gulf and Atlantic Coastal States must balance the structural
requirements necessary to resist Hurricanes, against the desire to
improve energy efficiency. Texas\'s new building code requires
protection from windborne debris along the Coastal Regions of the state.
After queries performed today I was unable to find a window product that
had been approved as an impact resistant product, which was made of
another material other than aluminum! We want to keep the playing field
level for all of our manufacturers. We do not believe that the DOE is
working with this same goal in mind. It is not the role of government in
a free marketplace, to work on behalf of one part of an industry against
another. Most American Consumers expect the Energy Star Label to provide
a fair and honest evaluation of a products energy use. If the goal of
the DOE is to provide this type of information for consumers and reduce
energy waste, then the DOE must not work to exclude Aluminum from the
market. Let us remember that this is America, and our people can make
their own decisions on what level of energy performance they want and
can afford from the window products they choose to purchase. We at
Atrium Companies Inc. and other groups such as The Architectural
Manufacturers Association of Florida, (AMAF), The Efficient Windows
Collaborative (EWC) and Alliance to Save Energy (ASE), have been working
to improve energy efficiency in Texas through educating all Window and
Door Manufacturers of the advantages of improving their products and
testing to attain the Energy Star Label. If the DOE is successful in
implementing this plan, the effect will be to halt all Aluminum
Manufacturers from working towards the this goal of attaining the label,
as it will be far out of reach, as the DOE and other special interest
groups are well aware. The proposed U-Factor of 0.35 for all of the U.S.
is absurd and can not be defended with scientific data as to it
necessity for Texas. As all recent studies have been pointing out, if
your goal is to conserve energy in Texas, a .40 SHGC is the target, not
a low U-Factor. U-Factor, while extremely important in Minneapolis, it
is not at nearly as important in Texas and other Southern States. It is
clear that DOE's Proposal to go to a .35 U-Factor nationwide, was not
meant for the public, or our members to read, or participate in the
process. It is my opinion that if Step 2 is implemented and EWC
continues to support Energy Star as the optimum selection, DOE and the
EWC will lose all the trust and credibility they have gained in the past
18 months, and Texas manufacturers will resist ever more strongly
against any Federal efforts for energy standards. All window and door
manufacturers must use their collective voices to inform the DOE, Energy
Star, and their U.S. Senators and Representatives regarding the issues
in Texas. We will ask our Texas Congressional Delegation to begin an
investigation, as to the mission of the DOE and its relevance in
today\'s society!

Sincerely,

Joseph L. Biegel

Director -- Finance and Administration

Cc: AMAF Members

William Noel, Manager Energy Star Program, Office of Building
Technology, State

and Community Programs Energy Efficiency and Renewable Energy

September 30, 2001

#### Mr. Gary Curtis

D & R International

147 Commercial Street NE

Salem, OR 97301

E-mail: <garyc@drintl.com>

Fax: 503.364.4146

Re: Comments to DOE's Proposed Revisions to Energy Star Window Criteria

Dear Mr. Curtis:

I have been authorized to express the following comments on behalf of
Pilkington North America, Inc., PPG Industries, Inc. and AFG Industries,
(referred to in this letter for simplicity as the " Three Glass
Manufacturers" or "TGM") to the two-step changes that have been proposed
to the criteria for the Energy Star Window and Door Program as outlined
in William Noel's letter of August 31, 2001 ("DOE Proposal"). Consistent
with our e-mail exchange, I appreciate your willingness to receive and
consider these comments through September 28, 2001.

As you know Gary, all Three Glass Manufacturers have been directly
involved in various discussions on revisions to Energy Star Windows. As
background for this level of interest, the TGM represent over 60% of the
glass sold into the residential market, including a wide range of energy
efficient products.

The TGM have reviewed the Step 1 and Step 2 proposed revisions to Energy
Star Windows and have achieved a technical consensus that DOE's proposed
revisions are not beneficial and, therefore, the TGM urges DOE to
consider the alternative proposals which are outlined in the attached
Appendix. The consensus reached by the TGM regarding the proposed
revisions is as follows.

Step 1 of DOE's Proposal is unacceptable. It will increase energy
consumption and contrasts significantly from the International Energy
Conservation Code ("IECC) relative to the 2000 HDD line for the
"Central" geographical region of the United States.

As an alternative, the TGM proposes a Step 1 revision that will result
in energy savings and be consistent with the IECC relative to energy
conservation requirements and geographical divisions.

Regarding Step 2 of the DOE's proposal, the TGM is opposed to the single
U-factor / SHGC limit for the entire USA. Whereas, such an approach can
easily be applied to household appliances, it is simply unrealistic and,
quite frankly, detrimental as a vehicle to promote energy conservation
and the use of renewable energy sources in the diverse weather
environments found across the United States.

We would particularly encourage DOE to reconsider its proposal to apply
the IECC's most severe, southern region SHGC of 0.40 throughout all
climatic regions of the United States. The application of such a SHGC
limit value in the central U.S. and all of the northern U.S. is
completely unjustified by any technical or engineering analysis. In that
regard, the IECC imposes no such SHGC limitation on any region above
3,500 HDDs. Moreover, our calculations show that adherence to step 2 of
DOE's Proposal will actually result in an **[increase]{.underline}** in
energy consumption in the north and central regions of the United
States. Our calculations show that a typical new home in the northern
region (above 6000 HDDs) will experience an annual reduction in energy
consumption of 2.3 million Btu's if windows having a U-factor of 0.35
and a SHGC of 0.50 are used, rather than windows having a 0.35 U-factor
and a 0.40 SHGC as outlined in step 2 of the DOE Proposal. Similarly, a
new home in the central region (between 3500 and 6000 HDDs) would
experience an annual reduction of energy usage of 1.1 million Btu's.

DOE's Step 2 Proposal is also completely inconsistent with the
Congressional mandate resulting in the creation of the Energy Star
Program. The Congressional objective is to increase energy efficiency
and reduce the Country's dependence on non-renewable sources of energy.
The adoption of a national SHGC of 0.40 will not advance either
objective. While the 0.40 SHGC limit may reduce peak load demands during
a few extreme days of heat in the summer, it will only do so at the
expense of a significant increase in overall energy consumption
throughout the remainder of the year.

As a result of the overall energy consumption increase, the TGM are
completely and uniformly opposed to the second step of DOE's Proposal.
It is not supported in any manner by the requirements of the IECC.
Indeed, it has no technical justification at all. It will result in an
increase in energy usage in the north and central regions of the United
States. At the same time, it will reduce the benefits that can be
derived from passive solar heat gain through the widows by homeowners in
the central and northern regions of the United States. The TGM urges DOE
to adopt our Step 2 proposal as set out in the attached Appendix.

The TGM's proposals also meet or exceed all changes resulting from the
adoption of Title 24 in California and the requirements of the IECC.
They are technically sound and accomplish the twin objectives of the
Energy Star Program, namely, energy conservation and encouraging the use
of renewable energy sources.

We urge you to adopt the changes to the program articulated in the
attached Appendix. If there remains major opposition from window
manufacturer's regarding the proposed changes within the program over
the next 15 months, then DOE should re-open the comment period relative
to the second step of its proposal. If DOE is unwilling to extend the
time necessary to hear additional industry concerns respecting the
second step of its proposal, the TGM urges DOE to consider the TGM
second step as articulated in the attached

> Very truly yours,

Terry Rex

> BFRich Co. Inc., on behalf of:

Pilkington North America, Inc., by Paul M. Gore

PPG Industries, Inc., by Al Lutz, and

AFG Industries, Inc. by Thomas J. Mewbourne

# 

cc: William Noel,

Department of Energy

Office of Building Technologies

1000 Independence Ave., SW

Room 5E-098 EE042

Washington D.C. 20585

e-mail: <william.noel@hq.doe.gov>

fax: 202.586.1233

# 

# [Appendix]{.underline}

## Step 1 - Change in Energy Star Criteria

**U-factor SHGC**

**Northern Region** 0.35 Any

\> 6000 HDD

### Central Region 0.40 0.55

> 3500 - 6000 HDD
>
> **Southern Region** 0.50 0.40
>
> \< 3500 HDD
>
> U-factor and SHGC values represent maximum values

##### 

###### Step 2 - Change in Energy Star Criteria

**U-factor SHGC**

**\> = 3500 HDD** 0.35 Any

**\< 3500 HDD** 0.50 0.40

####### U-factor and SHGC values represent maximum values

41827_1

![](media/image22.png){width="6.496527777777778in" height="8.375in"}