**Kolbe & Kolbe** **Millwork Co., Inc.**

[***Beautify* YOUR HOME WITH WOOD WINDOWS**]{.underline}

**1323 South 11th Ave. Wausau, WI 54401 TEL (715) 842-5666**

**RESEARCH & DEVELOPMENT DEPARTMENT FAX (715) 847-0646**

Mr. Gary Curtis 27 July 2001

D&R International EWC ES-025

147 Commercial St. NE

Salem, OR 97301

TEL (503)364-4127

FAX (503)364-4146 Subject: Energy Star Revisions

Dear Mr. Curtis,

Thank you for the opportunity to participate in today\'s conference
call. I have four suggestions.

1\. Revising Energy Star [climate area boundaries]{.underline} to be
aligned with IECC heating degree day contours seems like a logical thing
to do. This would help manufacturers to answer borderline homeowner
questions about, \"What climate area am I in?\"

2\. Please, no huge changes to Energy Star\'s [northern U
factor]{.underline}.

For Kolbe, meeting the northern U .35 is a challenge for many of our
wood & aluminum clad wood products. This requirement encouraged Kolbe to
standardize on LoE² IG. Products sent to high altitude often must be
tubed and result with U~RES~ \>.35, so we still have something to work
toward.

\> \> The central & southern possible changes I heard mentioned to keep
up with building code changes sound okay.

3\. [SHGC requirements for]{.underline} windows and [doors]{.underline}.
Kolbe makes lots of full lite patio/entry doors using LoE² with low
SHGC. Kolbe onelite windows and doors typically have SHGC~RES~ in the
.23 to .27 range. The central & southern SHGC requirements are little
challenge and could both be lowered. Some call participants mentioned
that southern SHGC of .35 or .30 might be considered but didn\'t want to
upset things.

A. Entry door category is all new, so no upsetting anything with a lower
SHGC value. B. Above paragraph shows that lower SHGC is easily
obtainable. C. Doors and sidelites for the residential market tend to
have wide stiles & rails, which result in lower \"glazing area/total
area\" than windows (assuming NFRC\'s current proposed single unit
sizes,casement \[79%\] & swing door \[57%\]), which further helps to
lower SHGC. Argument \"C.\" is a clincher.

\> \> Energy Star should require full lite entry door SHGC - southern
.30 and central .45

4\. [Air Infiltration]{.underline} could be added to Energy Star. Some
call participants mentioned that weep sealing takes place as part of
thermal tests, which allows opportunity for mfr. chicanery or test lab
slip-up. NFRC is working toward allowing the use of air values obtained
during air-water-structural tests at NFRC approved labs. I know
horizontal and vertical slider windows with sliding seals tend to have
greater air infiltration. When testing these units for high design
pressure ratings, it can be a delicate balancing act to achieve both
good air & water performance, yet still keep sill dam reasonably low.

**\> \>** Energy Star should require air value be obtained from an
AAMA/WDMA air-water-structural test by NFRC approved lab.

Thank you for your attention. If you have any additional questions,
contact Ken Wilcox TEL(715)847-0565 or FAX(715)847-0646 or Email
kwilcox@kolbe-kolbe.com

Sincerely,

KOLBE & KOLBE MILLWORK CO. INC.

Ken Wilcox

R&D Certification Engineer