With the activation of Energy Star Version v6.0 just around the corner (Jan. 1, 2015, for all but the Northern Zone), we will be pulling up new qualifying criteria tables for U-factor, SHGC and now Air Leakage. For anyone who has not yet read the new version, the meat of it is in these tables. Beyond that, is much else new?
This summer, the Environmental Protection Agency issued label guidance for identifying window, door and skylight products that meet Energy Star Version 6.0 requirements. Section I of the document outlines labeling of products; Section II describes the proper use of display unit labels; and Section III presents guidelines for use of labels on packaging that obscures product labels. Guidelines for label design, size and placement on the product or packaging are listed in a “dos and don’ts” format.
If the guidelines are followed, Energy Star labeling usually isn’t particularly complicated. However, the rollout of v6.0 has an unusual circumstance: There is a different transition schedule between v5.0 and v6.0 in regard to U-factor and SHGC requirements in the Northern Climate Zone versus other climate zones. This discontinuity introduces potential confusion in both the application and interpretation of labels.
A Risk for Confusion
Beginning Jan. 1, 2015, manufacturers may immediately apply the appropriate labels to products that meet the v6.0 specification for the North-Central, South-Central, and/or Southern Climate Zones. However, they may continue to use the v5.0 product specification for the Northern Zone until January 1, 2016.
This poses a risk for confusion over the allowance of windows meeting v5.0 requirements in the Northern Zone, which is particularly concerning in terms of the various rebate and financial incentive programs that tie requirements to the latest version of Energy Star.
For example, legislation currently before the U.S. Senate—S. 2260 (The Expire Act of 2014)—offers homeowners a 10 percent federal tax credit only for windows meeting Energy Star Version 6 requirements. Thus, windows that meet the Version 5 requirements in the Northern Zone may be perceived as non-compliant even though they are qualified until January 1, 2016.
To reduce confusion, AAMA requested that the table used by the EPA to designate v6.0 U-factor and SHGC requirements be amended to provide both the 2015 and 2016 criteria under the common heading of “Energy Star Version 6.” This format eliminates the need to use two separate tables to determine product compliance. Plus, it may prevent a substantial number of program providers from improperly excluding homeowners from access to rebates and incentives for purchasing qualified Energy Star windows in the Northern Zone throughout 2015.
Energy Star “Certification”
AAMA also noted that the use of the term “Energy Star Certification” throughout the label guidance document raises a number of concerns. Energy Star has historically been deemed a “specification” or “qualification” program, which accurately represents its nature and intent. The term “certification” implies that EPA administers a detailed accreditation and testing program with ongoing audits in the role of a “certification body” as defined in ISO/IEC 17065.
While Energy Star qualifying products must adhere to requirements achieved through third-party certification, it is misleading and confusing to consumers to refer to EPA as a certification agency or Energy Star as a certification program. AAMA therefore requested that EPA return to using the term Energy Star Qualified. However, repeated attempts to convince EPA staff met with steadfast resistance.
Indeed. New for Energy Star v6.0 is Section 3D: Installation Instructions. Wait. What? When I first learned about this, I thought, this doesn’t belong here.
I am the first to agree, teach, and promote that installation can impact the energy efficiency of fenestration. However, we already have many generic and brand-specific sources of installation instruction from the best industry resources. Why would Energy Star v6.0 provide and require its own installation instructions—especially for dozens, if not hundreds, of installation scenarios?
Those who have read the Installation Instruction section of v6.0 know that my initial reaction was unjustified. Section 3D in no way includes installation-specific instructional material. In a nutshell, it simply requires that Energy Star qualifying products “shall have installation instructions readily available online or packaged with the product.”
There are more requirements (eight in all) but the expectations are reasonable and acknowledge, “…the manufacturer cannot write installation instructions for every situation… .” This is an important disclosure.
During the v6.0 development, I read much of the stakeholder comments. In the original framework document, the proposed installation instruction criteria were much more stringent and, in my opinion, not very realistic. Fortunately, thanks to the stakeholders’ feedback, I think we ultimately reached an acceptable, happy place.
In fact, prior to the release of the final version earlier this year, if manufacturers already had installation instructional material in place, they were nearly ready for this requirement of v6.0. All that remained were a few details they might have had to add to their existing instructions such as, “A list of hardware and tools…, Proper disposal…, General guidance on safely removing old products…,” etc.
No responsible industry party denies the disservice and costly consequences of improper installation. I absolutely believe in providing installation instruction whenever possible. However, doesn’t the industry already have enough incentive to provide for and promote proper installation?
I’m very involved in industry task groups that revise and create installation instructional material. I can attest to the fact that most of the industry is bending over backward to make installation instructions better. Do we really need a tighter noose?
Jim Snyder is an AAMA-certified FenestrationMaster and InstallationMaster who shares his years of installation field experience as an industry writer, speaker, trainer and project/product consultant for dealers and manufacturers. A member of various industry organizations, Snyder also is involved in instructional document creation and revision. Contact him at firstname.lastname@example.org.